Data Protection Policy Developed to Guide FinTechs in Ghana

by Ashnah Kalemera and Edrine Wanyama |

The Financial Inclusion Forum Africa, through an Africa Digital Rights Fund (ADRF) grant, has drafted a Data Protection and Privacy Policy to serve as an internal guide on how digital financial service providers in Ghana should collect, store and process individuals’ data. The ADRF is an initiative of the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) which provides flexible and rapid response grants for the advancement of digital rights in Africa.

The policy outlines principles on the management of personal data in compliance with Ghana’s Data Protection Act 2012 and the International Organization for Standardization and International Electrotechnical Commission Standards for Information Security Management – ISO 27001:2013.

The policy outlines data protection principles including accountability by jurisdiction of data subject; lawfulness of processing through consent; disclosure of purpose; compliance with further processing; accuracy and completeness; openness; safeguards; and correction as well as deletion. The principles of privacy outlined are legal compliance; limitations of purpose; adequacy; and retention. 

The policy requires mandatory and frequent information security awareness training for staff and the constitution of an Information Security team responsible for implementing the policy and incident response. Roles and responsibilities are also outlined for risk and compliance, heads of departments, and employees. Provisions for the rights of data subjects include the right of access, rectification, cessation of processing and prevention of automated decision making. In the event of violation of the provisions, the policy provides for internal investigations and sanctions under the law. 

The policy was previewed at the Data Protection and Privacy Roundtable, which saw leading digital financial service providers such as Appruve, Jumo, Vodaphone Cash, and G Money, alongside industry experts and regulators such as the eCrime Bureau, RegTheory, and CUTS (Consumer Unit and Trust Society) Ghana provide insights into its viability and applicability. Discussions drew on real-life experiences of service providers and key feedback was incorporated into a revised version of the policy.

Commenting on the policy, Dr. William Derban, Chairperson of the Financial Inclusion Forum Africa, stated that data privacy and protection was “critical to financial inclusion”, as data was the cornerstone of innovation in digital financial services delivery. “These guidelines [the policy] serve as a template to enable fintechs who are developing such services to ensure that all our data is being protected,” he added. 

With data breaches, including by business entities, a growing concern among users of digital services across the African continent, the policy can go a long way in addressing the live issues in protecting the privacy of data in the financial sector in Ghana, if widely adopted by service providers.

As data becomes increasingly pivotal to the digital economy and digital rights, it is becoming essential to develop sector-specific data protection guidelines. The fintech sector, which is growing exponentially in Africa, is one of these sectors. Such guidelines are essential to buttress existing legislation, which in Ghana’s case includes the Payment Systems and Services Act, 2019Data Protection Act, 2012, Electronic Communications Amendment Act. 2016, Electronic Transactions Act, 2008 and the Anti-Money Laundering Act, 2008.

While the policy is not binding, it is anticipated that through ongoing data protection and privacy campaigns, it will draw stakeholder buy-in and implementation, as it is in harmony and gives effect to various local laws while also reflecting the General Data Protection Regulation of the European Union and the African Convention on Cyber Security and Personal Data Protection which Ghana has signed and ratified.

Tech to the Rescue Against Covid-19: Reflections from West Africa

By Afi Edoh |

The role of technology in aiding the Covid-19 fight in Africa is increasingly undisputed. As Covid-19 cases have grown in Cote d’Ivoire, Ghana and Togo, governments and the private sector have played a decisive role in the three countries’ technology-based response measures, with large scale national efforts to minimise the social-economic impact of the pandemic.

In Ghana, in the wake of the pandemic, the Ministry of Health partnered with the Ministry of Information to leverage websites, USSD short codes, toll free lines, alongside broadcast media to share with the citizenry information on the virus spread and response management measures. The government also rolled out utility (water and electricity) subsidies and reduced from 9% to 5% the communications service tax as part of its relief interventions. Telecommunications operators also supported the fight against Covid-19, with MTN and Vodafone supporting distance learning with zero-rated access to education content for subscribers.

In Togo, in a move to promote cashless transactions, telecommunications operator Moov waived fees on mobile money transactions and payments for utilities. Meanwhile, the Association of Volunteers for the Promotion of Youth (AV-JEUNES) launched a mobile application which provides reliable information on Covid-19, practical advice and awareness videos in French and four additional local languages. Initially intended to provide sexual and reproductive health information to youth, women and vulnerable populations, the platform known as eCentre Convival has supported the fight against misinformation and helped educate pregnant women and young people about the coronavirus. In the telecommunications sector, service providers rolled out reduced price offers and doubled internet speeds.

Meanwhile,  partly to fight the spread of false and misleading information on the virus, Orange Cote d’Ivoire launched a media platform to allow print, online and broadcast media to keep abreast of its Covid-19 response and relief measures. MTN and the Ivorian government partnered to support data-driven decision making in the fight against the virus. Like in Ghana, MTN Cote d’Ivoire waived mobile money transaction fees and subsidised internet services. As part of social-economic relief strategies, the Ivorian government announced a grace period for utility service payments.

