First Published: 7 December 2020

1. The Ministry of Health and Child Care

The Ministry of Health and Child Care is a fully-fledged Ministry in the Government of the Republic of Zimbabwe  (hereafter referred to as “MoHCC,” “we,” or “us” or “our”) duly authorized in terms of the Public Health Act [CHAPTER 15:17], to coordinate and conduct all efforts associated with curbing any threats to public health and in these current circumstances, combat Covid-19 in the country. In so doing, the MoHCC has developed and seeks to utilize mobile and web-based applications for use by duly authorized members and employees of the Ministry to collect information related to COVID-19 in the country. In so doing, the MoHCC is aware of its ethical and legal obligations to treat in confidence the information it receives and there is also need to protect the privacy of individuals. We have designed this Mobile App Privacy Policy (the “Policy”) to explain how and when MoHCC collects, uses, and safeguards the information you provide and that we collect through the mobile or web-based applications owned and offered for download by the MoHCC, including, the “Impilo COVID-19 Surveillance App” and any other mobile applications that we may develop and offer in the future (collectively, the “Apps” and individually, an “App”). 

Please carefully review this Policy to understand our policies and practices regarding the collection, use and treatment of your information. By using, accessing, or registering with an App, you consent to our collection, use, and disclosure of information in accordance with this Policy.  You also acknowledge and agree that your access to and use of our Apps is subject to our Terms of Use and any conflict between this Policy and the Terms and Conditions of Use will be determined in favor of the Terms and Conditions of Use. The Privacy Policy is expressly made a part of the Terms and Conditions. You also acknowledge and agree that we are not responsible for how third parties, vendors, and service providers collect or use your information.

2. Scope of this Policy

This Policy applies to information you provide to us or that we collect automatically when you visit, access, use, or register with one or more of our Apps and when you interact with App content or applications that may link to or be accessible from or on the App that are provided or managed by a third party. 

This Policy will tell you:

  • Who collects information

  • What types of information are collected and how this is done

  • How we use and disclose the information that is collected

  • How we secure your information

  • Where you can get answers to your questions about this Policy

3. Who Collects Information

3.1 We are the Ministry of Health and Child Care Zimbabwe. Our national headquarters office is at Kaguvi Building, Central Avenue, Harare, Zimbabwe and the MoHCC shall be the Data Controller.

3.2 The entire system for the app is under the direct control of the MoHCC and is operated technically, on its behalf, by the MoHCC and any other third parties as may be identified by the Ministry.

3.3 Where the MoHCC engages third parties to assist with providing this service, they have signed confidentiality agreements, undertaking contractually to comply with all requirements of section 39 of the Public Health Act [Chapter 15:17], as well as the provisions of the Terms and Conditions of Use and this Privacy Policy. The MoHCC monitors their compliance with these legal requirements.

3.4 All employees of the MoHCC, and any other third parties contracted in the development and maintenance of the App, are bound by confidentiality in the management of data.

3.5 For the purposes of this Privacy Notice our Data Protection Officer is Dr Simukai Tirivanhu Zizhou and you can contact him directly by clicking szizhou@mohcc.org.zw.

4. Types of Information Collected

4.1 Information You Provide Directly. You provide information to us when you use our Apps, including when you download, register with, or log into our Apps. This information may include, but is not limited to, Personally Identifiable Information (‘PII”) including, name, email address, phone number, mailing address, device ID, username and password, registration ID number, and other information that may identify a person. You may also provide, non-personal information such as terms used for searches within Apps, responses to questions, schedules, bookmarks, notes, content viewed, features used, and other information about personal activities within and usage of the Apps. Unless otherwise noted within an App or in this Policy, any information you provide through the App may be transmitted to or stored by MOHCC and/or its third-party providers.

4.2 In utilizing the Apps such as the “Impilo COVID-19 Surveillance App”, you will be able to collect and input the following information (which information has been deemed necessary to directly respond to the public health emergency, and will support COVID-19-related efforts or epidemiological research in the Republic of Zimbabwe) from citizens and persons entering the Republic of Zimbabwe:

  • Personal identifiers such as identity numbers, passport numbers or birth certificate numbers.

  • Demographic information such as dates of birth, gender, education level, nationality and country of birth.

  • Contact details, next of kin and their contact details including residential addresses.

