Privacy Statement
At Botswana Short Term Insurance Underwriters Association, we are strongly committed to protecting your personal data and by upholding privacy, we aim to provide a safe and secure environment for you. The purpose of this Data Privacy Statement is to inform you about how we collect, use, store, make available, disclose, update, safeguard, destroy or process your personal data, further to explain your rights relating to the privacy of your personal information and how the law protects you, and how to get in touch with us for anything concerning your privacy. You may request a copy of the privacy policy.
What information we Collect
Please note that the type of information we collect may include but are not limited to;
1.1 Personal Identification Details: such as your name, contact information, National ID, email address,
1.2 Financial Information: such as bank account details.
1.3 Audio, video and other electronic data: audio, electronic, visual or similar information such as, photographs, and call recordings.
1.4 Sensitive information and data relating to criminal records and offences: such as health information and some background checking information (i.e. alleged criminal offences and records).
Purpose of Processing
The personal data we collect depends on the use of the personal data. We collect the minimum personal data necessary for the stated purposes. The purpose for processing your personal data is detailed below:
- Communicate with you and to respond to your requests, inquiries, comments and concerns.
- Carry out due diligence, identity, data validation, anti-money laundering, “Know Your Customer” and other business acceptance, vetting and risk management checks;
- Process payments, including your payments for services rendered to the Association.
- Fulfil legal and regulatory obligations, including applicable industry codes of conduct.
- Research, audit, reporting and other Association operations purposes,
Legal basis for processing:
We will use the information we collect about you in connection with the Services and for any such use, we rely on an appropriate legal ground. Where processing involves sensitive personal information, we also rely on an additional legal justification to use such information.
a. Performance of the contract with you to enable us to take steps in offering services and fulfil our obligations.
b. To meet our legal and regulatory obligations as Botswana Short Term Insurance Underwriters Association is regulated by certain industry regulators (and is required to provide some Services in accordance with relevant regulatory rules, such as financial and prudential regulations, tax rules, obligations to prevent and detect unlawful activities, among others.
c. Consent: You may also provide us with your consent to receive certain Services, marketing or communications from us (where legally required). In such situations, you are not obliged to provide your consent, and you may choose to subsequently withdraw consent at any stage once provided by sending us an email at info@bstiua.co.bw or contact us during office hours at Plot 64517 Unit 19, The Office, Gaborone. However, where you refuse to provide information that we reasonably require to provide the Services or fulfil obligations, we may be unable to proceed with the business relationship and/or we may terminate where not possible to fulfil the Services without the respective information.
d. Legitimate Interest except where the interests are not overridden by those of the data subject or processing is carried out by a public authority when performing its functions.
Recipients of your information
Botswana Short Term Insurance Underwriters Association may from time to time share your personal information with the following categories of recipients where necessary to offer, administer and manage the Services provided to you.
a. Within Botswana Short Term Insurance Underwriters Association, we may share your personal data with member entities subsidiaries for the processing purposes outlined in this Statement.
b. Insurance market participants: where necessary to offer, administer and manage the Services provided to you, such as insurers underwriters, reinsurers, Associations of Insurance Underwriters, brokers, intermediaries, assessors, claim investigators, loss adjusters and legal advisors where necessary to defend legal claims, insurance claims or claims similar in nature.
c. Internal and external auditors: where necessary for the conduct of company audits or to investigate a complaint or security threat.
d. Law enforcement bodies: where necessary to facilitate the prevention or detection of crime or the apprehension or prosecution of offenders.
e. Public authorities, regulators and government bodies: where necessary for Botswana Short Term Insurance Underwriters Association to comply with our legal and regulatory obligations.
f. Third party service providers: where we outsource our processing operations to suppliers that process personal information on our behalf. These processing operations shall remain under our control and will be carried out in accordance with our security standards and strict instruction.
Third country/ International Organisation Transfers
Botswana Short Term Insurance Underwriters Association may transfer your personal information to other countries for further processing for the purposes outlined in this Statement. We endeavour to ensure that such transfers comply with all applicable data privacy laws and provide appropriate protection for the rights and freedoms conferred to individuals under such laws.
This may include transfers to countries that the Information and Data Protection Commission consider to provide adequate data privacy safeguards. Where we transfer personal information to countries that are not subject to an adequacy decision we shall put in place appropriate safeguards, approved by the Commission and in accordance with the Data Protection Act to ensure that personal data receives an appropriate and consistent level of protection across the entities.
Direct Marketing
Botswana Short Term Insurance Underwriters Association may send you information about its services to your contacts shared with us, which may include text messages, phone calls, emails and other related platforms. If you do not wish to receive such information, you have the right to opt out of receiving such messages at no cost to you by contacting our offices.
Data Security
The security of your personal information is important to us, and we have implemented appropriate technical and organizational security measures to protect the confidentiality, integrity and availability of your personal information from unauthorised access, alteration, disclosure, or destruction, to ensure that such information is processed in accordance with applicable data privacy laws.
Data Retention
We retain appropriate records of your personal information for as long as is reasonably necessary for the purposes outlined in this statement and compliance with our legal and Where it is no longer required for the outlined purposes, we undertake to securely dispose it in a timely and consistent manner. regulatory obligations on how long such data is required to be retained.
Data subject request rights
• Access and request a copy of your personal data
• Request rectification where accuracy is disputed.
• Request the erasure of your personal information where erasure is subject to legal or statutory obligations to which we are subject.
• Object to the processing of your personal data under certain circumstances
• Right to withdraw consent given for the processing of personal data at any time.
• Request that your personal information be provided to you or a third party of your choice in portable form to enable its reuse. That is, in a structured, commonly used and machine-readable format transmittable to another data controller without hindrance. Provided that the processing is based on consent or contract, carried out by automated means, and where technically feasible, directly transmittable.
• We do not make any decision solely based on automated processing that produce legal or similarly significant effects.
Please note, the above rights are subject to legal and regulatory requirements.
If you have any questions about the content of this Statement or the rights conferred to you under the applicable data privacy laws, or a complaint regarding the processing of your personal data, you may contact our office at:
Data Protection officer: Ms Aobakwe Kwape
Email info: aobakwe.kwape@bstiua.co.bw
Contact number: 73886606/ 74434273
Postal Address: P O BOX 715, Gaborone
After engaging us, should your complaint not be addressed to your satisfaction, you have the right to lodge a complaint with the Information and Data Protection Commission.
Changes to this Statement
This Statement may be amended from times to time in accordance with changes in our regulatory requirements and data protection practices.