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DSARF Smartcash PERSONAL BROADBAND AIRTEL TOUCHING LIVES BUSINESS ABOUT US
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Contact Us Copyright and Privacy TERMS & CONDITIONS





© 2024 2017 Airtel Africa. All Rights Reserved.


Cookies & Privacy

This website uses cookies that provide necessary site functionality and improve
your online experience. By continuing to use this website, you agree to the use
of cookies. Our privacy policy provides more information about what cookies we
use and how you can change them.

Allow Cookies

PRIVACY POLICY

×

I consent to the collection and processing of my personal Information. For
further information please read our
Privacy Policy

1. Introduction

As part of our operations, Airtel Networks Limited (“Airtel”) collects and
processes certain types of information (including but not limited to NIN, name,
telephone numbers, address phone number, sex, photograph, ID card, fingerprint,
and signature etc. of individuals that makes them easily identifiable. These
individuals include current, past and prospective employees, merchants,
suppliers/vendors, customers or merchants and other individuals whom Airtel
communicates or deals with, jointly and/or severally (“Data Subjects”).

Maintaining the Data Subject’s trust and confidence requires that Data Subjects
do not suffer negative consequences/effects as a result of providing Airtel with
their Personal Data. To this end, Airtel is firmly committed to complying with
applicable data protection laws, regulations, rules and principles to ensure
security of Personal Data handled by the Company. This Data Privacy & Protection
Policy (“Policy”) describes the minimum standards that must be strictly adhered
to regarding the collection, use and disclosure of Personal Data and indicates
that Airtel is dedicated to processing the Personal Data it receives or
processes with absolute confidentiality and security. This Policy applies to all
forms of systems, operations and processes within the Airtel environment that
involve the collection, storage, use, transmission, and disposal of Personal
Data. Failure to comply with the data protection rules and guiding principles
set out in the Nigeria Data Protection Act, (NDPA) and the Nigerian Data
Protection Regulations 2019 (NDPR) as well as those set out in this Policy is a
material violation of Airtel’s policies and may result in disciplinary action as
required, including suspension or termination of employment or business
relationship. 2.0 SCOPE This Policy applies to all employees of Airtel, as well
as to any external business partners (such as merchants, suppliers, contractors,
vendors and other service providers) who receive, send, collect, access, or
process Personal Data in any way on behalf of Airtel, including processing
wholly or partly by automated means. This Policy also applies to third party
Data Processors who process Personal Data received from Airtel. 3.0 GENERAL
PRINCIPLES FOR PROCESSING OF PERSONAL DATA Airtel is committed to maintaining
the principles in the NDPA and NDPR regarding the processing of Personal Data.
To demonstrate this commitment as well as our aim of creating a positive privacy
culture within Airtel, we adhere to the following basic principles relating to
the processing of Personal Data: Lawfulness, Fairness and Transparency Personal
Data must be processed lawfully, fairly and in a transparent manner at all
times. This implies that Personal Data collected and processed by or on behalf
of Airtel must be in accordance with the specific, legitimate, and lawful
purpose consented to by the Data Subject, save where the processing is otherwise
allowed by law or within other legal grounds recognized in the NDPA and NDPR.
Data Accuracy Personal Data must be accurate and kept up-to-date. In this
regard, Airtel : a) shall ensure that any data it collects and/or processes is
accurate and not misleading in a way that could be harmful to the Data Subject;
b) make efforts to keep Personal Data updated where reasonable and applicable;
and c) make timely efforts to correct or erase Personal Data when inaccuracies
are discovered. Purpose Limitation Airtel collects Personal Data only for the
purposes identified in the Airtel Privacy Notice provided to the Data Subject
and for which consent has been obtained. Such Personal Data cannot be reused for
another purpose that is incompatible with the original purpose, except a new
Consent is obtained. The purposes for which Airtel will use your personal data
includes but not limited to the following: a) For the provision of services to
you. For example, when you purchase any of our products or services, we will use
your personal data to process your order. b) For customer care and billing. When
you use our products or services, we will use your personal information to bill
you and to respond to enquiries and concerns that you may have about our
products and services. c) Customer service messages. We will use your personal
data to keep you updated with the latest information or changes about our
products and services. d) For marketing purposes. To serve you better, will use
your personal data to market our products and services to you. e) Fraud
prevention and security. We will process your personal and traffic data to
protect you against and detect fraud, to protect and detect misuse or damage to
our networks. f) Managing our networks and understanding network usage. We do
this to manage the volume and quality of calls and to understand how you use our
networks, products, and services Data Minimization Airtel limits Personal Data
