Specifically, the Cyber and Data Protection (Licensing of Data Controllers and Appointment of Data Protection Officers) Regulations, 2024, sets out the rules for who must be licensed. The law defines a data controller broadly as anyone who determines the purpose and means of processing personal data.
A WhatsApp group administrator is considered a data controller if they collect and process personal information (such as phone numbers) for commercial or business purposes, including running a church or community organization. The law makes a distinction between these groups and those used strictly for personal, family, or household affairs, which are generally exempt from the licensing requirement.
Many Zimbabwean organisations have not been licenced as Data Controllers.
While the Cyber and Data Protection Act itself states that “a person” who processes data without a license is liable for a fine or imprisonment, this “person” can refer to both a legal entity (the company) and specific individuals within that entity.
Based on the legal framework in Zimbabwe, criminal liability for a company’s non-compliance can extend to the individuals responsible for the company’s operations and compliance. Therefore, if a company is not licensed and continues to operate as a data controller, the following individuals can potentially be held criminally liable and face imprisonment:
- Directors and senior management: These individuals have a fiduciary duty to ensure the company complies with all laws. Their failure to ensure the company is licensed can be considered a breach of this duty, making them personally liable.
- The Data Protection Officer (DPO): If a DPO was appointed but failed to ensure the company met its licensing obligations, they could also be held responsible.
- Any individual who actively manages or oversees the data processing activities without a license, even if they are not a director, could potentially be prosecuted.
Recently, Zimbabwe has taken a significant step towards protecting the personal information of its citizens by publishing a list of licensed Data Controllers. But what exactly does it mean for an organization to be a licensed Data Controller, and why should you care?
In simple terms, a licensed Data Controller is a company or entity that has been officially approved by the government to handle people’s personal information. This licensing is a crucial part of Zimbabwe’s Cyber and Data Protection Act, which sets out rules for how personal data must be treated.
Why Does This Licensing Matter?
For the Public: Enhanced Data Protection and Trust
For you, the public, this licensing system is a promise that organizations handling your data are doing so responsibly and legally. The government requires these licensed entities to follow strict guidelines to ensure your information is:
- Collected fairly and lawfully
- Kept secure from unauthorized access
- Used only for the purposes stated
When you see an organization on the list of licensed Data Controllers, it provides a level of trust. It signifies that the company is committed to protecting your privacy and is accountable to the regulatory authorities.
For Businesses: Legal Compliance and Reputation
