1 Regulatory Framework & Scope
This Privacy Policy explains how AVS Digital Solutions Private Limited (“AVS”, “we”, “our”) collects, uses, encrypts, and discloses personal data processed within the AVS Human Capital Enterprise ERP platform.
Our policies and safeguards are governed by and constructed pursuant to the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe and relevant guidelines issued by the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) acting as the Data Protection Authority.
2 Controller vs. Processor Distinction
Under Zimbabwean data protection principles:
- The Subscribing Employer (Customer) is the Data Controller: Your employer or organization determines the purposes, categories, and retention criteria of employee workforce data uploaded to the ERP.
- AVS is the Data Processor: AVS provides the software infrastructure, encryption mechanisms, statutory calculation algorithms, and technical hosting solely on the documented instructions of the Customer.
3 Categories of Personal Data Processed
In order to administer employment contracts and compute dual-currency payroll, the platform stores and processes:
- Employee Identity Information: Full legal names, National Registration Number (Zimbabwe National ID), passport numbers, date of birth, gender, nationality, and marital status.
- Contact Information: Residential address, corporate email, personal email, and WhatsApp / cellular telephone numbers.
- Financial & Banking Data: Commercial bank name, branch code, bank account numbers, currency preferences (USD and ZiG), basic salary, and allowances.
- Statutory Tax Identifiers: ZIMRA Business Partner (BP) numbers, Taxpayer Identification Numbers (TIN), NSSA Social Security Numbers, and designated pension scheme numbers.
- Time, Attendance & Shift Logs: Biometric clocking timestamps, shift schedules, leave application histories, overtime records, and public holiday adjustments.
- Recruitment & Talent Records: Curricula Vitae (CVs), academic certificates, job interview notes, and periodic appraisal scores.
- Beneficiaries & Emergency Contacts: Full names, phone numbers, and designated relationship of next of kin.
4 Lawful Bases of Processing
All processing of personal workforce data is carried out strictly under lawful bases established by law:
- Contractual Performance: Necessary for the administration of the employment agreement, payslip generation, and timely salary disbursement.
- Legal & Statutory Obligation: Necessary to comply with the Labour Act [Chapter 28:01], statutory tax withholding under the Finance Act & ZIMRA PAYE, and social security remittances under the NSSA Act [Chapter 17:04].
- Legitimate Interests: Workforce planning, performance appraisals, internal audit governance, and asset protection.
5 Cryptographic Safeguards & Schema Isolation
AVS enforces multi-layered technical safeguards to safeguard workforce records against unauthorized disclosure:
- PostgreSQL Schema Data Isolation: Every enterprise tenant operates in an independent database schema. Database sessions dynamically restrict their search paths, preventing accidental cross-tenant data access.
- Field-Level Encryption at Rest: High-risk fields (such as National Registration IDs and bank accounts) are encrypted with symmetric AES-256 cipher keys prior to database commitment.
- Bcrypt Password Hashing: User passwords are encrypted with salted, high-work-factor bcrypt hashing algorithms. Passwords cannot be decrypted or retrieved by system administrators.
- Granular Role-Based Access Control (RBAC): Administrative rights are segmented across discrete roles (Platform Admin, HR Officer, Payroll Officer, Manager, and Employee) with custom permission overrides.
- Audit Logging: System activities, employee record modifications, and payroll approvals generate tamper-evident audit log entries recording actor, IP address, timestamp, and action description.
6 Document Storage & Cloudflare R2
Digital employment files (such as national ID scans, certified qualifications, and employment contracts) are stored using secure S3-compatible object storage (Cloudflare R2):
- Files are encrypted in transit via TLS 1.3 and encrypted at rest.
- Bucket permissions are strictly private. Direct public URL access is prohibited.
- Authorized personnel view documents exclusively through cryptographically signed, pre-signed URLs that automatically expire after 15 minutes (900 seconds).
7 Third-Party Sub-Processors
AVS partners with selected infrastructure providers under stringent data processing agreements:
- WhatsApp Enterprise Gateway (Whapi.cloud): Utilized solely for dispatching requested employee self-service notifications, OTP verifications, and digital payslips. Mobile numbers and notification payloads are transmitted securely and not shared with advertising networks.
- Accounting Integrations (Ledger Harmony): Transmits synchronized financial journals and aggregated payroll expense lines without exposing personal individual health or disciplinary details.
- Commercial Banking Batch Files: Generates formatted text/CSV files for direct employer import into commercial bank corporate portals for batch payroll settlement.
8 Data Retention & Archival Standards
Workforce records are retained in compliance with statutory requirements:
- Statutory Tax Records: Payroll calculations, P2 monthly summary returns, and annual ITF16 returns are preserved for a minimum of six (6) years in accordance with ZIMRA statutory audit mandates.
- Active Employment Files: Maintained for the duration of the employment contract and preserved for legal dispute prescription periods following termination under the Labour Act.
- Tenant Deprovisioning: When a client company terminates its subscription, tenant database schemas and associated document buckets are permanently sanitized following the designated export grace window.
9 Employee & Data Subject Rights
Employees and users residing in Zimbabwe enjoy statutory rights under the Cyber and Data Protection Act:
- Right of Access: Staff can inspect personal records, leave balances, and historical payslips 24/7 via the Employee Self-Service (ESS) web portal and WhatsApp bot.
- Right to Rectification: Employees may request correction of inaccurate bank account numbers, residential addresses, or misspelled names via their company HR officer.
- Right to Restrict or Object: Individuals may raise inquiries regarding unauthorized data processing.
- Right to Lodge a Complaint: Data subjects have the right to lodge formal regulatory complaints with POTRAZ (Data Protection Authority) in Harare.
10 Cookies & Session Integrity
The platform employs strictly essential cookies for session state and CSRF authentication security:
- Session Cookies: Encrypted, HttpOnly, SameSite cookies used solely to maintain authenticated sessions and tenant isolation.
- No Behavioral Tracking: We do not deploy third-party advertising tracking pixels, cross-site trackers, or commercial profiling cookies.
11 Data Protection Officer (DPO) Contact
For inquiries, privacy requests, or data protection audits, contact our designated Data Protection Officer: