You have reached the TCS privacy addendum for Botswana. To go back to the general TCS privacy notice, please click here.
For data subjects of Botswana, when we collect and use personal data (information) about you, we may be subject to the Botswana Data Protection Act (‘BDPA’) of Botswana and responsible as a ‘data controller’ for such personal data. Below you will find the additional specific provisions applicable to you as a data subject whose data is processed in Botswana; including your rights to your data as it may be processed by TCS.
How we will use your personal data
Where the BDPA is applicable to TCS, we are only permitted to process your personal data on the basis of certain legal requirements which are outlined in the applicable legislation. As such, you will find below the valid legal bases which permits us to process your personal data for the fulfilment of one of the below purposes (which are outlined more specifically above in our general notice).
- To ensure access to our website and online services
Under the BDPA, the lawful basis for this processing is our legitimate interest in enabling and improving our website and online services, or consent, where requested and obtained. - To answer your queries, support and contact requests
Under the BDPA the lawful basis for this processing may be for the performance of a contract with you or to take steps at your request before entering into a contract with you, or for our legitimate interests in behaving as a responsible organization in dealing with these matters, or consent, where requested and obtained. - Subscriptions to our promotional communications
Under the BDPA the lawful basis for this processing is the consent, where requested and obtained. - To administer events and activities
Under the BDPA the lawful basis for this processing is our legitimate interest in organizing and running such events, or consent, where requested and obtained. - To manage, administer and fulfil the obligations under contracts, and regulations
Under the BDPA and depending on the processing activity, the lawful bases for this processing may be for the performance of a contract with you or to take steps at your request before entering into a contract with you, our legitimate interest in providing services to your company or employer, or legal obligation. - To promote TCS brand, products, initiatives and values with marketing communications
Under the BDPA the lawful basis for this processing is TCS’ legitimate interests in promoting its brand, products, initiatives and values, or consent, where requested and obtained.
Transferring Data Subject information outside of Botswana
We may transfer the personal data we collect about you to one of more countries outside Botswana, including India, in order to perform one of the activities under the heading ‘How we will use your personal data’ in this notice and the TCS general privacy notice. Where there isn't an adequacy decision by the Commission in respect of those countries - meaning that these are not deemed to provide an adequate level of protection for your personal data - we have put in place the appropriate measures to ensure that your personal data will be secure. These measures include Data Transfer Agreements based on the Botswana standard data protection clauses requirements’. If you require further information about these protective measures, you can request it from our Data Protection Officer (see contacts below).
Your duties and rights in connection with personal data
If the processing of your personal data is subject to the BDPA, you are obligated to the duties and entitled to the rights listed below.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, subject to procedural requirements.
- Request rectification of the personal data that we hold about you. This enables you ask us to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us, in certain situations, to delete or remove personal data where it is no longer necessary for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below) or revoked consent, provided no other lawful requirements permit retention.
- Object to processing of your personal data where we are relying on a public interest or legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes and in certain circumstances profiling.
- Be informed on retention of your personal data at collection of your personal, data which TCS determines on the bases of legal obligation, establishment, exercise or defence of legal claims or your consent.
- Be provided with information on the collection and processing of your personal data when it is collected directly from you or not collected directly from you, within a reasonable time, where you have not previously been informed of the collection of your information indirectly by TCS or another valid reason expressed in BDPA exists that does not requirement notification.
- Further, to be provided detail on the consequence of not providing or refusing to provide personal data.
- Request the restriction of processing of your personal data. This enables you to ask us, in certain circumstances, to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Data portability, which enables you to ask us, in certain circumstances, to provide you with the personal data you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal data that you have provided to us to another party.
- Be informed about Automated decision-making and not to be subject to a decision based solely on automated processing that produces profiling and may result in legal effects concerning you or similarly significantly affects you.
- Be notified of any personal data breach affecting your personal data.
- Lodge a complaint with TCS or the Commission regarding the treatment of your personal data.
If you are a data subject for TCS Botswana and want to exercise a data subject right in connection to your personal data, please contact our Data Protection Office for Botswana (see contacts below).
What we may need from you
If you exercise one of the above rights, we may need to request specific information from you to help us confirm your identity and that you are entitled to make such a request. This is to ensure that personal data is not disclosed to any person who has no right to receive it.
Data protection supervisory Authority under BDPA
If you're not satisfied of how we process your personal data and the processing of your personal data is subject to the BDPA, you can lodge a complaint at any time to our Data Protection Office or to the Commission.
Data Protection Officer
We have appointed a Data Protection Officer to oversee compliance of TCS with applicable data protection laws and with this privacy notice. If you would like to exercise one of the above rights in connection to your personal data or if you have any queries or complaints about our privacy notice or how we handle your personal data, please write to our Information Office at Mea.privacy@tcs.com
