Privacy Policy & Data Protection Statement
Effective Date: December 22, 2025 Version: 2.0
1. Introduction and Scope
Coalition Health Zambia (“CHZ,” “we,” “us,” or “our”) is a non-profit organization committed to the highest standards of data privacy and information security. We recognize that in the course of our health systems strengthening and clinical service delivery, we collect and process personal data from employees, consultants, beneficiaries, and website visitors.
This Privacy Policy governs the collection, use, and disclosure of personal data by CHZ. It has been drafted in strict compliance with the Data Protection Act No. 3 of 2021 of the Laws of Zambia and aligns with international best practices required by our global funding partners.
2. Identity of the Data Controller
For the purposes of the Data Protection Act, the Data Controller is: Coalition Health Zambia [Insert Physical Address, e.g., Plot 123, Rhodes Park] Lusaka, Zambia Email: [email protected]
3. Information We Collect
We limit the collection of personal data to what is strictly necessary for our operational and legal obligations.
3.1. Recruitment and Consultant Roster Data When you apply for a vacancy or join our Consultant Roster via our website, we collect:
Identity Data: Full name, nationality, date of birth, and gender.
Contact Data: Email address, physical address, and telephone numbers.
Professional Data: Curriculum Vitae (CV), educational qualifications, employment history, and references.
Compliance Data: Professional registration numbers (e.g., HPCZ, GNC) and tax identification (TPIN), as required for verification.
3.2. Technical Usage Data When you access our digital resources (SOPs, Reports), our servers may automatically log:
IP address and browser type.
Time zone settings and location data (country/city level).
Download history (e.g., which technical briefs were accessed).
4. Lawful Basis for Processing
We process your personal data under the following lawful bases:
Contractual Necessity: Processing is necessary to evaluate your application for employment or to fulfill a consultancy contract.
Legal Obligation: To comply with Zambian labor laws, tax regulations (ZRA), and statutory contributions (NAPSA).
Legitimate Interest: To maintain a roster of qualified experts for rapid deployment in response to public health needs.
Consent: Where you have explicitly opted in to receive technical newsletters or alerts.
5. How We Use Your Data
Your data is used strictly for the following purposes:
Talent Acquisition: To assess your suitability for specific projects, including clinical service delivery contracts in high-burden provinces.
Donor Compliance: To vet key personnel against prohibited party lists (e.g., sanctions lists) as required by international funding agreements.
Operational Deployment: To facilitate logistics, travel, and payroll for hired staff.
Knowledge Management: To monitor the reach and impact of our technical publications.
6. Disclosure and Data Sharing
CHZ maintains strict confidentiality. We do not sell, rent, or trade your personal data. However, we may share your data in the following specific circumstances:
Funding Partners & Consortium Leads: As an implementing partner for various international development programs, we may be required to submit the CVs and qualifications of proposed staff (Key Personnel) to Funding Agencies, Prime Contractors, or Government Ministries for technical approval and compliance verification. Submission of your CV constitutes consent for this specific disclosure to the relevant project funder.
Regulatory Authorities: We may disclose data to the Zambia Revenue Authority (ZRA), National Pension Scheme Authority (NAPSA), or Health Professions Council of Zambia (HPCZ) for verification and statutory compliance.
Service Providers: Third-party IT support or cloud storage providers who act as Data Processors under strict confidentiality agreements.
7. International Data Transfers
Given the global nature of our partnerships, some data may be processed on servers located outside of Zambia (for example, in the databases of international donors or multinational consortium partners). CHZ ensures that any international transfer of data complies with the Zambian Data Protection Act No. 3 of 2021, ensuring adequate safeguards are in place to protect your rights regardless of where the data is processed.
8. Data Retention Policy
We retain personal data only for as long as necessary:
Unsuccessful Applicants: CVs are retained for a period of 12 months in our “Active Roster” for future opportunities, after which they are archived or deleted unless you request otherwise.
Employee/Consultant Records: Retained for 6 years post-employment in compliance with tax and limitation of liability laws.
9. Data Security
We employ robust technical and organizational measures to protect your data, including:
Encryption: Data at rest and in transit is encrypted using industry-standard protocols (SSL/TLS).
Access Control: Access to HR and recruitment databases is restricted to authorized personnel only on a “need-to-know” basis.
Vendor Due Diligence: We vet all third-party software vendors for security compliance.
10. Your Rights
Under the Zambian Data Protection Act, you have the right to:
Request Access: Obtain a copy of the personal data we hold about you.
Rectification: Correct any inaccurate or incomplete data.
Erasure (“Right to be Forgotten”): Request the deletion of your data from our roster.
Objection: Object to the processing of your data for specific purposes.
To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected].
11. Updates to this Policy
CHZ reserves the right to update this policy to reflect changes in our operations or legal obligations. The latest version will always be posted on this page.
PART B: TERMS OF USE
1. Acceptance of Terms By accessing and using the Coalition Health Zambia (CHZ) website, you agree to comply with and be bound by these Terms of Use. If you do not agree, please do not use our website or download our resources.
2. Intellectual Property Rights All content on this website, including technical briefs, Standard Operating Procedures (SOPs), annual reports, logos, and text, is the property of CHZ or its funding partners and is protected by Zambian and international copyright laws.
Permitted Use: You may download, view, and print materials for personal, non-commercial, or educational use, provided you maintain all copyright notices.
Restricted Use: You may not modify, reproduce, or distribute our clinical tools or proprietary data for commercial gain without prior written consent.
3. Medical Disclaimer (Important) The clinical guidelines, SOPs, and health information provided on this website are for informational and educational purposes only and are intended for use by qualified health professionals.
Not Medical Advice: This content does not constitute medical advice, diagnosis, or treatment.
Professional Judgment: Healthcare providers using our tools must exercise their own professional judgment. CHZ assumes no liability for clinical decisions made based on these resources.
4. Limitation of Liability To the fullest extent permitted by Zambian law, CHZ and its consortium partners shall not be liable for any direct, indirect, incidental, or consequential damages resulting from:
Your use or inability to use the website.
Errors or omissions in the technical content.
Unauthorized access to your data.
5. User Conduct When using our “Careers” or “Contact” features, you agree not to:
Submit false or misleading information (including fake academic credentials).
Upload files containing viruses or malicious code.
Attempt to breach the security of our recruitment databases.
6. Governing Law These Terms shall be governed by and construed in accordance with the Laws of Zambia. Any disputes arising under these terms shall be subject to the exclusive jurisdiction of the Zambian courts.
7. Contact Information For questions regarding these Terms or to request permission to use our IP, please contact: [email protected]