Ghana Telecommunication Company Limited (GTCL) - Privacy Notice

Overview

This Privacy Statement explains the data processing practices of GTCL. If you have any requests concerning your personal information or any questions about these practices, please contact our Privacy Officer by e-mail atprivacy@telecel.com.gh. We encourage you to periodically review this Statement as GTCL reserves the right to alter or change the terms and information set out in this Statement at any time at its sole discretion

If at any time, you provide us with personal information for registration or procurement of any of our Services, your privacy rights will be protected according to our stated general and privacy policies. These will be posted and available for your review at the time of purchase. Kindly note that your personal information shall also represent/mean your personal data (any information relating to you directly or indirectly as an identifiable natural person).

Personal information we collect about you

The information we collect about you and how we collect it can vary depending on the products and services that you use and subscribe to, how you have used the products and services, and how you have interacted with GTCL even if you aren’t a customer, or what we have obtained from a third party with permission to share it with us.

GTCL will process your personal data based on:

The performance of your contract or to enter into the contract and to take action on your requests. For example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using, and when you’re doing it so we can provide connectivity. This also enables us to generate your bill, based on your usage.

GTCL’s legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, direct marketing, and the improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases, you have the right to object to this processing.

Compliance with a mandatory legal obligation, including for example accounting and tax requirements and regulations to electronic communications and financial services, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data, which control the scope of legal assistance to be provided.

Substantial public interest, for example, to assist with detecting and preventing fraud, tax evasion, and financial crime, or to safeguard the economic well-being of certain individuals.

Consent you provide where GTCL does not rely on another legal basis. Consent may be withdrawn at any time. When you give your consent, you will be given details on how to change your mind.

We will collect your personal information when you, for example:

• Buy or use any of our products and services.
• Use our network or other GTCL products and services.
• Register for a specific product or service.
• Subscribe to newsletters, alerts, or other services from us.
• Contact us through various channels or ask for information about a product or service.
• Take part in a competition, prize draw, event, or survey.
• Visit or browse our website or other GTCL websites.
• Have permitted other companies to share information about you.
• Where your information is publicly available.
• Are the customers of a business that we acquire.

We may also collect information about you on CCTV when you visit our premises or on other security cameras as part of our security and crime prevention measures.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). For more details on this and how to opt out of these, please visit our Cookies policy page.

We’ll also get information about how you use our products and services, such as:

• The level of service that you receive – for example, network or service faults and other events that may affect our network services or other services.
• Details of your use of the specific services or products, for example: every time you use your mobile phone, a record is kept. This includes the number you called or sent a text or picture message to, the length, date, and time of that call, text or picture message, and your approximate location at the time that the communication takes place (based on the location of the nearest cell that you sent that call or message from). The same is also recorded every time you receive an incoming call or message. We don’t, however, keep a record of the content of your calls or messages.
• Your traffic data. This is data we see as part of providing you with connectivity, like the numbers you call, the time and duration of the call, or how you are using data.
• Your location data. This can be precise where it uses Global Positioning System (GPS) data or by identifying nearby mobile phone masts and Wi-Fi hotspots and enabling location-based services or features. Or less precise where, for example, a location is derived from your IP address or data such as a postcode or name of a town or city.
• Your contact with us, such as a note or recording of a call you make to one of our contact centres, a Live Chat, an email, or letter sent, or other records of any contact with us.
• Your account information, such as dates of payment owed or received, subscriptions you use, account numbers, or other information related to your account.
• Credential information – we’ll collect passwords, hints, and similar security information used for authentication and access to accounts and services.
• See the ‘Cookies Policy’ for details on what we collect using cookies, web beacons, and other technologies.
• Your browsing history. We don’t have a history of the sites you browse, as this is limited for a short time to enable the connection.
• The level of service that you receive – for example, network or service faults and other events that may affect our network services or other services.
• Details of your use of the specific services or products, for example: every time you use your mobile phone, a record is kept. This includes the number you called or sent a text or picture message to, the length, date, and time of that call, text or picture message, and your approximate location at the time that the communication takes place (based on the location of the nearest cell that you sent that call or message from). The same is also recorded every time you receive an incoming call or message. We don’t, however, keep a record of the content of your calls or messages.

How we use your personal information:

We use your Data for purposes, which may include but are not limited to the following:

1. To provide you with your service:

   1. Processing your order and providing you with your products and services:

      • To process the products and services you’ve bought from us, install equipment at your property or deliver equipment to you, and keep you updated with the progress of your order.

   2. Billing and customer care:

      • To bill you for using our products and services, or to take the appropriate amount of credit from you.
      • Contact you if the billing information you provided us with is about to expire or we’re not able to take payment.
      • To respond to any questions or concerns you may have about our network, products, or services.

   3. Service messages:

      • We will contact you with customer service messages to keep you updated with current information about products and services you’ve taken. For example, changes to our terms and conditions or service interruptions.

2. To improve our service:

   1. Improving and innovating our products and services:

      • We collect anonymous, de-identified, or aggregate information to improve the service we offer to everyone. None of these analytics are linked back to you in any way.

