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Data Protection Policy for High System Botswana (Pty.) Ltd.

1. Introduction

At High System Botswana ("the Company"), we are committed to protecting the privacy and security of the
personal data we handle in the course of our business. As a telecommunication contractor managing generators
remotely for clients, we are required to ensure that all personal and sensitive data we collect, process, store, or
share is handled in compliance with the Data Protection Act, 2024, and applicable data protection laws.

This Data Protection Policy outlines how we collect, use, store, and protect personal data to ensure the privacy
and rights of data subjects (clients, employees, contractors, and any other individuals whose data we process).

2. Scope of the Policy

This policy applies to all employees, contractors, and third-party service providers who handle personal data on
behalf of the Company. It covers:

 Personal data of employees

3. Data Protection Principles

The Company is committed to ensuring that all personal data is:

1. Processed Lawfully, Fairly, and Transparently: We will inform individuals about the collection and
use of their data and ensure transparency in our processes.
2. Collected for Specific, Legitimate Purposes: Personal data will only be collected for the purposes
necessary for the operation of our telecommunication services and generator management systems.
3. Adequate, Relevant, and Limited: We will collect only the minimum amount of personal data
necessary to fulfill the identified purposes.
4. Stored Securely: We will take appropriate security measures to protect personal data from
unauthorized access, loss, or misuse.
5. Retained Only for as Long as Necessary: Personal data will be retained only for the period
necessary to fulfill the purposes for which it was collected.
6. Processed in a Way that Protects Data Subjects' Rights: Data subjects will be able to exercise
their rights to access, correction, and deletion of their data.

4. Data Collection and Use

We collect and process the following types of data:

 Client Data: Information provided by clients, including contact details, billing information, and service
agreements.
 Employee Data: Information about employees for employment-related purposes.
 Generator Monitoring Data: Remote monitoring data related to the operation and performance of
generators, including operational metrics, maintenance history, and incident reports.
 Contractor Data: Information regarding third-party contractors, such as contact details and work
performance.

The data we collect is used solely for managing generator operations, providing maintenance services,
conducting business transactions, and fulfilling contractual obligations with clients.

[email protected], 72732668, 74285418, Plot 51554 unit 7, G-west industrial, Gaborone, Botswana
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5. Data Security

We take the following measures to ensure the security of personal data:

 Access Control: Only authorized personnel have access to personal data. We use role-based access
controls to ensure that access is granted based on the need to know.
 Data Encryption: Sensitive data is encrypted when stored and transmitted.
 Sensitization: Employees and sub-contractors are sensitized about the data protection act that is in
force.
 Regular Audits: Conduct bi-annual audits of our data handling processes to ensure compliance with
this policy and the Data Protection Act, 2024.

6. Data Subject Rights

As a data subject, you have the following rights regarding your personal data:

1. Right to Access: You have the right to request access to the personal data we hold about you.
2. Right to Rectification: You have the right to request that we correct any inaccurate or incomplete
data.
3. Right to Erasure: You have the right to request that we delete your personal data when it is no
longer necessary for the purposes for which it was collected.
4. Right to Restriction: You have the right to request the restriction of processing of your personal data
in certain circumstances.
5. Right to Data Portability: You have the right to request a copy of your personal data in a structured,
commonly used, and machine-readable format.
6. Right to Object: You have the right to object to the processing of your personal data in certain
circumstances.

7. Data Breach Procedures

In the event of a data breach involving personal data, we will take immediate action to:

1. Notify the Information and Data protection commission within 72 hours, as required by the
Data Protection Act, 2024. Contact no. 3957755, and E-mail : [email protected]
2. Inform Affected Individuals if the breach is likely to result in high risk to their rights and freedoms.
3. Investigate and mitigate the breach, identifying its cause and implementing measures to prevent
future occurrences.

8. Cross-Border Data Transfers

Personal data may be transferred to countries outside Botswana for processing and storage, particularly when
working with international clients or contractors. Cross-border data transfers will only occur if the destination
country has been determined to offer an adequate level of data protection, or if appropriate safeguards are in
place (e.g., contractual agreements, standard contractual clauses).

9. Data Retention

Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected,
including for legal, accounting, or reporting purposes. When data is no longer needed, it will be securely
destroyed or anonymized.

10. Accountability

The Company will designate a Data Protection Officer (DPO) responsible for ensuring compliance with this
policy. The DPO will oversee its implementation, address any questions or concerns related to data protection,

[email protected], 72732668, 74285418, Plot 51554 unit 7, G-west industrial, Gaborone, Botswana
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and act as the primary point of contact for regulatory authorities. In the interim, the Managing Director will
fulfill these responsibilities until a dedicated DPO is appointed.

11. Policy Review and Updates

This Data Protection Policy will be reviewed and updated regularly to ensure that it remains in line with the
latest legislative developments and best practices in data protection. Any significant changes will be
communicated to employees, contractors, and clients as appropriate.

Approval

This Data Protection Policy has been approved by the Directors of High System Botswana (Pty) Ltd. and is
effective as of 15th Jan 2024

[email protected], 72732668, 74285418, Plot 51554 unit 7, G-west industrial, Gaborone, Botswana