Your Data. Our Responsibility.
At BTC, we are committed to protecting your data and respecting your privacy. This section outlines how we collect, use, store, and safeguard your information across all our digital channels.
We ensure full compliance with applicable data protection laws and uphold the highest standards in handling your data, whether you’re browsing our website, using our services, or engaging with us online.
Our goal is to be transparent and give you control over how your data is used. Here, you’ll find key information about:
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Your data rights
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How we keep your information secure
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Our privacy practices and policies
PRIVACY NOTICE FOR BTC SERVICE USERS
The types of personal data we collect depend on the specific purposes for which it is processed. We only collect data that is necessary, relevant, and limited to what is required for those purposes, which may include the following:
PURPOSE AND LEGAL BASIS
| Type of Personal Data | Purpose of processing | Legal basis |
| First name and surname, email address, phone number, and other contact information. | Register customers, communicate about services, and manage accounts. | Performance of a contract
Legitimate interests in customer support |
| Payment card information (PCI), i.e., Cardholder data such as the cardholder’s name, the primary account number, and the card’s expiration date and security code | Process payments and fulfil transactions | Performance of a contract
Compliance with legal obligations (e.g., tax law) |
| Sensitive Personal data (criminal checks, biometric data, and the personal data of minors). | Verify identity, assess eligibility for specific services. | – Explicit consent |
| Log-in credentials and authentication data | Allow secure access to online services and ensure account security. | Performance of a contract
Legitimate interests in ensuring service security |
| Demographic data such as your gender, age, country, and preferred language | Personalise services, content, communication, and user experience | Consent
Legitimate interests in service customisation |
| Device and browsing data (data about how you and your PC or device interact with BTC, including web pages you visit when you use our websites and device, connectivity, and configuration data). | Improve website functionality, performance, and user experience; compile website usage statistics from platforms. | Legitimate interests in improving digital services. |
HOW WE COLLECT DATA
– Directly from you when you create an account, make a purchase, communicate with us, participate in promotions, or access our websites and digital platforms; and from third parties, including public databases, analytics providers, and marketing or technical partners.
Additionally, technical data is automatically collected through cookies and similar technologies.
WE MAY SHARE YOUR DATA WITH
We may share your personal data with:
– our affiliates and subsidiaries;
– third-party service providers for IT, payment processing, analytics, and customer service; and
– regulatory authorities, courts, or law enforcement where legally required.
All recipients are required to implement appropriate data protection safeguards.
TRANSFERS OUTSIDE BOTSWANA
– BTC may transfer your personal data to countries outside Botswana. We prioritise countries recognised as having data protection standard equivalent to those in Botswana. Where this is not the case, we ensure appropriate safeguards are in place or rely on derogations that are available at law.
WHAT ARE YOUR RIGHTS?
You have certain rights regarding the personal data we hold about you, including:
– Right to Access: Access your data;
– Right to Rectification: Request rectification of inaccurate or incomplete personal data;
– Right to Objection: Object to the processing of your data based on legitimate interest or for direct marketing;
– Right to Erasure: Request erasure of your personal data in certain circumstances;
– Right to Restriction: Request restriction of processing of your data under specific conditions;
– Right to Portability: Receive your data in a structured, commonly used, machine-readable format and transfer it to another data controller; and where consent is the legal basis for processing, you have the right to withdraw that consent at any time.
Some rights may be subject to conditions based on the purpose and legal basis of processing. To exercise your rights, please contact us. We will explain any applicable limitations.
You also have the right to lodge a complaint with the Information and Data Protection Commission. We encourage you to contact us first so we can resolve your concerns directly.
AUTOMATED DECISION MAKING
BTC does not use your personal data to carry out automated decision-making or profiling that would produce legal effects or similarly significant consequences for you.
JOB APPLICANTS’ PRIVACY NOTICE
During the recruitment process, BTC collects and processes personal data to evaluate candidates, support hiring decisions, and comply with legal and operational obligations. The table below outlines the types of data collected, their purposes, and the legal basis for processing:
PURPOSE AND LEGAL BASIS
| Category of personal data | Purpose of processing | Legal basis |
| Identification data such as your name, ID number, or passport | Verify your identity during the recruitment process. | Legitimate interest in ensuring the authenticity of candidates and the integrity of the recruitment process. |
| Contact information such as your telephone number, email address, and physical address | Enable communication with you throughout the application process. | Legitimate interest in enabling timely and effective candidate communication. |
| Application and background information including your curriculum vitae, cover letter, qualifications, and work history | Assess your suitability for the role and evaluate your skills, experience, and qualifications. | Legitimate interest in conducting a fair and informed recruitment process. |
| References and background screening data, where applicable and lawful | Verify your professional background and confirm the accuracy of information provided. | Legitimate interests in mitigating recruitment risks and ensuring accurate hiring decisions. |
HOW WE COLLECT DATA
BTC collects your personal data directly from you during the application process including through application forms, CV submissions, interviews, and assessments. BTC may also obtain additional data from third parties such as referees, previous employers, or background screening providers, where permitted by law.
