DATA PROTECTION POLICY

 

SENACA EAST AFRICA DATA PRIVACY POLICY AND STATEMENT

  1. Introduction

Our company is committed to protecting the privacy and security of your personal information.

This privacy policy describes how we collect and use personal data about you in accordance with the Data Protection Act 2019. The purpose of the Act is to give to effect Article 31(c) and (d) of the Constitution that contains the right to privacy which is a fundamental human rights.

Data protection is the process of safeguarding personal information, in accordance with a set of  principles laid down by law. This clearly stipulates what should our system collect, whose data is collected, and who else is the data likely to identify based to the collected or processed data.

As Senaca East Africa, we have a responsibility to ensure that we collect, process, and use personal data in accordance with the law. When we do so, we are regulated under the Data Protection Act 2019 and we are responsible as “data collectors” of that personal information for the purpose of the law or as “data processors” on behalf of our clients who contract our security services.

  1. Purpose and Scope of this Policy

We recognize and understand that innovation, new ways of doing business, and new technology drive continued change in risk, expectations, and laws. Therefore, this policy is intended to provide and guide on the minimum standards in regards to collection and processing of personal information.

The policy ensures that, Senaca East Africa:

 

  1. Complies with local and, to extent applicable, international laws and regulations on data protection.
  2. Protects the rights of its employees, customers, visitors, suppliers, business partners, and other stakeholders.
  3. Promotes fairness and transparency in how it collects, processes, and stores personal data.
  4. Has put measures and mitigation plan to protect itself from data breaches.

 

All company employees and management have core privacy responsibilities they must abide with and uphold. This should abide by:

 

  • Legal, regulatory, and corporate policy compliance;
  • Confidentiality;
  • Integrity; and
  • Availability of the information.

Any breach of this policy and related policies and procedures may result in disciplinary measures.

Our Data Protection Officer (DPO) is responsible for overseeing the implementation and review of this Policy and can be reached through email john.sanga@senacaworld.com.

We collect personal data through the following activities (the list is not exhaustive):

  1. Recruitment
  2. Job applications
  • Customers and clients contracts
  1. Suppliers and vendors
  2. Financial transactions
  3. Visitors to our premises and clients premises
  • Training and sponsorship
  • Biometric installations
  1. CCTV camera surveillance
  2. Website and social media

 

  1. Data Protection Principles

 

  Privacy Principle

 

Our Core Commitment
1. Right to Privacy

 

·        Senaca East Africa shall strive to protect the privacy of the data subject by:

 

ü  Requesting for the consent of the “Data Subject” before collecting or processing any personal information.

ü  Allowing only authorized personnel to process personal data.

ü  Concealing the identity of the data subject.

ü  Using end-to-end encryption in its internet connectivity.

ü  Anonymizing where possible.

 

·        We have implemented and applied comprehensive security program and controls that are based on the sensitivity of the information and the risk level of the activity.

·        Data and information collection and processing is implemented in accordance to the “Need to know” Rule right from recruitment, vetting and background checks, deployment on clients premises, and separation.

·        Our security policies include emergency and contingency planning, business continuity planning, access management and search procedures, information security, physical security, investigations, and risk management.

 

 

2. Fairness and Lawfulness

 

 

·        Senaca East Africa will always strive to process personal data in fair, lawful and transparent manner.

·        Processing of personal data will deemed to be lawful if the following conditions are met:

 

a)    The “Data Subject” has given consent.

b)    Processing is necessary for the data subject to be allowed access to Seneca East Africa premises or to the premises of a  “Data Controller” who has contracted Senaca east Africa to process data on their behalf.

c)    Processing is necessary for Senaca East Africa to pursue legitimate interest without prejudicing the dignity and rights of the data subject.

d)    To comply with legal obligations as stipulated by state legislation and statutes.

 

·        Senaca East Africa being  member of the UN Blue Company program abides by the Universal Declaration of Human rights Article (12) that states:

 

“No one shall be subjected to arbitrary interference with his/her privacy, family, home, or correspondence, nor to attacks against his/her honour or reputation.”

 

.

3. Legitimate Purpose

 

 

·        Senaca East Africa shall ensure that the data collected is for legitimate purposes only.

·        The data collected should be specified, explicit and should not further be processed in a manner incompatible with these purposes.

·        Control and monitoring measures shall be put in place to minimize any privacy impact on the data subject.

 

4. Purpose Limitation/Adequacy

 

 

·        Where sensitive data revealing natural person’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details, including names of the person’s children, parents, spouse or spouses, sex or the sexual orientation of the Data Subject, should be collected as directed by the Office of the Data Protection Commissioner.

·        Employees of Senaca East Africa shall not process data for a new purpose that is not compatible with the original purpose.