For businesses in Zimbabwe, obtaining a Data Controller license is not just about compliance; it’s about demonstrating trustworthiness and building a strong reputation. By getting licensed, companies:
- Operate within the bounds of the law, avoiding hefty penalties.
- Show their commitment to data protection, which can boost customer confidence.
- Become part of a transparent system overseen by the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ).
Being licensed signifies that a business takes data protection seriously and is a responsible custodian of personal information.
What Are the Penalties for Non-Compliance?
The Cyber and Data Protection Act in Zimbabwe takes the issue of unlicensed data processing very seriously. Any organization that handles personal information without the necessary license faces significant penalties, including:
- Substantial fines (not exceeding a Level 11 fine).
- Imprisonment for a period of up to seven years.
- Both a fine and imprisonment.
These penalties underscore the importance of adhering to the data protection regulations and obtaining the required license.
The Full List of Licensed Data Controllers
- 10 10 TECHNOLOGIES
- A L ROGERSON LAW CHAMBERS
- A J HAMEY OPTOMETRISTS PVT LTD
- ABC ASSET MANAGEMENT PVT LTD
- ABC EASY LOANS PVT LTD T/A BANCASY
- ABC STOCKBROKERS PVT LTD
- ABCOM AND SHIPBINDING PVT LTD
- ACTION CONTRE LA FAIM (ACTION AGAINST HUNGER)
- ADMT SOLUTIONS PVT LTD
- AFDIS DISTILLERS ZIMBABWE
- A&C RADIOLOGY GROUP
- AFB HOLDINGS LTD
- APC COMMERCIAL BANK
- APE HOLDING
- APE INSURANCE COMPANY
- APIC LAND AND DEVELOPMENT BANK
- APE LEASING COMPANY
- APIC CORPORATE RESCUE
- APOSTOLIC FAITH MISSION
- AFRICA UNIVERSITY
- AFRICAN CENTURY LIMITED
- AFRICAN DISTILLERS LIMITED
- AFRICAN SUN LIMITED
- AGRIBANK PROPERTIES PVT LTD
- AGRISOFT HOLDINGS
- AGROFON EQUIPMENT PVT LTD
- AGRITRADE SOLUTIONS T/A
- AIRPORTS COMPANY OF ZIMBABWE
- ALBERT BOWERS MEDICAL PRACTICE
- ALDO HEALTH
- ALLIANCE INSURANCE COMPANY
- ALLIED HEALTH PRACTITIONERS COUNCIL OF ZIMBABWE
- ALPHA ALLOY ZIMBABWE PVT LTD
- ALPHA ASSET MANAGEMENT
- AMNESTY INTERNATIONAL
- ANDALUSIA INVESTMENTS PVT LTD T/A
- ARABAKHOYA INVESTMENTS
- ARAIYA HEALTH PVT LTD T/A ARAIYA PHYSIOTHERAPY
- ARDBENNIE SERVICE HOME OWNERS ASSOCIATION
- ARUNDEL SCHOOL
- ASSEFAH ANALYTICS PVT LTD
- ASSOCIATED MEAT PACKERS PVT LTD
- ASSOCIATED NEWSPAPERS OF ZIMBABWE
- ASSOCIATION OF HEALTHCARE FUNDERS OF ZIMBABWE
- ASSOCIATION OF TRUST SCHOOLS
- ASTRA INDUSTRIES
- ATLAS GROUP PVT LTD
- AURA GROUP PVT LTD
- AUREX PVT LTD
- AUTOMOBILE ASSOCIATION OF ZIMBABWE
- AUTOTROPIC INVESTMENTS PVT LTD
- AXCENTIUM
- BAKERS INSTITUTION PVT LTD
- BAKER TILLY ADVISORY
- BAKER TILLY CHARTERED ACCOUNTANTS
- BAKER TILLY DIGITAL
- BANK ABC
- BANQUER ZIMBABWE LTD
- BARRIER TIME SYSTEMS PVT LTD
- BETHEL CLINIC
- BETHEL CHURCH
- BHEBHE SERVICES PVT LTD
- BINGA HOLDINGS PVT LTD
- BINOCURA UNIVERSITY OF SCIENCE EDUCATION
- BIOMEDICAL RESEARCH AND TRAINING INSTITUTE
- BIOMIMAS PVT LTD
- BLACKROOK PROTECTION SERVICES
- BLANKET MINE(1983) PVT LTD
- BLANKET MINE EMPLOYEE TRUST (PRIVATE) PVT LTD
- BOC GASES ZIMBABWE PVT LTD
- BODYSURE PVT LTD
- BORROWDALE BROOKE HOMEOWNERS ASSOCIATION
- BROWNE CONSULTANCY
- CALATH HEALTH MEDICAL AID SOCIETY
- CALEDONIA HOLDINGS ZIMBABWE
- CALM HEALTH INTERNATIONAL