WE MAY SHARE YOUR DATA WITH
Where necessary, your personal data may be shared with third-party service providers such as recruitment agencies, background screening providers, or technical testing providers. All third parties are subject to contractual data protection obligations. In limited cases, BTC may share your personal data with regulatory or legal authorities where required by law.
CROSS-BORDER DATA TRANSFERS
BTC may transfer your personal data to jurisdictions outside Botswana, such as when using international background screening services or cloud-based recruitment platforms. In such cases, BTC ensures that appropriate safeguards are in place. Transfers may also be based on your explicit consent or BTC’s legitimate interests in accessing global service providers, provided those interests are not overridden by your rights.
RETENTION
BTC retains personal data collected during the recruitment process only for as long as necessary to assess your suitability for the specific role for which you applied and to manage the recruitment process. Once this purpose has been fulfilled, your data will be securely deleted or anonymised, unless further processing is justified.
In some cases, BTC may retain certain personal data beyond the recruitment process for purposes that are compatible with the original purpose. If further processing is not compatible with the original purpose, BTC will only proceed on the basis of a separate lawful ground, and you will be provided with prior notice.
If your application is successful, some of the personal data collected during recruitment may be incorporated into your employee file and processed as part of your employment relationship.
WHAT ARE YOUR RIGHTS?
You have certain rights regarding the personal data we hold about you, including:
– Right to Access: Access your data;
– Right to Rectification: Request rectification of inaccurate or incomplete personal data;
– Right to Objection: Object to the processing of your data based on legitimate interest or for direct marketing;
– Right to Erasure: Request erasure of your personal data in certain circumstances;
– Right to Restriction: Request restriction of processing of your data under specific conditions;
– Right to Portability: Receive your data in a structured, commonly used, machine-readable format and transfer it to another data controller; and where consent is the legal basis for processing, you have the right to withdraw that consent at any time.
Some rights may be subject to conditions based on the purpose and legal basis of processing. To exercise your rights, please contact us. We will explain any applicable limitations.
You also have the right to lodge a complaint with the Information and Data Protection Commission. We encourage you to contact us first so we can resolve your concerns directly.
AUTOMATED DECISION MAKING
BTC does not use your personal data to carry out automated decision-making or profiling that would produce legal effects or similarly significant consequences for you.
VENDOR/CONTRACTOR REPRESENTATIVE PRIVACY NOTICE
BTC collects and processes personal data to manage its relationship with contractors, to ensure compliance with applicable laws, including the Financial Intelligence Act, and to support its operational needs. The table below outlines the types of data processed, along with the purposes and legal bases for each processing activity
PURPOSE AND LEGAL BASIS
| Category of personal data | Purpose of processing | Legal basis |
| Identification information such as your full name, national ID or passport number, and photo | Manage the contractual relationship.
Comply with Know Your Customer (KYC) obligations under the Financial Intelligence Act. |
Performance of a contract.
Compliance with legal obligations |
| Contact information including your address, email address, and telephone number | Facilitate communication regarding the engagement to enable project coordination, issue notices, and respond to queries. | Performance of a contract. |
| Contractual and engagement data such as the terms of your service, invoice records, service logs and performance reports.
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Evaluating and monitoring service delivery, processing payments, and resolving disputes. | Performance of a contract.
Legitimate interests in maintaining efficient vendor management and service quality oversight. |
| Financial data including bank account details and tax identification numbers and VAT registration (where applicable). | Support payment processing.
Tax compliance. |
Performance of a contract.
Compliance with legal obligations under tax legislation |
| Access control and usage data such as user credentials, system access logs, and entry records | Monitor and control access to BTC systems and facilities. | Legitimate interests in ensuring the security of its infrastructure, data, and personnel. |
| Legal compliance data such as professional certifications, immigration documentation, or background screening results (where applicable) | Assess service eligibility and meet regulatory requirements. | Compliance with legal obligations (immigration and employment laws).