 Covid 19- Statistics at April 2021

Country Confirmed case Recovered Deaths Date
Togo 12,610 10,350 121 April 20, 2021
Ghana 91,783 89,661 772 April 16, 2021
Ivory Coast 45,570 45,160 274 April 20, 2021

These examples from the three countries point to a variety of ways in which governments, telecommunications operators and innovators have ensured service continuity, promoted digitalisation and access to reliable information in the face of Covid-19 lockdown restrictions.

Indeed, an opinion assessment through an online survey and interviews conducted by the author among 42 individuals, indicated that online platforms including social media were the primary means through which citizens in the three countries stayed informed during the pandemic. However, whereas there have been efforts to provide content in local languages, English and French remained predominant, excluding illiterate segments of the population.

As stated by one respondent, “the exponential growth of online platforms in the wake of Covid-19 will have a powerful effect on the digital economy, enabling business and the public sector to explore new service offerings, with significant efficiency gains.” The respondent added that with a supportive policy and legislative environment, alongside infrastructure roll out and more local language options, across the three countries, “entire sectors and traditional business models, whether in the field of transport, hospitality or automotive industry will be transformed.”

Afi Edoh is a CIPESA Fellow exploring  digital transformation and the digital economy in Ivory Coast, Ghana, and Togo during the Covid-19 pandemic, to determine value and innovation opportunities as well as challenges.

2018 Edition of the Forum on Internet Freedom in Africa (FIFAfrica) Set To Take Place In Ghana

Announcement |
The Collaboration for International ICT Policy in East and Southern Africa (CIPESA) is pleased to announce the fifth edition of the Forum on Internet Freedom in Africa (FIFAfrica). This year, the Forum will be hosted in partnership with the Media Foundation West Africa (MFWA) and will take place on September 26–28, 2018 in Accra, Ghana.
The Forum is a landmark event that convenes various stakeholders from the internet governance and online rights arenas in Africa and beyond to deliberate on gaps, concerns and opportunities for advancing privacy, access to information, free expression, non-discrimination and the free flow of information online on the continent.
Since inception, FIFAfrica has also served as a platform to mark the International Day for Universal Access to Information (IDUAI). Engagements at the Forum aim to reflect current trends and concerns in access and usage of the internet and related technologies on the continent. As such, each year has seen us launch themed research on the State of Internet Freedom in Africa. Last year, we also launched a key report on Calculating the Economic Cost of Internet Disruptions in Sub-Saharan Africa.
While the 2014, 2015 and 2016 editions of FIFAfrica were hosted in Uganda, in 2017, the Forum was hosted in Johannesburg, South Africa in partnership with the Association for Progressive Communications (APC), an international network and non-profit organisation that works towards a free and open internet.
Indeed, spreading the physical footprint of FIFAfrica across different regions of the continent ensures that the Forum lives up to its goal of unpacking internet freedom challenges and opportunities in sub-regions of Africa and developing responses that are collaborative, and informed by insights from the experience of other sub-regions of the continent. Hosting the Forum in in west Africa for the first time will not only open up the space to more west African civil society, private sector and public sector actors to contribute their experiences to the regional discussion, but will  also give life to the Forum’s commitment of ensuring broader regional representation and deepening conversations across the continent.
At a practical level, skills development among participants is prioritized. Previous Forums have seen our partners AccessNow and DefendDefenders host digital security clinics. In 2017, The Localisation Lab hosted a localization sprint aimed at advancing the adoption of internet freedom tools in East and Southern Africa through translation of technologies and creation of key resources to support the education, training, and adaptation of digital security and circumvention tools in the region. This included the translation of tools into languages like Shona, Luganda, and Ndebele.
Other skills development events at the Forum have in the past included a workshop on Strategic Digital Rights Litigation hosted in partnership with the Berkman Klein Center for Internet & Society at Harvard University, and the Media Legal Defence Initiative (MLDI) and a workshop on human rights review mechanisms, which took participants through African and United Nations (UN) Universal Periodic Reviews processes which was hosted by APC, CIPESA and Small Media.
With strategic linkages to other internet freedom forums and support for the development of substantive inputs to inform the conversations on human rights online happening at national level, at the African Union and the African Commission on Human and People’s Rights (ACHPR), the African Internet Governance Forum (IGF), subregional IGFs, the global IGF, Stockholm Internet Forum (SIF), the Internet Freedom Festival (IFF), the Internet Freedom Forum (Nigeria) and RightsCon, among others, FIFAfrica provides a pan-African space where discussion from these other events can be consolidated at continent-wide level, drawing a large multi-stakeholder audience of actors.

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