- CALVARY HOSPITAL AND DIALYSIS CENTRE
- CANALMETALLOBOX
- CAPARINCE INVESTMENTS T/A
- CAPARINCE INVESTMENTS T/A ZIMBABWE BRIDGE
- CATHOLIC BELIEF SERVICES PVT LTD
- CBZ HOLDINGS
- CELL INSURANCE COMPANY (PRIVATE) LIMITED
- CENTRAL HEALTH FUND
- CENTRAL AFRICAN BUILDING SOCIETY
- CENTRE FOR SEXUAL HEALTH AND HIV/AIDS RESEARCH ZIMBABWE (CESHHAR ZIMBABWE)
- CENTRIC DATA (PVT) LTD
- CFI HOLDINGS LTD
- CHAMPIONS INSURANCE
- CHAMPIONS CHARTERED ACCOUNTANTS
- CHARLES STEWART DAY OLD CHICKS PVT LTD
- CHASE MAGUDUZA LEGAL PRACTICE
- CHEETAH EXPRESS
- CHIKUUNE ZIMBABWE
- CHINHOYI IMAGING CENTRE
- CHINHOYI UNIVERSITY OF TECHNOLOGY
- CHIPS ENTERPRISE SOLUTIONS
- CHIRUMHANZU RURAL DISTRICT COUNCIL
- CHITETEVE LAW PRACTICE
- CHROMESOFT PVT LTD
- CICADA GROUP
- CIMAS HEALTH GROUP
- CIMAS MEDICAL AID SOCIETY
- CITY OF BULAWAYO
- CITY OF GADONA
- CITY OF MUTARE
- CITY OF VICTORIA FALLS
- CITY PARKING
- CITYMED PHARMACY (ARISBYN PHARMACY) PVT LTD
- CIVIL AVIATION AUTHORITY OF ZIMBABWE
- CIVILSERV PVT LTD
- CLOCKCAN GALAXYTA
- CLICKCASH
- CLICKPAY INVESTMENTS
- COCKRAIN, WELSH AND GUEST
- COMMISSION OF THE MINED INDUSTRIES PENSION FUND
- COMMISSION ON TARIFF COMPUTATION
- COMPUTER SOCIETY OF ZIMBABWE
- CONSTRUCTION INDUSTRY PENSION FUND
- CONUSMER FEEDBACK CONSULTANCY
- CONTROL COMPUTER SYSTEMS (PVT) LTD
- CONTROLPAX T/A TANTANA SMARTPAY
- COUNTRY CLUB TWENTY TEN PVT LTD
- CREDBRIDGE FINANCE
- CREOLENE INSURANCE
- CREST BREEDERS INTERNATIONAL PVT LTD
- CRISTA HOLDINGS
- CROWN MINES
- CROSS COUNTRY CONTAINERS PVT LTD
- CUAZ
- DAREDBOUL HOLDINGS LIMITED
- DAREDBOUL ZIMBABWE PVT LTD
- DALLASAD INVESTMENTS
- DATASHEET PVT LTD
- DAPP ZIMBABWE
- DATUMAFR PVT LTD
- DAVE GRANT PVT LTD
- DELORTA BEVERAGES (PVT) LTD
- DEMBE PVT LTD
- DEPOSIT PROTECTION CORPORATION
- DEUTSCHE GESELLSCHAFT FUR INTERNATIONAL ZUSAMMENARBEIT (GIZ) GMBH
- DFI ZIMBABWE
- DHL INTERNATIONAL ZIMBABWE
- DHAKAWA’S ATTORNEYS
- DIAGNOSTIC LABORATORY SERVICES
- DIAMOND MEDICAL LABORATORIES
- DICKS PHARMACY T/A
- DISASTROUS ENTERPRISES
- DISTRIBUTED POWER AFRICA
- DMB HOLDINGS
- DOMINICAN CONVENT SCHOOL
- DR A VIN
- DR BRIDGET SIBANDA
- DR DOUGLAIN
- DR G FANGA
- DR JM OKWEE
- DR KADOMWANGA
- DR KEVIN NDHLOVU
- DR LINDIZA M SIBANDA
- DR LOVELOY PADZIMOYO
- DR MUPUNURI
- DR MUTETWA
- DR MWARINGA
- DR MUNENGWENGA PVT LTD
- DR NKOMO
- DR P J MARAMBA SURGERY
- DR P M MUDZINGWA
- DR R MUREWA
- DR R CHIKARAE MUDZANANYIKA
- DR R MWAHINAZA T/A NDIVA FAMILY CLINIC
- DR SANDE T/A CRYSTAL HEALTH
- DR T M CHAMISA
- DR TAHINGA
- DR TINETS Y WILSON MANASE
- DR WADZONAI MUKURAKATI
- DR WILSON MUPARAKWA T/A
- DR ZIM
- DR ZIMBABWE
- DULUX ZIMBABWE PVT LTD
- DZIMBA, JARAVAZA AND ASSOCIATES
- EAGLE ASSET MANAGEMENT
- EDINBURGH ZIMBABWE
- ECONET LIFE
- ECHO NET WIRELESS (PRIVATE) LIMITED
- EDISON FINANCE ZIMBABWE
- EIFFEL FLATS SATELLITE CLINIC T/A DR OLYN KUSANGANYA
- EMERALD HILL MEDICAL AID SOCIETY
- EMERGENCY ROOMS TWENTY FOUR (PRIVATE) LIMITED
- EMERITUS REINSURANCE (PRIVATE) LIMITED
- EMPOWERMENT BANK
- ENVIROMINT MANAGEMENT PVT LTD
- ERA INVESTMENTS
- ESSECT INVESTMENTS
- ERNST & YOUNG ADVISORY SERVICES PVT LTD
- ERNST & YOUNG CHARTERED ACCOUNTANTS ZIMBABWE
- ETHICAL SYSTEMS PVT LTD
- EUREKA INSURANCE BROKERS
- EVERLASTING RESOURCES PVT LTD
