The Africa Practice group is committed to protecting your privacy.
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or about you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
- We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.
- We do our very best to protect your privacy by using security technology appropriately. This means:
- we make sure that we have appropriate security measures to protect your information; and
- we make sure that when we ask another organisation to provide a service for us, they have appropriate security measures.
Knowing your rights
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org. The same website provides useful definitions of some of the key terms you will find in this notice. If you are uncertain about any aspect after reading this notice, or would like additional information you are welcome to contact us; for this purpose we have provided relevant contact details at the end of this notice.
Who we are
The Africa Practice group (“Africa Practice”) comprises Africa Practice Limited, a company registered in the UK with registration number 03920994 and its affiliates and subsidiary companies operating across Africa including principle trading offices in Nigeria, Kenya, Tanzania, Botswana and South Africa. The address and contact details of all our office locations are to be found on our website at: www.africapractice.com
Africa Practice is both a data controller and a data processor. That is we directly control the processing of certain categories of your personal data as described below – and we may also process data on behalf of our clients under a suitable services contract.
Specifically, under UK law:
- The data controller is : Africa Practice Limited, of 14 Cambridge Court, 210 Shepherds Bush Road, Hammersmith, London W6 7NJ
- Our data protection officer is Murtaza Gulamhusein : email@example.com
The lawful bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contractual relationship with you
When you enter into a service or other contractual agreement with us, or create an account on an Africa Practice website, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we will process the information you give us. Some of this information may be personal information. We may use it in order to:
- verify your identity for security purposes or to detect and manage fraud and credit risk.
- manage a contractual relationship with you as a client or service provider, or affiliate or business partner, including updating and enhancing our records and the routine exchange of related information by various media
- provide you with suggestions and advice on strategies and actions or the purchase of additional products and services including those that may be available from third parties.
- Act as a Data Processor for personal information on third parties that you provide to us in the context of a service contract and where you are therefore the Data Controller with legal responsibility to comply with relevant data protection and privacy legislation within your own jurisdiction.
We may aggregate information information provided to us under a contract and use it to provide class information, for example to monitor our performance with respect to a particular service we provide.
We shall ordinarily continue to process your personal information until the contract between us ends or is terminated by either party under the terms of the contract. However we may maintain a copy of this information on our contractual relationship for compliance purposes, or for research purposes or for the purposes of monitoring and improving our performance.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Information we process for the purposes of legitimate interests
We may process your information on the basis there is a legitimate interest, either to you or to us, of doing so. Under “legitimate interests” we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.
Africa Practice is in the business of providing communications, thought leadership and strategic advisory services for a range of high level clients, therefore we may process your personal information where :
- you are a media professional and there is a mutual interest between us to maintain each others personal information in order to exchange valuable information about activities, events, trends, businesses or people within each others areas of interest.
- you browse our website or contact us by any means to ask for information in relation to our business, including job opportunities, or to ask for our advice.
- You are a professional with a constructive interest in furthering economic, social, political or commercial development in Africa and either (a) you are receiving an opt-in newsletter from us with information on events and current affairs on the continent or (b) we reasonably believe that you may be interested in hearing from us regarding opportunities to work under a services or other form of agreement to mutual advantage.
- you are a public official or other influential person with publicly stated positions on events or activities relating to the countries of Africa and where we may undertake research in order to improve our knowledge-base and understanding of these events and related trends and this research legitimately includes your personal information including special category personal information such as political affiliations and interests.
- you have consented to participate in a survey or other information gathering exercise undertaken on our behalf or that of a client of Africa Practice.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
We may analyse your personal information to create a profile of your interests and preferences for research purposes or so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively.
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Job application and employment
If you send us information in connection with a job application, we may may keep this in case we decide to contact you at a later date.
If we employ you, we will collect and process information about you and your work from time to time throughout the period of your employment. This information may include special category information such as medical records. It will be used only with your permission and for purposes directly relevant to your employment. After your employment has ended, we may keep your file for a reasonable period of time before destroying or deleting it.
Data may be processed outside the European Union
Africa Practice’s group structure means that we routinely share personal information for the purposes set out in this notice outside of the UK and the European Union.
Additionally we may use outsourced services including those of data processors in countries outside the European Union from time to time in any aspect of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be done with the relevant protection (stated under UK law) being in place and specifically the following safeguards will apply:
- the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
- the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
- Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
We use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)
Internet Based Advertising
We use Linkedin, Facebook, Twitter and other advertising services and as such may place tracking codes on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
How long will we hold your data for?
We will routinely review and consider our legitimate need to maintain your personal information and delete it when this legitimate need no longer applies. We would not normally expect to maintain your personal information outside of a contractual or other mutually agreeable relationship for longer than seven years
Security precautions in place about data collected
Africa Practice maintains all personal information securely protected by secure passwords, ssl encryption, physical protections, effective internal policies and training and through relationships with secure accredited data processors.
However non-sensitive details (your email address etc.) may routinely be sent over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to put adequate protections in place we cannot guarantee the 100% security of any such information.
Where you hold or transmit any personal information via any websites or systems controlled by Africa Practice we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Access to your information, correction and deletion
You have important rights with respect to your personal information:
- the right to make a Subject Access Request to receive copy of information that we hold about you
- the right to ask us to correct or remove information you think is inaccurate
- the right to ask us to completely delete all information that we hold about you.
If you wish to exercise any of these rights please email or write to us at the following address: Murtaza Gulamhusein, Africa Practice Limited, 14 Cambridge Court, 210 Shepherds Bush Road, Hammersmith, London W6 7NJ. Email : firstname.lastname@example.org
How you can complain
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. You have the additional right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/