collection and usage to data that is relevant, adequate, and necessary for
carrying out the purpose for which the data is processed. Airtel will evaluate
whether and to what extent the processing of personal data is necessary and
where the purpose allows, anonymized data must be used. Integrity and
Confidentiality Airtel shall establish adequate controls in order to protect the
integrity and confidentiality of Personal Data, both in digital and physical
format and to prevent personal data from being accidentally or deliberately
compromised. Personal data of Data Subjects must be protected from unauthorized
viewing or access and from unauthorized changes to ensure that it is reliable
and correct. Any personal data processing undertaken by an employee who has not
been authorized to carry such out as part of their legitimate duties is
un-authorized. Employees may have access to Personal Data only as is appropriate
for the type and scope of the task in question and are forbidden to use Personal
Data for their own private or commercial purposes or to disclose them to
unauthorized persons, or to make them available in any other way. Human
Resources Department must inform employees at the start of the employment
relationship about the obligation to maintain personal data privacy. This
obligation shall remain in force even after employment has ended. Personal Data
Retention All personal information shall be retained, stored and destroyed by
Airtel in line with legislative and regulatory guidelines. For all Personal Data
and records obtained, used and stored within the Company, Airtel shall perform
periodical reviews of the data retained to confirm the accuracy, purpose,
validity and requirement to retain. To the extent permitted by applicable laws
and without prejudice to Airtel Document Retention Policy, the length of storage
of Personal Data shall, amongst other things, be determined by: (a) the contract
terms agreed between Airtel and the Data Subject or as long as it is needed for
the purpose for which it was obtained; or (b) whether the transaction or
relationship has statutory implication or a required retention period; or (c)
whether there is an express request for deletion of Personal Data by the Data
Subject, provided that such request will only be treated where the Data Subject
is not under any investigation which may require Airtel to retain such Personal
Data or there is no subsisting contractual arrangement with the Data Subject
that would require the processing of the Personal Data; or (d) whether Airtel
has another lawful basis for retaining that information beyond the period for
which it is necessary to serve the original purpose. Notwithstanding the
foregoing and pursuant to the NDPA and NDPR, Airtel shall be entitled to retain
and process Personal Data for archiving, scientific research, historical
research, or statistical purposes for public interest. Airtel would forthwith
delete Personal Data in Airtel’s possession where such Personal Data is no
longer required by Airtel. or in line with Airtel Retention Policy, provided no
law or regulation being in force requires Airtel to retain such Personal Data.
Accountability Airtel demonstrates accountability in line with the NDPA and NDPR
obligations by monitoring and continuously improving data privacy practices
within Airtel. Any individual or employee who breaches this Policy may be
subject to internal disciplinary action (up to and including termination of
their employment); and may also face civil or criminal liability if their action
violates the law. 4.0 DATA PRIVACY NOTICE Airtel considers Personal Data as
confidential and as such must be adequately protected from unauthorized use
and/or disclosure. Airtel will ensure that the Data Subjects are provided with
adequate information regarding the use of their Personal Data as well as acquire
their respective Consent, where necessary. Airtel shall display a simple and
conspicuous notice (Privacy Notice) on any medium through which Personal Data is
being collected or processed. The following information must be considered for
inclusion in the Privacy Notice, as appropriate in distinct circumstances in
order to ensure fair and transparent processing: a) Description of collectible
Personal Data; b) Purposes for which Personal Data is collected, used and
disclosed, c) What constitutes Data Subject’s Consent? d) Purpose for the
collection of Personal Data, e) The technical methods used to collect and store
the information. f) Available remedies in the event of violation of the Policy
and the timeframe for remedy; and g) Adequate information to initiate the
process of exercising their privacy rights, such as access to, rectification and
deletion of Personal Data. Airtel Privacy Notice is available on Airtel website
via this www.airtel.ng/dataprotection 5.0 LEGAL GROUNDS FOR PROCESSING OF
PERSONAL DATA The personal data we collect from our customers and how we collect
it depends on the services that our customers subscribe to, how they use our
services and how they interact or interface with us. This also applies to
persons who are not customers of Airtel but have interacted with Airtel such as
our employees and external business partners. We may also obtain your personal
data from a third party who has permission to share it with us. We may share
your data with third parties to whom you have given your consent to procure such
data from Airtel; Personal data we have about our customers where applicable
includes but not limited to: Name, Phone number, address, sex, photograph, ID
card details, fingerprint, signature etc. Please note that we collect your data
