Contractor Privacy
Effective date: May 23rd, 2025
1. Introduction
At KYAfrica, we are committed to maintaining the privacy and security of all individuals and entities we work with, including independent contractors and service providers. This Contractor Privacy Policy outlines how we collect, use, store, share, and protect the personal data of contractors in compliance with applicable data protection laws, including but not limited to:
- The Nigeria Data Protection Act (2023)
- The Nigeria Data Protection Regulation (NDPR)
- Kenya’s Data Protection Act
- The EU General Data Protection Regulation (GDPR)
- The UK GDPR and other relevant laws
By engaging with KYAfrica as a contractor, you agree to the collection and use of your personal data as outlined in this policy.
2. Scope
This policy applies to:
- Independent contractors
- Freelancers and consultants
- Third-party vendors or agencies
- Technical or academic service providers
It covers personal data processed by KYAfrica in connection with the contractor’s engagement, onboarding, or service delivery.
3. Definitions
“Contractor” – Any individual or organization providing services to KYAfrica under a non-employee agreement.
“Personal Data” – Information that identifies or can identify a living individual (e.g., name, email, ID number, payment details, etc.).
“Processing” – Any operation performed on personal data, including collecting, storing, using, and deleting it.
“Data Controller” – KYAfrica, who determines the purpose and means of processing your personal data.
4. What Information We Collect
KYAfrica may collect the following categories of data from contractors:
Identity Information: Full name, date of birth, gender
Contact Information: Email address, phone number, physical address
Professional Data: CV, portfolio, skillset, certifications, job role, references
Legal & Tax Documents: Government-issued ID, tax ID, business registration certificates
Banking Information: For payment processing
Contractual Information: Agreements, scopes of work, invoices
Usage Data (if using our systems): Access logs, communication records, task submissions
5. How We Collect Your Data
We collect data:
- Directly from you during onboarding or contracting
- Via email or document submissions
- Through our platforms or project management tools
- From public sources (e.g., LinkedIn, portfolio sites) or references
6. Purpose of Data Collection
We process contractor data to:
- Verify identity and qualifications
- Draft and execute service contracts
- Communicate and coordinate deliverables
- Process payments and issue invoices
- Maintain compliance with tax and labor laws
- Assess service quality and audit performance
- Protect the legal and operational interests of KYAfrica
7. Legal Basis for Processing
Depending on your location, the lawful basis for processing your data may include:
- Performance of a contract
- Legal obligation (e.g., tax or employment compliance)
- Legitimate interest (e.g., business operations, fraud prevention)
- Consent (where required)
8. Data Sharing and Disclosure
KYAfrica may share your personal data with:
- Internal teams (HR, finance, project managers)
- External auditors or regulatory bodies (as required by law)
- Payment processors and financial institutions
- Tax and government agencies (for compliance)
- Third-party platforms used for service delivery (e.g., Trello, Slack, Google Workspace)
All data shared with third parties is done under strict confidentiality and in line with data protection agreements.
9. International Transfers
Your data may be processed or stored in countries outside your own, including the US, UK, or within the EU. Where data is transferred internationally, KYAfrica ensures:
- Adequate legal safeguards are in place
- Data is handled securely and only for intended purposes
- Cross-border processing complies with GDPR, NDPR, or similar laws
10. Data Retention
We retain contractor data only for as long as needed to:
- Fulfill contractual obligations
- Meet legal and financial reporting requirements
- Resolve disputes or enforce agreements
When no longer needed, data will be securely deleted or anonymized.
11. Security Measures
KYAfrica protects contractor data with:
- Encryption and secure file storage
- Role-based access controls
- Confidentiality clauses in contracts
- Regular audits and compliance training
Contractors are expected to follow our security protocols and protect any KYAfrica data they access.
12. Your Rights
Subject to applicable laws, you have the right to:
- Request access to your personal data
- Correct inaccurate or incomplete data
- Request deletion of your data (where applicable)
- Object to or restrict processing
- Withdraw your consent at any time
- Lodge a complaint with a Data Protection Authority
To exercise these rights, contact us at dpo@kyafrica.com.
13. Contractor Responsibilities
As a contractor, you agree to:
- Provide accurate and up-to-date information
- Use KYAfrica systems securely and professionally
- Keep confidential all data or materials shared with you
- Inform us of any data breaches, loss, or misuse affecting KYAfrica data
- Comply with all data protection clauses in your contract
14. Changes to This Policy
We may update this Contractor Privacy Policy from time to time. Changes will be communicated via email or through our platform. Continued engagement with us after updates constitutes your acceptance of the revised policy.
15. Contact Us
For any questions or concerns about your data or this policy, please contact: dpo@kyafrica.com.