Legitimate interests in risk management and legal compliance. |
HOW WE COLLECT DATA
BTC collects your personal data directly from you during the contracting process, and throughout the duration of your engagement. Additional information may be collected from third parties, such as referees or regulatory authorities, where necessary and permitted by law.
WE MAY SHARE YOUR DATA WITH
BTC may disclose your personal data to third-party service providers such as payment processors, external auditors, legal and accounting advisors, or IT system support providers, all of whom are contractually obligated to maintain confidentiality and comply with data protection laws. BTC may also disclose your personal data to regulatory or public authorities when required to do so by law, including for compliance with KYC requirements under the Financial Intelligence Act.
CROSS-BORDER DATA TRANSFERS
Your personal data may be transferred to jurisdictions outside of Botswana that may not have the same data protection standards. In such cases, BTC will implement appropriate safeguards. Where necessary, BTC may also rely on your explicit consent or the necessity of the transfer for the performance of a contract. In limited cases, BTC may rely on its legitimate interests in securing services from cross-border providers, provided that your rights and freedoms are not unduly affected.
RETENTION
BTC retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required to comply with legal, regulatory, and contractual obligations.
Personal data collected and processed in accordance with BTC’s obligations under the Financial Intelligence Act, including Know Your Customer (KYC) information, will be retained for a period of twenty (20) years following the termination of the business relationship, in compliance with the requirements of that Act.
All other personal data is retained in accordance with BTC’s internal retention policy, which determines appropriate retention periods based on legal requirements, the nature of the data, and the purpose of processing. Once the relevant retention periods have expired, and where there is no lawful basis for continued retention, BTC will ensure that the data is securely deleted or anonymised.
WHAT ARE YOUR RIGHTS?
You have certain rights regarding the personal data we hold about you, including:
– Right to Access: Access your personal data;
– Right to Rectification: Request rectification of inaccurate or incomplete personal data;
– Right to Objection: Object to processing of your personal data based on legitimate interest or for direct marketing;
– Right to Erasure: Request erasure of your personal data in certain circumstances;
– Right to Restriction: Request restriction of processing of your personal data under specific conditions;
– Right to Portability: Receive your personal data in a structured, commonly used, machine-readable format and transfer it to another data controller; and where consent is the legal basis for processing, you have the right to withdraw that consent at any time.
Some rights may be subject to conditions based on the purpose and legal basis of processing. To exercise your rights, please contact us. We will explain any applicable limitations.
You also have the right to lodge a complaint with the Information and Data Protection Commission. We encourage you to contact us first so we can resolve your concerns directly.
AUTOMATED DECISION MAKING
BTC does not use your personal data to carry out automated decision-making or profiling that would produce legal effects or similarly significant consequences for you.
COOKIES AND SIMILAR TECHNOLOGIES
COOKIES
BTC uses cookies and similar technologies to:
– Enable sign-in and authentication;
– Store and manage preferences and settings;
– Compile statistics and monitor site performance; and
– Improve your browsing experience.
You can adjust browser settings to refuse cookies, though some features may be unavailable as a result.
FURTHER PROCESSING
If BTC intends to process your personal data for a purpose other than that for which it was originally collected, we will ensure that such processing is either compatible with the original purpose or based on a new lawful basis. We will inform you in advance of the new purpose and provide any additional information required under the law before such further processing takes place.
CHANGES TO THIS PRIVACY NOTICE
BTC may amend this Privacy Notice from time to time in response to changes in legal, regulatory, or operational requirements. Where material changes are made, BTC will provide notice of such changes either directly or by posting an updated version of the notice through appropriate communication channels. The most current version of the Privacy Notice will always be available upon request. You are encouraged to review the notice periodically to remain informed about how your personal data is processed.
CONTACT INFORMATION
If you have any questions about this notice or how BTC processes your personal data or if you wish to exercise any of your rights, you may contact the Data Protection Officer at:
Data Controller: Botswana Telecommunications Corporation
Physical Address: Khama Crescent, Plot 50350, Megaleng
Postal Address: P O Box 700 Gaborone, Botswana
Telephone Number: (+267) 395 8000
Email Address: DPO@btc.bw
If you are not satisfied with BTC’s response, you have the right to lodge a complaint with the Information and Data Protection Commissioner.