KPA Pension Scheme Data Privacy Statement
1.0 Introduction
Your privacy is important to us. This privacy statement explains the personal data KPA Pension Scheme collects, how we process it, and for what purposes.
This statement applies to all members, suppliers, customers, tenants, beneficiaries, and all visitors authorized to access our services.
2.0 Definitions
References to
2.1 “You” means:
- i) Members- members and beneficiaries of both DB and DC pension schemes.
- ii) Any visitor that is a person (including contractors/subcontractors or any third parties) who gains access to any KPA Pension Scheme premises.
iv)Any supplier who has been contracted by KPA Pension Scheme
2.0 Statement Details
2.1 Collection of Information
2.1.1 We collect your personal information including sensitive personal information using biometric technologies with your knowledge and consent when you do any of the following (please note that this list is not exhaustive):
- a) become a member of the scheme through your employment into permanent and pensionable terms with Kenya Ports Authority.
- b) subscribe to use any of our services including technology systems and member products like income drawdown, PRMF, Trust Fund.
- c) conducting census or life certification
2.2 What Information is collected?
The information we collect and store about you includes but is not limited to the following:
2.2.1 Your identity including your name, photograph, address, location, phone number, identity document type and number, date of birth, email address, age, gender and mobile number and biometric records.
2.2.2 Your beneficiary details like children names, age, relationship
2.2.3 We use Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are installed at strategic locations to provide a safe and secure environment as a part of our commitment to community safety, security, and crime prevention.
2.2.4 Where you use our voice recognition platform for census verification we may collect and process your voice biometrics.
3.3 Use of Information
We may use and analyze your information for the following purposes:
3.3.1 Processing your pension and monthly payroll.
3.3.2 Payment of burial allowance.
3.3.3 Responding to any of your queries or concerns.
3.3.4 Verifying your identity information through publicly available and/or restricted government databases to comply with applicable regulatory requirements.
3.3.5 Conduct life certification/census
3.4. Categories of Data
Categories of Personal Data as defined in the Data Protection Act of Kenya may be processed depending on the particular types of products and services you have subscribed to.
3.5. Lawful Basis for processing your information.
We will process your personal information based on any of the lawful basis provided for under the Data Protection Law:
3.5.1 The processing and payment of retirement benefits;
3.5.2 Compliance with a mandatory legal obligation;
3.5.4 Consent you provide;
3.6. Retention of Information
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.
Anonymised information that can no longer be associated with you may be held indefinitely.
4.0 Disclosure of Information
4.1 Any disclosure of your information shall be in accordance with applicable law and regulations. KPA Pension Scheme shall assess and review each application for information and may decline to grant such information to the requesting party.
4.2 We shall not release any information to any individual or entity that is acting beyond its legal mandate.
5.0 Safeguarding and Protection of Information
KPA Pension Scheme has put in place technical and operational measures to ensure integrity and confidentiality of your data via controls around: information classification, access control, physical and environmental security and monitoring and compliance.
6.0 International Data Transfers
From time to time we may need to transfer your personal information outside the Republic of Kenya.
Where we send your information outside Kenya, we will make sure that your information is properly protected in accordance with the applicable Data Protection Laws.
7.0 Your Rights
Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below: –
- a) Right to be informed that we are collecting personal data about you;
- b) Right to access personal data that we hold about you and request for information about how we process it;
- c) Right to request that we correct your personal data where it is inaccurate or incomplete.
- d) Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;
- e) Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;
- f) Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;
- g) Right to request transfer of your personal data in [an electronic format].
If you wish to exercise any of the rights set out above, please contact us on info@kpapension.co.ke
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.0 How to Contact Us
If you would like to contact us on any topics in this privacy policy, you can email us on info@kpapension.co.ke.co.ke
As a Data Controller and Processor, below are the contact details of our Data Protection Officer:
Data Protection Officer
info@kpapension.co.ke.co.ke
9.0 Right to Lodge Complaint
You have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya
10.0 Amendments to this Statement
KPA Pension Scheme reserves the right to amend or modify this statement at any time. If
KPA Pension Scheme amends this statement, You can access the most current version of
the privacy statement by clicking this link Privacy Statement so that you will always know how your personal information is being used or shared. Any amendment or modification to this statement will take effect from the date of notification on the Schemes website.
Statement Effective Date
30th March 2023