   2. Managing our networks and understanding network usage:

      • To protect our networks and manage the volumes of calls, texts, and other uses of our networks. For example, we identify peak periods of use so we can try and ensure the networks can handle the volume at those times.
      • To understand how you use our networks, products, and services. That way we can seek to review and improve these and develop more interesting and relevant products and services, as well as personalizing our products and services.

3. Marketing and tailoring our service to you Marketing:

   1. • As our customer, we will contact you to keep you informed about new and existing products and services, competitions, prize draws, events, rewards offers, and other promotions and we may use your personal information to run those competitions, prize draws, events, and promotions. We may also send you texts and occasionally invite you to participate in market research. We tailor these messages based on the products and services you’ve bought from us in the past.

4. Research and analytics:

   1. We use a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and hitherto unrevealed trends. At GTCL we take governance of big data analytics seriously. Our data scientists are required to sign up to a Code of Ethics. We have a strict use case process that requires that privacy and data protection law checks are carried out before any use case commences. We also have strict rules ensuring that personal information is anonymized or de-identified at the appropriate stage in the process. We use our analytics to, for example:

      • Conduct market research and carry out research and statistical analysis, including monitoring how customers use our networks, products, and services.
      • Frame our marketing campaigns and determine how we might personalize those.

5. Credit checks, fraud prevention and security:

   1. We will sometimes need to profile you, for credit, fraud, and security purposes

   2. Credit checks and ID:

      • We will carry out a credit check when you apply for a contract for any products or services with us.

   3. Fraud prevention and security:

      • We will process your personal and traffic data to protect against and detect fraud, to protect and detect misuse or damage to our networks, to recover debts, or to trace those who owe us money resulting from the use of our services

How we protect your personal information

We have specialized security teams who constantly review and improve our measures to protect your personal information from unauthorized access or use, alteration, accidental loss, disclosure, or unlawful or accidental destruction.

Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through several countries before being delivered, as this is the nature of the internet.

We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.

Our website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. So, make sure you read that company’s privacy and cookies policies before using or putting your personal information on their site.

The same applies to any third-party websites or content you connect to using our products and services.

You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter, and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.

Social plug-ins and social applications are operated by the social network themselves and are subject to their terms of use and privacy and cookie policies. You should make sure you’re familiar with these.

Ghana Telecommunication Limited shall take reasonable and appropriate technical and organizational measures against the unauthorized or unlawful deliberate interference with Customers’ personal data, however, there is still some risk that criminals could find a way to thwart our security systems.

How we share your personal information

Where applicable, we share information about you with:

• Partners, suppliers, or agents involved in delivering the products and services you’ve ordered or used.
• Companies who are engaged to perform services for, or on behalf of, Telecel Ghana, or Ghana Telecommunications Company Limited (GTCL) Credit reference, fraud prevention or business-scoring agencies, or other credit scoring agencies.
• Debt collection agencies or other debt-recovery organizations
• Law enforcement agencies, government bodies, regulatory organizations, courts, or other public authorities if we have to, or are authorized to by law.
• A third party or body where such disclosure is required to satisfy any applicable law or other legal or regulatory requirement.
• Emergency services (if you make an emergency call), including your approximate location.
• Third parties that we advertise with to serve you advertisements online (e.g., Facebook, Google, Twitter, Amazon)

Fraud management and law enforcement:

• We will release information if it’s reasonable to protect us against fraud, defending our rights or property, or protecting the interests of our customers.
• We also may need to release your information to comply with our legal obligation to respond to the authorities’ lawful demands. Your personal data shall only be provided when we in good faith believe we are obliged to do so in accordance with the law and according to an exhaustive evaluation of all legal requirements

Mergers and acquisitions:

• If we’re reorganized or sold to another organization, we will provide your information to that organization.

International data transfers:

• The Internet is a global environment. Using the Internet to collect and process Personal Data necessarily involves the transmission of Data on an international basis. When we collect Personal Information from you on our website, we comply with both local and international data protection laws and safeguards.

How long do we keep your personal information for :

• At GTCL, we ensure that your personal data is processed fairly, lawfully, and kept no longer than necessary.

Your privacy rights

You can write to us at any time to get a copy of the personal information we hold about you. Please complete an application form available either by walking into any of our retail shops clickhereto view online

Send the completed form to disclosures@telecel.com.gh at no charge. Allow GTCL seven (7) working days to provide you with the requested information.

If you wish to change or correct your information or lodge a complaint, please contact our Customer Care Service Team as follows:

• Helpline: 100 / 050 555 5111
• WhatsApp: 0501000300
• Email: info@telecel.com.gh
• Twitter: @Asktelecelgh
• Facebook: Telecel Ghana

You may reach out to the Data Protection Commission at https://www.dataprotection.org.gh/ if you feel your privacy rights have been violated.

You also have the right to withdraw the consent given to us by you. We shall not process your personal data where you object to this being carried out and withdraw your consent. We may however not be able to fulfil our contractual obligations to you where your personal data is required after withdrawal of your consent.

Changes to this Policy

This Statement takes effect from 1 July 2018. From time to time we may make changes to this Privacy Statement to reflect any changes to our privacy practices in accordance with changes in legislation, regulation, best practice, or website enhancements. We will notify you about material changes to this Statement by placing a prominent notice on our website

Last updated on 19 February 2024