·        Where a new purpose is required, Seneca East Africa shall first notify and obtain a fresh consent of the data subject.

 

5. Valid Explanation

 

·        We shall ensure that all personal data is collected only where a valid explanation is provided whenever information relating to family or private affairs is required.

 

6. Accuracy

 

·        Senaca East Africa shall ensure that personal data is kept up to date.

·        Necessary measures like employees having access to their personal data on request and periodical checks of files have been put in place for correcting and updating inaccurate data.

 

7. Retention

 

·        Senaca East Africa shall ensure that there is storage limitation and that data is not stored for longer than is necessary.

·        Personal data shall not be stored in a way that identifies the data subject.

 

8. Transfer Outside Kenya

 

·        Senaca East Africa operates across the trans borders and incase of data transfer shall ensure that the entity and country of transfer has in place laws or measures that ensure an individual’s data is protected against loss or breaches.

 

 

  1. Rights of the Data Subject

The data subject has a right to:

  • Be Informed of the use to which their personal data is to be used.
  • Access their personal data in the custody of data controller or data processor.
  • Object to the processing of all or part of their personal data.
  • Correction of false or misleading data.
  • Deletion of false or misleading data about them.
  • Right to withdraw consent at any time.
  1. Compliance with Audit

Senaca East Africa management shall conduct periodic audits to ensure compliance with this policy.

  1. Related Documents
  • Service Level Agreements.
  • Standard Operating Procedures.
  • Access control policy.
  • Human Resources Policy.

 

  1. Review

The process shall be reviewed periodically and when there is a change in threat or change in operational environment.

  1. Policy Approval

This policy was approved by the board of management on 10th August 2022.

Appendix

Definition of terms

 

Term Explanation
Consent Means any manifestation of express, unequivocal, free, specific, and informed indication of the data subject’s wishes by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to the data subject.

 

Data Subject An identified or identifiable natural person who is the subject of personal data.

 

Data Controller Natural or legal person, public authority, agency or other body which, alone or jointly with others, determine the purpose and means of processing of personal data.

 

Data Processor Natural or legal person, public authority, agency or other body which, processes personal data on behalf of the data controller.

 

Sensitive Personal Data

 

Data revealing the natural person’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of person’s children, sex, or sexual orientation of the data subject.

 

Personal Data Any information relating to an identified or identifiable natural person.

 

Processing Any operation or set of operation which is performed on personal data or on set of personal whether or not by automated means such as:

 

i.          Collection, recording, organization, structuring.

ii.          Storage, adaptation or alteration.

iii.          Retrieval, consultation or use.

iv.          Disclosure by transmission, dissemination or availability.

v.          Alignment or combination, restriction, erasure or destruction.

 

 

Senaca EA scoops 4 major awards

Senaca EA, has yet again claimed its place as The Market Leader after emerging as the    overall Best in three categories at this year’s OSPAS Awards and Real Estate Excellence Awards. This makes a total of 10 awards won by Senaca EA in the last 2 years.

The OSPAs recognize and reward Companies and Individuals across the security sector. The OSPAs operate in 11 Countries which include USA, UK, Germany, Australia, India, Nigeria, Ghana, Romania and now in Kenya . The OSPAs are designed to be both independent and inclusive, providing an opportunity for   outstanding performers, whether buyers or suppliers, to be recognized and their success to be celebrated.

Senaca EA recorded   a resounding victory at The OSPAs in 2 categories, bagging 3 Awards including sweeping the top slots for the;

  1. Outstanding Contract Security Company (Guarding)
  2. Outstanding Security Installer/Integrator
  3. Outstanding Security Training Initiative for our Academy the Private Security Training Academy.

This comes hot on the heels of similar success at the Real Estate Excellence Awards where the Company was yet again able to bag the 2nd award in a successive year as the Best Manned Security Solutions Provider in 2020. Making the award a testament to Senaca EA’s transformation plan has placed the Company at the helm of the Industry.

Commenting on the awards, General Manager John Sanga said, “These awards recognize the efforts we have put in and we are continuing to put in, to offer tailored solutions to our clients through best trained security officers. This has increased our portfolio in serving and             integrating new technology with security in line with our new Vision “Securing the future now.”

The Company was recognized as the  Outstanding Security Installer /Integrator. This award recognizes the fact that Senaca has long positioned itself as a leading security firm across East African Market specializing in      integrated security solutions. Over time, the company has challenged the conventional  market ethos and approaches with the use of GSM radios and integrated automated systems in regards to communication, thus transforming how       business is conducted. We continue to put effort in being responsive to customers emerging needs and preferences.

The President and the Chair Panelist of The OSPAs Awards, Professor Martin Gill indicated that the awards are key for benchmarking against the best and encouraged all nominees raise the standards in the security market.

