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Privacy Policy



  1. Definition of Terms



The removal of personal identifiers from personal data so that the

data subject is no longer identifiable.

Biometric data

Personal data resulting from specific technical processing based on physical, physiological or behavioural characterisation including blood typing, fingerprinting, deoxyribonucleic acid analysis, earlobe

geometry, retinal scanning and voice recognition.


Agreement which must be freely given, specific, informed and be an unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to

the processing of personal data relating to them.


Information which is processed by means of equipment operating automatically in response to instructions given for that purpose or recorded with intention that it should be processed by means of such

equipment or recorded as part of a relevant filing system.

Data Controller

The person or organisation that determines when, why and how to process personal data. It is responsible for establishing practices and policies in accordance with the Data Protection Act. Hazina Sacco is the Data Controller of all personal data relating to it and used in

facilitating its business operations.

Data Processing

Any activity that involves the use of personal data and includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. In brief, it is anything that can be done to personal data from its creation to its destruction, including both creation and


Data       Protection

Impact   Assessment (DPIA)

This is a tool or procedure of identifying and reducing risks involved in any processing activity that will involve personal data.






Data              Protection Officer

The person appointed as such under the Data Protection Act and in accordance with its requirements. A data protection officer is responsible for advising the Sacco (including employees) on their obligations under various data protection laws, for monitoring compliance with data protection law, as well as with Hazina Sacco


Data Subject

A living, identified or identifiable individual about whom the Sacco

hold personal data.

Personal Data

Any information identifying a data subject or information relating to a data subject that the Sacco can identify (directly or indirectly) from that data alone or in combination with other identifiers the Sacco possess or can reasonably access. Personal data includes sensitive personal data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an

opinion about that person’s actions or behaviour

Personal          Data Breach

Any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data, where that breach results in a

risk to the data subject.


Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or

movements. Profiling is an example of automated processing.

Third Party

Any natural or legal person other than the data subject, Hazina

Sacco, or any implementing partner.


  1. Purpose of this Policy

This Data Protection Policy has been developed as a guide to Hazina Sacco Society Ltd in management of stakeholders’ data. Hazina Sacco obtains, uses, stores and otherwise processes personal data relating to its stakeholders such as potential and current employees, former staff, members, suppliers, visitors to Sacco premises, contractors and website users, collectively referred to in this policy as data subjects. This Policy sets out how the Sacco manages those responsibilities.

In developing this Policy, the BOD intends to have this as the primary reference point for all matters pertaining to data management in the Sacco. Contents of this Policy will therefore be carefully studied and implemented, as it constitutes an integral part of the Society’s risk management processes. The Policy will be circulated to all Sacco officials and management to enable them to familiarise themselves with the provisions herein.

The Sacco heavily draws its data policy guidelines from the Data Protection Act, 2019 and the Data Protection General Regulations, 2021. When processing personal data, the Sacco is obliged to fulfil individuals’ reasonable expectations of privacy by complying with the Act and related Regulations and other relevant data protection legislation.

The policy document is therefore intended to ensure that the Sacco:

  • Is clear about how personal data must be processed and the Sacco’s expectations

for all those who process personal data on its behalf;

  • Complies with existing data protection laws and with good practice;
  • Protects its reputation by ensuring the personal data entrusted to it is processed

in accordance with data subjects’ rights;

  • Protects itself from risks of personal data breaches and other breaches of data protection law.
  1. Scope of this Policy

This policy applies to all personal data the Sacco processes regardless of the location where that personal data is stored (e.g. on an employee’s own device, Hazina Sacco ’s servers, Sacco website, etc.) and regardless of the data subject.

  1. Justification for collection of personal information

The Sacco may collect and use Data Subject’s personal data:

  • If it is necessary for the Sacco’s legitimate interest and so long as its use is fair, balanced and does not unduly impact data subject’s rights.
  • With the Data Subject’s consent. For example, to send marketing emails, to take and use a data subject’s photograph, to collect relevant medical information. The data subject can withdraw consent for this at any time.
  • As required to fulfil the Sacco’s legal obligations as a registered Deposit Taking Co-operative Society and employer. This includes sharing personal info with bodies such as SASRA, Ministry of the day responsible for co-operatives, NSSF, NHIF, Courts, Police, EACC, CRBs, among other legal/statutory bodies.

The Sacco will only process sensitive personal data if it has data subject’s explicit consent. In extreme situations, the Sacco may share data subject’s personal details with the emergency services if it believes it is in data subject’s ‘vital interests’ to do so.

  1. Sources of personal information

The Sacco may collect information about data subject from different sources, for example:

  1. Directly from data subject when they:
    • Apply for membership
    • Apply for account opening
    • Apply for sacco loan products
    • Apply for employment/internship
    • Are employed in the Sacco
    • Apply as a supplier
    • Register for or at one of events
    • Complete a survey
    • Visit sacco premises and register as guests
    • Subscribe for updates via Sacco’s mobile and electronic services.
  1. Indirectly:
  2. a) From other people who think that the data subject may be interested in collaborating in our
  3. b) From the public domain when the data subject has deliberately made the data
  4. c) From third parties such as previous or current employers to verify details about job
  5. d) From external sources such as publications and external reviewers or
  6. e) From another source when the guardian appointed has consented to the collection in cases where the data subject has an
  7. f) Where collection of data from another source is necessary:
    • for the prevention, detection, investigation, prosecution and punishment of crime;
    • for the enforcement of a law which imposes a pecuniary penalty; or
    • for the protection of the interests of the data subject or another person.
  1. Forms of personal information collected

The Sacco only collect personal information that is genuinely needed for its operations. This may include:

  • Contact details such as name address, email address and phone numbers
  • Biometric data such as thumb prints
  • Nationality
  • National ID and Passport information
  • Date of birth
  • Gender
  • Information about race and ethnicity
  • Qualifications
  • Bank account details
  • Medical information
  • Benefits received
  • Employment details
  • Photographs and video recordings
  • Tax and residency status for statutory requirements
  • References from previous employers or educational institutions
  • Contact details for family members and next of kin
  • Details of criminal convictions
  1. Personal Data Protection Principles

In processing personal data, Hazina Sacco Society Ltd shall be guided by the principles of data protection as captured in the Data Protection Act, and requires the Sacco to ensure that personal data is:

  1. a) Processed in accordance with the right to privacy of the data subject;
  2. b) Processed lawfully, fairly and in a transparent manner in relation to any data subject;
  3. c) Collected for explicit, specified and legitimate purposes and not further processed in a manner incompatible with those purposes;
  4. d) Adequate, relevant, limited to what is necessary in relation to the purposes for which it is processed;
  5. e) Collected only where a valid explanation is provided whenever information relating to family or private affairs is required;
  6. f) Accurate and, where necessary, kept up to date, with every reasonable step being taken to ensure that any inaccurate personal data is erased or rectified without delay;
  7. g) Kept in a form which identifies the data subjects for no longer than is necessary for the purposes which it was collected; and
  8. h) Not transferred outside the Sacco and the country, unless there is proof of adequate data protection safeguards or consent from the data

In complying with the stated data protection principles, Hazina Sacco will observe the following:

  1. Fairness and lawfulness

When processing personal data, the individual rights of the data subjects must be protected. Personal data must be collected and processed in a legal and fair manner.

  1. Restriction to a specific purpose

Personal data can be processed only for the purpose that was defined before the data was collected. Subsequent changes to the purpose are only possible to a limited extent and require substantiation.

  1. Transparency

The data subject must be informed of how his/her data is being handled. In general, personal data must be collected directly from the individual concerned. When the data is collected, the data subject must either be aware of, or informed of:

  1. a) The identity of the Data Controller
  2. b) The purpose of data processing
  3. c) Third parties or categories of third parties to whom the data might be transmitted, if
  1. Data reduction and data economy

Before processing personal data, the Sacco will determine whether and to what extent the processing of personal data is necessary in order to achieve the purpose for which it is undertaken. Where the purpose allows and where the expense involved is in proportion with the goal being pursued, anonymized or statistical data must be used. Personal data may not be collected in advance and stored for potential future purposes unless required or permitted by national law.

  1. Deletion

Personal data that is no longer needed after the expiration of legal or business process- related periods must be deleted. There may be an indication of interests that merit protection or historical significance of this data in individual cases. If so, the data must remain on file until the interests that merit protection have been clarified legally, or the Sacco has evaluated the data to determine whether it must be retained for historical purposes.

  1. Factual accuracy; up-to-date data

Personal data on file must be correct, complete, and – if necessary – kept up to date. Suitable steps must be taken to ensure that inaccurate or incomplete data are deleted, corrected, supplemented or updated.

  1. Confidentiality and data security

Personal data is subject to data secrecy/privacy. It must be treated as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction.

  • Rights of the Data Subject

Every data subject has the following rights:

  1. a) To be informed of the use to which their personal data is to be put;
  2. b) To access their personal data in custody of data controller or data processor;
  3. c) To object to the processing of all or part of their personal This does not apply if a legal provision requires the data to be processed;
  4. d) To correction of false or misleading data; and
  5. e) To deletion of false or misleading data about

A right conferred on a data subject may be exercised:

  1. a) by a person who has parental authority or by a guardian if the data subject is a minor;
  2. b) by a person duly authorized to act as a guardian or administrator in a case where the data subject has a mental or other disability; or
  3. c) by a person duly authorized by the data
  • Data Subject Consent

A data subject may prior to the processing of their personal data give consent either orally or in writing, and may include a handwritten signature, an oral statement, or use of an electronic or other medium to signify agreement.

The Sacco shall seek consent from data subjects through various means. These include the data subjects willingly:

  1. Appending their signature of acceptance of terms and conditions of engagement on physical consent form.
  2. Ticking an opt-in box on paper or electronically.
  • Clicking an opt-in button or link online.
  1. Responding to an email requesting consent.
  2. Volunteering optional information for a specific purpose.
  3. Selecting from equally prominent Yes/No options.

In obtaining consent from a data subject, the Sacco shall ensure that the data subject:

  1. a) has capacity to understand and communicate their consent;
  2. b) is informed of the nature of processing in simple and clear language that is understandable;
  3. c) is informed whether data is being transferred to third party or implementing partners, or whether data is being collected by a third party on behalf of Hazina
  1. d) is informed of their duty to keep Hazina Sacco informed of changes to their personal data and
  2. e) is informed of right to access to their personal data, or correction or deletion of
  3. f) is informed of procedure to lodge a complaint in case of suspected
  4. g) is informed of the importance of providing accurate and complete
  5. h) voluntarily gives consent and that the consent is
  • Confidentiality of Data Processing

Personal data is subject to data secrecy. Any unauthorized collection, processing, or use of such data by employees is prohibited. Any data processing undertaken by an employee that he/she has not been authorized to carry out as part of his/her legitimate duties is unauthorized. The “need to know” principle applies. Employees may have access to personal information only as is appropriate for the type and scope of the task in question. This requires a careful breakdown and separation, as well as implementation, of roles and responsibilities.


Employees are forbidden to use personal data for private or commercial purposes, to disclose it to unauthorized persons, or to make it available in any other way. Supervisors must inform their employees at the start of the employment relationship about the obligation to protect data secrecy. The staff shall therefore sign an oath of secrecy at the time of engagement by the Sacco. This obligation shall remain in force even after employment has end

  • Data Processing Security

Personal data must be safeguarded from unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification or destruction. This applies regardless of whether data is processed electronically or in paper form. Before the introduction of new methods of data processing, particularly new IT systems, technical and organizational measures to protect personal data must be defined and implemented. These measures must be based on the state of the art, the risks of processing, and the need to protect the data.

In particular, the responsible department or staff can consult with the Registry Officer. The technical and organizational measures for protecting personal data are part of the Sacco’s data security management and will be adjusted continuously to the technical developments and organizational changes.

  • Duration for holding personal information 

The Sacco will hold personal information for as long as is necessary and will therefore not retain personal information if it is no longer required. In some circumstances, the Sacco may legally be required to retain data subject’s personal information, for example for finance, employment or audit purposes.

  • Data Breach and Notification

Hazina Sacco shall promptly notify the Office of the Data Commissioner within 72 hours upon becoming aware of personal data breach involving data subject within its records and properly record the breach. The Sacco shall also undertake to inform the data subject within reasonable time of the breach on their personal data and explain mitigating measure taken to safeguard the data and address potential adverse effects of the breach.

Hazina Sacco may update this Data Protection Policy from time to time. We will notify you of any changes by posting the new Data Protection Policy on our website. If you have any questions about this Policy, please contact us.