when you provide it to us through any of our data collection points (physical,
online, virtually, etc.) and only process your personal data based on the
grounds set out in the NDPA and NDPR. Accordingly, processing of Personal Data
by Airtel shall be lawful if at least one of the following applies: a) where you
give us consent to the processing of your Personal Data for one or more specific
purposes. You are at liberty to withdraw the consent and Airtel will cease to
process your personal where there is no other basis to do so. b) Where the
processing is necessary for the performance of a contract to which the Data
Subject is party or to take steps at the request of the Data Subject prior to
entering into a contract. c) Processing is necessary for compliance with a legal
obligation to which Airtel is subject. d) Processing is necessary to protect the
vital interests of the Data Subject or of another natural person; and e)
Processing is necessary for the performance of a task carried out in the public
interest or in exercise of official public mandate vested in Airtel. f) For the
purposes of the legitimate interest pursued by the data controller or by a third
party to whom the data is disclosed 5.1. We collect your personal data when you
do any of the following: a) Buy or use any of our products and services. b) Use
our network or other Airtel products and services c) Register for a specific
product or service d) Visit or browse our website, e) Have given permission to
other companies to share information about you, f) Where your information is
publicly available, g) Are the customers of a business we acquire or, h) Take
part in a competition, prize draw or survey. i) Where Airtel engages you as an
employee or external business partner j) We also keep records when you
use/conduct an activity on your mobile phone using our network. This includes
the number you dialed, the length, date and time of that call, and records of
your IP data sessions. k) When you provide your data to us through any of our
data collection points including but not limited to the following: our KYC
registration forms, SIM Swap Forms, MNP Forms self-service applications, social
media platforms, websites 6.0 CONSENT Where processing of Personal Data is based
on consent, Airtel shall obtain the requisite consent of Data Subjects at the
time of collection of Personal Data. In this regard, Airtel will ensure: a) that
the specific purpose of collection is made known to the Data Subject and the
Consent is requested in a clear and plain language, b) that the Consent is
freely given by the Data Subject and obtained without fraud, coercion or undue
influence, c) that the Consent is sufficiently distinct from other matters to
which the Data Subject has agreed, d) that the Consent is explicitly provided in
an affirmative manner, e) that Consent is obtained for each purpose of Personal
Data collection and processing; and f) that it is clearly communicated to and
understood by Data Subjects that they can update, manage, or withdraw their
Consent at any time. Valid Consent For Consent to be valid, it must be given
voluntarily by an appropriately informed Data Subject. In line with regulatory
requirements, Consent cannot be implied. Silence, pre-ticked boxes or inactivity
does not constitute Consent under the NDPA 2023. Consent in respect of Sensitive
Personal Data must be explicit. A tick of the box would not suffice. Consent of
Minors In the unlikely event that we deal with minors, the consent of minors
will always be protected and obtained from minor’s representatives in accordance
with applicable regulatory requirements. 7.0 DATA SUBJECT RIGHTS All individuals
who are the subject of Personal Data held by Airtel are entitled to the
following rights: a) Right to request for and access the Personal Data collected
and stored. Where data is held electronically in a structured form, such as in a
Database, the Data Subject has a right to receive that data in a common
electronic format, b) Right to information on their personal data collected and
stored, c) Right to objection or request for restriction, d) Right to request
rectification and modification of their data which Airtel keeps, e) Right to
request for deletion of their data, except as restricted by law or Airtel
statutory obligations, f) Right to request the movement of data from Airtel to a
Third Party; this is the right to the portability of data; and g) Right to
object to, and to request that Airtel restricts the processing of their
information except as required by law or Airtel’s statutory obligations. h)
Right to request that Airtel restricts processing of your personal data and
Right i) To opt out of marketing and unsolicited messages: If you no longer want
to receive marketing messages from Airtel, you can choose to opt out at any
time. If you have previously opted in to receive personalized content based on
how and where you use our network, you can also opt out at any time. These are
various ways to opt out: • Contact our customer services team –
customercare@ng.airtel.com • Click the unsubscribe icon from our email;
airtelpremier@ng.airtel.com • Disable push notification messages, including
marketing messages, at any time in our apps by changing the notification
settings on your device or by uninstalling the app; • Contact our customer
service team by dialing 300 or send an email to customercare@ng.airtel.com
Airtel’s well-defined procedure regarding how to handle and answer Data
Subject’s requests are contained in Airtel’s Data Subject Access Request Policy.
Data Subjects can exercise any of their rights by completing the Airtel’s