- EXPERT DECISION SYSTEMS ZIMBABWE
- EXPORT CREDIT GUARANTEE CORPORATION
- EXTRAMED PHARMACY T/A
- BALLANTYNE PARK PHARMACY
- EYE SIGHT PLACE PVT LTD
- EZYTRACK PVT LTD
- FBC HOLDINGS LIMITED
- FIDELITY FUNERAL SERVICES PVT LTD
- FIDELITY GOLD REFINERY PVT LTD
- FIDELITY LIFE ASSURANCE
- FIDELITY LIFE FINANCIAL SERVICES
- FIDELITY LIFE MEDICAL AID SOCIETY
- FIRSTRANS PVT T/A VERITAS ZIMBABWE
- FIRST CAPITAL BANK LIMITED
- FIRST MUTUAL HEALTH COMPANY
- FIRST MUTUAL HEALTH SERVICES
- FIRST MUTUAL LIFE ASSURANCE
- FIRST MUTUAL MICROFINANCE
- FIRST MUTUAL PROPERTIES
- FIRST MUTUAL WEALTH MANAGEMENT
- FIRST MUTUAL WEALTH
- FREEPORT MINING ZIMBABWE PVT LTD
- FREDA REBECCA GOLD MINE
- FREDERICK PESTING PVT LTD
- FRIENDS OF THE ENVIRONMENT TRUST
- FUSHARUS ENTERPRISES (PVT) LTD T/A FOOD LOVERS MARKET
- FOLI FINANCIAL COMPANY OF ZIMBABWE PVT LTD
- GAIN CASH AND CARRY PVT LTD
- GENERATION HEALTH MEDICAL FUND
- GIANT CASHMACHINES T/A G MANHAMBE LEGAL PRACTIONERS
- GILL DODDINGTON & GERANS LEGAL PRACTIONERS
- GLASSWARE PVT LTD
- GODOLPHAST PROPERTIES PVT LTD
- GOLDEN VALLEY MINE
- GOODHOPE DENTAL SURGERY
- GRAND INSURANCE COMPANY PVT LTD
- GRANT THORNTON
- GREAT ZIMBABWE UNIVERSITY
- GREEN GOLDEN LEAF TOBACCO
- GREENSTONE RESORTS T/A SUITARE DRY PORT
- GREENWOOD WHOLESALERS
- GULMAM ZIMBABWE
- GUMANI RURAL MEDICAL VILLAGE (PVT) LTD
- GUNE LEGAL PRACTICE
- GWANDA STATE UNIVERSITY
- H AND N INVESTMENT
- H MOHLOTSHEYI T/A MONKS TRADING
- HALMICK INVESTMENTS
- HALLMARK CONFECTIONERS
- HARARE INSTITUTE OF TECHNOLOGY
- HAVANNA TECHNOLOGY CENTRE
- HEALTH BENEFITS
- HEALTHCARE PHARMACY
- HEALTHCARE INVESTMENTS
- HIGHTECH
- HONEST PVT LTD
- HORATIO PVT LTD
- HOSPITALITY AND ALLIED
- HOWE PVT LTD
- HUEY PVT LTD
- HUNDREDS ENTERPRISES PVT LTD
- HUNGER AND THIRST PRIVATE LTD
- HUNI BROTHERS AND ASSOCIATES
- HUNI ENTERPRISES PVT LTD
- HUNTER CONSULTING
- HUNYANI HOLDINGS
- ILALA PVT LTD
- IMPALA CAR RENTAL PVT LTD
- IMPALA LEASING PVT LTD
- IMPALA MOTOR SERVICES PVT LTD
- IMPALA TOYOTA PVT LTD
- INGENUITY PHARMACEUTICALS PVT LTD
- INGENUITY PVT LTD
- INNSCOR AFRICA T/A COLCOM FOODS
- INTELAB PVT LTD
- INTERNATIONAL COAL TECHNOLOGY PVT LTD
- INTERNATIONAL FINANCIAL REPORTING STANDARDS
- INTERNATIONAL GOLD TRADING PVT LTD
- INTERNATIONAL MEDICAL PRACTICE
- INTERNATIONAL ORGANISED CRIME UNIT
- INTERNATIONAL SCHOOL OF ZIMBABWE
- INTERNATIONAL SERVICES PVT LTD T/A
- INTERNATIONAL TRADE FAIR COMPANY
- INTERNATIONALLY RECOGNISED QUALIFICATIONS
- JENA MINES
- JESSE MAJOME AND COMPANY
- JESSE MUJOME AND COMPANY
- JESSICA MANAGEMENT PVT LTD
- JESTURE SYSTEMS
- JESURE LIMITED
- JIVE ZIMBABWE PVT LTD
- JOKO PVT LTD
- JOSAM ENTERPRISES
- JUDITH CHIKWA LEGAL PRACTICE
- JUMP FOR JUNGLE PVT LTD
- JUNIOR ADVENTIST HIGH SCHOOL
- K AND P SERVICES PVT LTD
- KADOMA INVESTMENTS T/A CHAKWANDA MINING
- KARO PLATINUM PVT LTD
- KEFALOS HEALTH PVT LTD
- KENAC COMPUTER SYSTEMS
- KENAC SECURITIES PVT LTD
- KENAC SOFTWARE PVT LTD
- KENCOR MANAGEMENT
- KINGSLEY LEGAL PRACTICE
Staying Informed
The publication of the list of licensed Data Controllers is a positive step towards a more secure and transparent digital environment in Zimbabwe. It’s recommended that individuals and businesses alike stay informed about these regulations and ensure compliance where necessary.