  • Travel history

  • COVID-19 Risk Assessment

  • COVID-19 symptom checklist

  • Any relevant medical history, drug/medicines special needs.

  • COVID-19 Rapid/laboratory tests done and their results.

  • Daily follow data for localised follow up for twenty –one (21) days.

4.3 Information We Collect Automatically.  If you download, access, or use our Apps, we may receive and store certain information about you and your mobile device(s) automatically using automatic data collection technologies, including but not limited to first- and third-party Cookies, log files, Web Beacons, Pixels, dynamic tag management and other technical means. This information may include:

  • Your mobile device ID

  • The type of mobile device and operating system you use to access our Apps.

  • Your IP address/span>

When you visit or use our Apps we may collect or receive information about you as described in this Policy.

5. How We Use Information

5.1 We may use the information we collect or receive about you to:

  • Provide our Apps and their content to you.

  • Complete your requested registrations, transactions or subscriptions.

  • Contact you in connection with requested services or inquiries.

  • Improve the content and functionality of our Apps

  • Track the total number of visitors to our Apps and to each page or feature of our Apps.

5.2 Use of Third-Party Information The information inputted using the Impilo App is specifically for utilization in the MoHCC’s efforts to detect, trace and manage COVID-19 in the Republic of Zimbabwe, as provided for in terms of the Public Health Act [Chapter 15:17]. Accordingly the information will be used for the following

  • To track and trace the COVID-19 virus in the territory of the Republic of Zimbabwe.

  • Registration and screening of persons with or at risk of contracting COVID-19 disease as well as daily follow-ups by MOHCC health care workers.

  • To register incoming travellers at ports of entry into the Republic of Zimbabwe, screen said travellers and perform risk assessment/stratification of travellers in accordance with World Health Organization’s symptom checker tool.

  • To initiate lab tests/rapid rapid test request on a patient as and when appropriate.

The information collected through the use of the App will only be used to detect, trace and manage COVID-19 in the Republic of Zimbabwe and shall not be availed to any third parties for any other reason that is not keeping medical ethics and regulations, detection and combating Covid-19 within the territory of Zimbabwe.

6. How we Secure the Information and Security Measures

6.1 We take the security of personal data very seriously. Our approach to information security is constantly evolving and continually reviewed. We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.

6.2 To protect data against unauthorised access, loss, or misuse the app makes use of a variety of sophisticated technical security measures (including, for instance, encryption; pseudonymisation, logging, access controls and restrictions). The MOHCC and its partners also employ organisational strategies (including, for example, staff directives, confidentiality agreements, reasonably regular inspections) to ensure that all legal requirements have been, and are being, complied with.

6.3 We will never share your user information with third parties for promotional purposes. We remain responsible at all times for the security of your information.

6.4 To protect data against unauthorized access, loss, or misuse, the MoHCC, in collaboration with Ministry of ICT, Postal and Courier Services, will utilise internal and cloud based data storage facilities.

6.5 However, despite all the security measures adopted, our IT systems could be compromised by parties seeking unauthorized access to our data or users’ data, by a technological malfunction or by an error by an employee, vendor or contractor. In addition, third parties could intercept the transmission of information via the Internet or mobile data networks. As a result, our efforts to protect our data and users’ data from unauthorized access may be unsuccessful and we cannot assure you that the security measures we have adopted will provide absolute certainty. By using, accessing or registering with the Apps, you agree that MOHCC is not responsible or liable for any loss or damage of any sort arising from or relating to any breach of our security, circumvention of any privacy settings or security measures, or interception of your transmissions. 

6.6 The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Apps or certain functions within our Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

7. How long we hold information for

The data and personal information collected through the utilisation of the App are considered medical/health records and the manner they are handled is in accordance with the Public Health Act and related regulations.

8.Cookies

While we do not intend to use Cookies or expose users to said Cookies, we reserve the right to utilize them.

9. Changes to This Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Should you register as a user through the App, you will be notified the next time you log in to make use of our services. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.

10. Other documents governing privacy and data protection

This Privacy Policy is not necessarily exhaustive. Specific matters may be governed by other data protection statements, similar documents, or terms and conditions of use. Where that is so, a link to any such documents will be made available to the user in the app.

11. Contact Us

If you have any concerns about the way we use personal information or any questions about this Privacy Notice, please let us know. We can be contacted via email at helpdesk@mohcc.org.zw, or you can write to us at the address above.