Subject Access Request (SAR) Form and submitting to the Company via
dataprotectionofficer@ng.airtel.com or call the number 09041119000 8.0 TRANSFER
OF PERSONAL DATA 8.1 Third Party Processor within Nigeria Airtel may engage the
services of third parties in order to process your Personal Data of collected by
us. The processing by such third parties shall be governed by a written contract
with Airtel to ensure adequate protection and security measures are put in place
by the third party for the protection of Personal Data in accordance with the
terms of this Policy and the NDPA 2023. We may also share your personal data
with law enforcement agencies where required by law to do so. Where applicable,
Airtel will share your information with: a) Partners, suppliers, or agents
involved in delivering the products and services you have ordered or used. For
example, when you apply for loan, your loan request is handled by our business
partner who is bound by contract to protect your personal data. b) Law
enforcement agencies, government bodies, regulatory organizations, courts or
other public authorities if we have to, or are authorized to by law. For
example, under the Cybercrimes Act, a law enforcement agency may request a
service provider to keep or release any traffic data, subscriber information,
content or non-content information. This is however for law enforcement purposes
only. c) A third party or body where such disclosure is required to satisfy any
applicable law, or other legal or regulatory requirement e.g. to respond to a
complaint or security threat, detect or prevent fraud or to respond to the
commission of any other crime. Further, disclosures of personal data may also be
needed our auditors to perform financial audits d) A merging or acquiring entity
where we undergo business reorganization e.g. merger, acquisition or takeover.
We may be required to disclose personal data about you for insurance purposes.
e) We may be required to share your information with other third parties who use
Airtel platforms/systems to advertise their products. However, the personal data
collected is anonymized or aggregated prior to sharing it to the third parties.
8.2 Transfer of Personal Data to Foreign Country 8.2.1 Airtel may transfer
Personal Data outside Nigeria only if such transfer is permitted by, and is in
accordance with Local Regulatory Requirements, and for the purposes described in
this Policy. Airtel Networks will take all necessary steps to ensure that the
Personal Data is handled and transmitted in a safe and secure manner. These
measures include conducting data protection impact assessments to verify that
such country has adequate data protection laws, which binds the recipient to
prescribed data handling and data protection requirements acceptable to Airtel
and our relevant regulators,. This measures also incudes entering into binding
data transfer agreements amongst others. Furthermore, Airtel as a multinational
operating company within the Airtel Africa Group, may transfer your personal
data to other Airtel affiliated entities within the Group. All these entities
are bound by Binding Corporate Rules (“BCR”) which ensures that the entity
receiving the data safeguards your data in accordance with the terms of the BCR.
9.0 DATA BREACH MANAGEMENT PROCEDURE A data breach procedure is established and
maintained in order to deal with incidents concerning Personal Data or privacy
practices leading to the accidental or unlawful destruction, loss, alteration,
unauthorized disclosure of, or access to, Personal Data transmitted, stored or
otherwise processed. All employees must inform their designated line manager or
the DPO of Airtel immediately about cases of violations of this Policy or other
regulations on the protection of Personal Data, in accordance with Airtel
Personal Data Breach Management Procedure in respect of any: a) improper
transmission of Personal Data across borders; b) loss or theft of data or
equipment on which data is stored; c) accidental sharing of data with someone
who does not have a right to know this information; d) inappropriate access
controls allowing unauthorized use; e) equipment failure; f) human error
resulting in data being shared with someone who does not have a right to know;
and g) hacking attack. A data protection breach notification must be made
immediately after any data breach to ensure that: a) immediate remedial steps
can be taken in respect of the breach b) any reporting duties to NDPC or any
other regulatory authority can be complied with, c) any affected Data Subject
can be informed and d) any stakeholder communication can be managed. When a
potential breach has occurred, Airtel will investigate to determine if an actual
breach has occurred, and the actions required to manage and investigate the
breach as follows: a) Validate the Personal Data breach. b) Ensure proper and
impartial investigation (including digital forensics if necessary) is initiated,
conducted, documented, and concluded. c) Identify remediation requirements and
track resolution. d) Report findings to the top management. e) Coordinate with
appropriate authorities as needed. f) Coordinate internal and external
communications. g) Ensure that impacted Data Subjects are properly notified, if
necessary. You can read more about Airtel Personal Data Breach Management
Procedure via the airtel.ng.com/privacy policy 10.0 DATA PROTECTION IMPACT
ASSESSMENT Airtel shall carry out a Data Protection Impact Assessment (DPIA) in
respect of any new project or IT system involving the processing of Personal
Data to determine whenever a type of processing is likely to result in any risk
