Data Management Procedures

Policy
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Data Management Procedures Admin March 6, 2025
  1. Purpose

The purpose of these Data Management Procedures is to establish a robust, secure, and compliant framework for the collection, storage, access, retention, and disposal of data related to projects undertaken by Africa Transcribe Enterprises Ltd. These procedures ensure compliance with Tanzania’s Personal Data Protection Act (2022) and align with international standards, such as GDPR and ISO 27001, to safeguard sensitive information, meet client expectations, and maintain operational excellence in transcription services.

  1. Scope

These procedures apply to all data generated, collected, or processed during the course of a project, including but not limited to:

  • Transcription files (e.g., audio recordings, text transcripts)
  • Project-related documents (e.g., client briefs, contracts, correspondence)
  • Electronic files (e.g., databases, emails, spreadsheets)
  • Physical records (e.g., paper notes, forms)
  • Media files (e.g., images, videos, audio uploads)

This applies to all employees, contractors, and third parties involved in project activities, whether based in Tanzania or operating internationally.

  1. Data Management Principles
  • Accuracy: Data must be accurate, complete, and reflective of client requirements.
  • Security: Data must be protected against unauthorized access, loss, or breaches using internationally recognized safeguards.
  • Accessibility: Authorized personnel must have appropriate, role-based access to data.
  • Compliance: Data handling must comply with Tanzania’s Personal Data Protection Act (2022), international regulations (e.g., GDPR where applicable), and client agreements.
  • Transparency: Data subjects (e.g., clients or individuals in recordings) must be informed of data use where required.
  • Efficiency: Processes should optimize transcription workflows and resource use.

 

  1. Procedures
    • Data Collection
  • Data will only be collected as necessary to fulfil transcription and project requirements, adhering to the principle of data minimization.
  • Sources of data (e.g., client-provided audio, documents) must be documented, including origin, date of receipt, and responsible party.
  • Where personal data is involved, explicit consent must be obtained from clients or data subjects in accordance with Tanzania’s Personal Data Protection Act and international standards (e.g., GDPR Article 6).
    • Data Storage
  • Electronic Data: Stored in a secure, centralized system (e.g., encrypted cloud storage or internal servers) compliant with ISO 27001 security standards.
  • Physical Data: Stored in locked filing cabinets or secure storage rooms at Africa Transcribe Enterprises Ltd.’s Tanzania headquarters or authorized facilities, with restricted access.

Backup copies of critical data (e.g., raw audio files, final transcripts) must be maintained in encrypted form and tested quarterly.

  • Data Access
  • Access is granted on a need-to-know basis, determined by the Project Manager or Transcription Supervisor, following the principle of least privilege.
  • User permissions must be reviewed at the start and end of each project and revoked upon project completion or staff departure.
  • Access logs will be maintained for sensitive data, including personal data as defined under Tanzania law and GDPR.
    • Data Retention
  • Retention Period: All project-related data will be retained for a period of 6 months following the official completion date of the project, unless otherwise required by Tanzania law, international regulations, or client contracts.
  • Completion Date: Defined as the date of final transcript delivery or client sign-off, as documented by the Project Manager.

During the retention period, data will remain accessible to authorized personnel for quality assurance, client inquiries, or audits, with access controls intact.

  • Data Disposal
  • After the 6-month retention period, data will be securely disposed of unless retention is extended by legal or contractual necessity.
  • Electronic Data: Permanently deleted using secure deletion tools (e.g., compliant with NIST 800-88 standards) to prevent recovery.
  • Physical Data: Shredded or incinerated by a designated staff member at the Tanzania headquarters, ensuring confidentiality.

A disposal log will be maintained, recording the date, method, and responsible party, in line with Tanzania’s data protection requirements.

  • Data Security
  • All data must be protected against unauthorized access, disclosure, or alteration using encryption (e.g., AES-256), strong passwords, and multi-factor authentication (MFA).
  • Physical records must be stored in secure, monitored locations at Africa Transcribe Enterprises Ltd facilities.
  • Data breach response plans must be in place, including immediate notification to the Tanzania Data Protection Authority and affected parties within 72 hours, as per international best practices (e.g., GDPR Article 33).
    • Monitoring and Compliance
  • Regular audits of data management practices will be conducted semi-annually to ensure adherence to these procedures, Tanzania law, and international standards.
  • Any breach or non-compliance must be reported immediately to the Data Protection Officer for investigation, remediation, and reporting to the Tanzania Data Protection Authority if required.
  1. Responsibilities
  • Administrative and Operations Lead: Oversees data management for their projects, ensures compliance, and authorizes access.
  • Projects Manager: Ensures transcription team members adhere to data handling protocols.
  • Data Protection Officer (DPO): Oversees compliance with Tanzania’s Personal Data Protection Act, international regulations, and client requirements; manages breach responses.
  • Data Custodian: Responsible for secure storage, backup, and disposal of data.
  • Employees/Contractors: Must follow these procedures and report issues or breaches promptly.

 

  1. Exceptions

Data subject to legal holds (e.g., under Tanzania law), international regulations (e.g., GDPR cross-border data transfers), or specific client contracts may be retained beyond the 6-month period. Such exceptions must be documented and approved by the Data Protection Officer.

  1. Review and Updates

These procedures will be reviewed annually or as needed to reflect changes in Tanzania’s legal framework, international standards (e.g., updates to GDPR or ISO 27001), or organizational needs of Africa Transcribe Enterprises Ltd.

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