Sending or making personal information accessible outside Zimbabwe requires a documented legal and security assessment. Cloud hosting, remote support and multinational platforms can all create transfer questions.
What to know
- ✓The Act ordinarily requires an adequate level of protection for overseas transfers and lists limited alternative circumstances.
- ✓The regulations require notice to the Authority of an intention to transfer or share information outside Zimbabwe.
- ✓Record the destination, recipient, purpose, categories, safeguards, retention and incident arrangements.
- ✓Where adequacy or an exception is uncertain, obtain regulator or professional confirmation before transfer.
Find the hidden transfers
Review hosting regions, backups, support access, collaboration tools, analytics, HR and finance platforms, outsourced processing and onward subcontractors. A transfer can arise through access, not only by physically sending a file.
Assess protection and necessity
Document why the transfer is needed, what laws and enforcement apply at the destination, individual rights and remedies, recipient security, breach response, government-access risk and onward transfers. Minimise the information and access involved.
Choose and document safeguards
The implementation guide discusses mechanisms such as contractual clauses, binding corporate rules, explicit consent, codes and certification. The relationship between adequacy, alternative safeguards and authorisation requires careful application in the specific case; do not treat a contract as an automatic permission.
Operational controls
Maintain a transfer register, contracts, due-diligence evidence, data-flow map, impact assessment, Authority correspondence and a cross-border incident plan. Reassess when suppliers, locations, purposes, categories or law change.
Read the underlying material
- Cyber and Data Protection Act: sections 28–29
- S.I. 155 of 2024: section 10(2)(c)
- Implementation Guidelines: cross-border transfer guidance