Below is a list of the awards at The Outstanding Security Performance Awards 2020    (https://ke.theospas.com/winners-2020/):

  1. Outstanding In-House Security Manager/Director
  2. Outstanding Contract Security Company (Guarding)
  3. Outstanding Security Training Initiative
  4. Outstanding Security Installer/Integrator
  5. Outstanding Female Security Professional

Last year we were proud to have won the   following awards from various entities:

  1. Fastest Growing Security Company in East Africa
  2. Most Innovative Security Brand
  3. Most Promising Security Company
  4. Leading Security in Gender Diversity
  5. Strategic Leadership and Governance of a Private Firm
  6. Visionary Leadership Award

We thank our esteemed employees and    clients who have been instrumental in our growth and recognition. It is your confidence in us, honesty, constant engagement, recommendations for continuous improvement and        business referrals as our valued client that have accorded Senaca EA with these much-coveted Crowns for two successive years. We also acknowledge the overwhelming support we have      received from all our staff and clients this challenging year amidst the COVID 19 Pandemic and the kindness and concern extended to our security officers in the line of duty.

In 2021, Senaca EA is implementing its Transformation Plan (SEA T-Plan). Our key area of focus are customer tailored solutions, an improved look and an unapologetic pride in improved our          customer service. We are looking forward to offering you bespoke security solutions designed with every client’s uniqueness in mind and giving you the peace of mind you deserve in all matters security.

 

Diversity in the Security Industry

DIVERSITY IN THE SECURITY INDUSTRY

 

Do an image search using the terms “security manager,” “security director,” or “security professional,” and the results will be fairly predictable. With its roots in law enforcement especially in my mother country Kenya, the security industry has long been dominated by men, whether in management, sales, or technical positions.

In recent years, however, this has begun to change. First making inroads in traditionally  female roles like marketing and human          resources, now more women are making their mark in leadership and other types of roles across the security industry. In fact, the last 10 years has demonstrated to professionals across all industries that business growth is best achieved by eliminating limitations based on gender. Yes Diversity is looking good. While the proportion of women to men continues to lag behind that reality, the balance is shifting and becoming more visible in the security     industry as well. Can you argue about that?

A few pioneers have paved the way over the years and present a more balanced model of what a security  professional might look like. Let’s make our company the case study        Senaca EA. As one of the earliest women in a top management position in the company since  inception, CEO Naomi Kipkorir co-founded the company in 2002 and built it over the next few years into being awarded as the most            innovative security company in 2019 at the Real Estate Excellence Awards. How amazing is this.

Home grown security officer Eunice Ndeto has risen through the ranks to become an expert in matters of the Control Room and Operational Excellence. Mercy Bonareri a Human Resource practitioner has continued to provide guidance to strengthen security operation for our         organization in the highly labor intensive field.        Annette Kimitei who has vastly grown in the      industry, regardless of her  not  being a       conventional security expert  has  helped shape the National  conversation about the role of women and the diversity of security in      current Information age, she was a moderator at the 2020 Women In Safety Excellence     Official Global Launch. Main topic of discussion being “The Call for Diversity in Security

There is good reason to applaud the growing presence of women in every type of security role. In a leadership effectiveness study       conducted recently via HR World. Women were rated higher than men in twelve of the fifteen functions listed. The roles included sales,      operations, finance, management, engineering and other positions traditionally held by men. Women were rated as excelling in – among other things – taking initiative, acting with     resilience, practicing self-development, driving for results and displaying high integrity and      honesty. Are you shocked yet? In fact, they were thought to be more effective in 84 percent of the capabilities that we most frequently measure to differentiate excellent  leaders, according to a Harvard Business      Review article. It is also worth noting that   women have traditionally been, and are often still, described as being stronger in the areas of compassion and empathy and as being able to work out compromises.Today, a fast-growing number of organizations within the security industry are hiring and     promoting women in a wider range of roles. This is even evident in our country where we have women sitting in the National Security  Table like Honorable Raychelle Omamo. Have you not seen women taking positions in the cyber-security field? You may have. We foresee a future where women will be taking their place as thought leaders, technology experts and  accomplished specialists in this field.

A number of industry groups have been created to offer community, education and networking opportunities for women. ASIS International created the Global ASIS Women in Security Council to provide resources and assistance to women in the security industry, as well as to inspire those  interested in entering the security industry. Have you heard about it? The council offers mentoring, volunteering and other support opportunities for its members. The growing presence of women in the security industry is without question a positive trend. As more young women enter the field, they will continue to bring with them the benefits of a more balanced workplace and a wider point of view, which is definitely something to celebrate.

We encourage both men and women to join this conversation.

The Call for Diversity in Security.