to the rights and freedoms of the Data Subject. Airtel shall carry out the DPIA
in line with the procedures laid down in the Airtel Data Protection Impact
Assessment Policy . 11.0 DATA SECURITY All Personal Data must be kept securely
and should not be stored any longer than necessary. Airtel will ensure that
appropriate measures are employed against unauthorized access, accidental loss,
damage and destruction to data. This includes the use of password encrypted
databases for digital storage and locked cabinets for those using paper form. To
ensure security of Personal Data, Airtel will, among other things, implement the
following appropriate technical controls: a) Industry-accepted hardening
standards, for workstations, servers, and databases. b) Full disk software
encryption on all corporate workstation/laptops operating systems drives storing
Personal and Personal/Sensitive Data. c) Encryption at rest including key
management of key databases. d) Enable Security Audit Logging across all systems
managing Personal Data. e) Restrict the use of removable media such as USB flash
disk drives. f) Anonymization techniques on testing environments. g) Physical
access control where Personal Data are stored in hardcopy. 12.0 DATA PROTECTION
OFFICER Airtel shall appoint a Data Protection Officer(s) (DPO) responsible for
overseeing the Company's data protection strategy and its implementation to
ensure compliance with the NDPA 2023 requirements. The DPO shall be a
knowledgeable person on data privacy and protection principles and shall be
familiar with the provisions of the NDPA 2023. The main tasks of the DPO
include: a) administering data protection policies and practices of Airtel ; b)
monitoring compliance with the NDPA 2023 and other data protection laws, data
protection policies, awareness-raising, training, and audits; c) advice the
business, management, employees and third parties who carry on processing
activities of their obligations under the NDPA 2023; d) acts as a contact point
for Airtel; e) monitor and update the implementation of the data protection
policies and practices of Airtel and ensure compliance amongst all employees of
Airtel; f) ensure that Airtel undertakes a Data Impact Assessment and curb
potential risk in Airtel data processing operations; and g) maintain a Data Base
of all Airtel is data collection and processing operations of Airtel. 13.0
TRAINING Airtel shall ensure that employees who collect, access and process
Personal Data receive adequate data privacy and protection training in order to
develop the necessary knowledge, skills and competence required to effectively
manage the compliance framework under this Policy and the NDPA 2023 with regard
to the protection of Personal Data. On an annual basis, Airtel shall develop a
capacity building plan for its employees on data privacy and protection in line
with the NDPA 2023. 14.0 DATA PROTECTION AUDIT Airtel shall conduct an annual
data protection audit through a licensed Data Protection Compliance Organization
(DPCOs) to verify Airtel compliance with the provisions of the NDPA 2023 and
other applicable data protection laws. The audit report will be certified and
filed by the DPCO to Nigeria Data Protection Commission (NDPC) as required under
the NDPA 2023. 15.0 RELATED POLICIES AND PROCEDURES This Policy shall be read in
conjunction with the following policies and procedures of Airtel • Personal Data
Breach Management Policy • IT Security Policy • Document Rétention Policy •
Cookies Policy • Privacy Notice • Data Protection Impact Assessment Procedure
CHANGES TO THE POLICY Airtel reserves the right to change, amend or alter this
Policy at any point in time. If we amend this Policy, we will provide you with
the updated version. GLOSSARY ‘‘Consent’’ means any freely given, specific,
informed and unambiguous indication of the Data Subject's wishes by which he or
she, through a statement or a clear affirmative action, signifies agreement to
the processing of Personal Data relating to him or her. “Database” means a
collection of data organized in a manner that allows access, retrieval, deletion
and processing of that data; it includes but not limited to structured,
unstructured, cached and file system type Databases. “Data Processor means a
person or organization that processes Personal Data on behalf and on
instructions of Airtel “DPCO” means an organization registered by NITDA to
provide data protection audit, compliance and training services to public and
private organizations who process Personal Data in Nigeria. “Data Subject” means
any person, who can be identified, directly or indirectly, by reference to an
identification number or to one or more factors specific to his physical,
physiological, mental, economic, cultural or social identity. “NDPR” means the
Nigeria Data Protection Regulation, 2019. “Personal Data” means any information
relating to an identified or identifiable natural person (‘Data Subject’); an
identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person; It can be anything from a
name, address, a photo, an email address, bank details, posts on social
networking websites, medical information, and other unique identifier such as
but not limited to MAC address, IP address, IMEI number, IMSI number, SIM,
Personal Identifiable Information (PII) and others. “Sensitive Personal Data”
means data relating to religious or other beliefs, sexual orientation, health,
race, ethnicity, political views, trades union membership, criminal records or
any other sensitive personal information.

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