Consumer Protection Policy
The following policy outlines the organization’s consumer protection strategy to ensure that Hubtel’s potential and current consumers have their rights protected in accordance with consumer protection legislation and contractual requirements.
In its everyday business operations, Hubtel makes use of a variety of data about identifiable individuals, including data about:
Current, past, and prospective employees
Users of its websites, applications, etc.
In collecting and using this data, Hubtel is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.
The purpose of this policy is to set out the relevant legislation and to describe the steps Hubtel is taking to ensure that it complies with it.
This control applies to all systems, people and processes that constitute Hubtel’s information systems, including board members, directors, employees, suppliers and other third parties who have access to systems in Hubtel.
Privacy and Personal Data Protection
Hubtel pledges that its consumer’s personal data shall be:
processed lawfully, fairly, and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’).
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to the implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).
Rights of the Consumer
The consumer has:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.
The right to access dispute resolution mechanisms, and where appropriate, obtain redress. These mechanisms should not impose a cost on consumers that is disproportionate to the value of the claim at stake. These mechanisms are designed to be sufficiently accessible and easy to use to enable consumers to elect to conduct the procedure without the need for legal representation or assistance as far as possible.
Data Protection Officer
A defined role of Data Protection Supervisor (DPS) has been appointed to perform large scale monitoring or if it processes particularly sensitive types of data on a large scale.
It is Hubtel’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. Where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant Data Protection Authority (DPA) will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
Consumer Dispute Resolution and Redress
The Board and senior management of Hubtel view complaints as an opportunity to maintain and enhance customer loyalty and enhance our competitiveness by continuous review and improvement.
Our consumer dispute resolution and redress is based on the following principles:
Employees work in good faith and without prejudice to the interest of consumers.
Consumers are always treated efficiently and fairly.
Complaints raised by consumers are dealt with courteously and on time.
Consumers are fully informed of avenues to escalate their complaints/grievances within the organization and their right to an alternative remedy if they are not satisfied with the organization’s response.
The Three-Level Process
The complaint handling and resolution process for our consumers have three levels:
Consumers are to use any channel of the complaint provided by Hubtel. Where the parties are unable to arrive at a consensus, Hubtel shall refer the matter to the industry regulator in writing within five working days of the stalemate.
The industry regulator shall take up all referred unresolved complaints or disputed decisions by Hubtel and act as arbitrators between the parties and give appropriate directives where required.
Where a party is dissatisfied with the decision of the industry regulator, the aggrieved party may seek redress in Court by instituting legal action.
Consumers may present complaints to Hubtel through the following channels:
Verbally, by telephone – 0307008000
In writing – Email: [email protected]
In writing via social media:
Back office chats/in-app chats
Personal data is defined as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing means: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Redress is defined as a conduct remedy that may include a restorative element (e.g. exchange of a good or service, specific performance or rescission of a contract).
Dispute resolution refers to the use of mechanisms designed to provide consumers who have suffered economic harm resulting from transactions involving goods or services, including transactions across borders, the opportunity to resolve their complaints against businesses and to obtain redress. This term is inclusive and encompasses informal and formal mechanisms, online and offline mechanisms, private and public sector mechanisms, and administrative and judicial mechanisms.