PVT Results Data & Privacy Policy

1. Introduction

This Data & Privacy Policy explains how PVT Results collects, uses, stores, protects, validates, and retains data submitted through the platform.

This policy applies to:

1. tenant organisations;
2. tenant administrators;
3. election agents;
4. verifiers;
5. readers;
6. account users;
7. other authorised users of the platform.

Zambia’s Data Protection Act No. 3 of 2021 and related regulations are relevant to personal data processing in Zambia; current legal summaries describe obligations around registration, data protection officers, lawful and transparent processing, data minimisation, security safeguards, and breach notification. ([DLA Piper Data Protection][4])

2. Types of Data We Process

The platform may process the following categories of data.

2.1 Tenant Data

Tenant Data means data submitted, uploaded, generated, reviewed, or stored by an organisation in its workspace, including:

1. polling station results;
2. candidate totals;
3. rejected ballot figures;
4. spoiled ballot figures;
5. turnout figures;
6. polling station, stream, ward, constituency, district, and province references;
7. evidence sheets, forms, photographs, or scans;
8. verifier comments;
9. discrepancy notes;
10. internal approval status;
11. reports, exports, dashboards, and aggregates.

2.2 User Account Data

This may include:

1. name;
2. email address;
3. phone number, where provided;
4. organisation;
5. role;
6. login credentials or authentication identifiers;
7. invitation status;
8. access permissions.

2.3 Audit and Security Data

This may include:

1. login history;
2. IP address;
3. device and browser information;
4. timestamps;
5. submission history;
6. edit history;
7. evidence upload history;
8. verifier actions;
9. access logs;
10. discrepancy flags;
11. system alerts.

2.4 Support and Communication Data

This may include messages, support requests, billing communications, onboarding information, and administrative correspondence.

3. Tenant Ownership of Data

Each tenant owns its Tenant Data.

PVT Results does not claim ownership over polling station results, uploaded evidence, internal verification notes, or tenant-specific reports submitted by or generated for a tenant.

By using the platform, each tenant grants the platform operator a limited licence to host, store, process, validate, analyse, secure, display, back up, and transmit Tenant Data solely for the purposes described in this policy, the Terms of Use, and any applicable service agreement.

4. No Sale of Data

PVT Results will not sell Tenant Data, User Account Data, uploaded evidence, audit logs, or personal data to third parties.

We will not sell data to advertisers, political parties, campaigns, consultants, media organisations, data brokers, or commercial third parties.

5. How We Use Data

We use data to:

1. provide and operate the platform;
2. create and manage tenant workspaces;
3. assign users to polling districts, stations, streams, contests, and roles;
4. enable polling station result capture;
5. require and store evidence-backed submissions;
6. perform arithmetic validation;
7. support verifier review;
8. generate dashboards, reports, and exports;
9. maintain audit trails;
10. detect discrepancies and suspicious submission patterns;
11. compare submissions across the platform for consistency;
12. secure the platform;
13. provide support;
14. comply with legal, contractual, audit, and regulatory obligations;
15. investigate misuse, manipulation, fraud, or breach of the Terms of Use.

6. Cross-Tenant Pooled Validation

PVT Results may use submitted election result data in a pooled validation process to improve data consistency and detect possible discrepancies.

This means the platform may compare data submitted by different tenants for the same polling station, stream, contest, ward, constituency, district, province, or election event.

The purpose of pooled validation is to:

1. identify inconsistent figures;
2. detect possible data-entry errors;
3. flag potential source manipulation;
4. detect broader divergence from other platform submissions;
5. improve confidence in the accuracy of submitted data;
6. alert tenants where their submissions materially differ from comparable submissions.

Pooled validation does not mean that one tenant can see another tenant’s private workspace, evidence, users, internal comments, or organisation-specific reports.

Unless expressly authorised or legally required, the platform will not disclose one tenant’s identifiable submissions, evidence, or internal verification records to another tenant.

The platform may generate alerts such as:

1. “Your submitted result differs from other submissions for this polling station.”
2. “Evidence review recommended.”
3. “Arithmetic mismatch detected.”
4. “Broader divergence detected across comparable submissions.”
5. “Potential source or transcription issue.”

A validation flag is not a final finding of fraud, manipulation, or wrongdoing. It is a risk indicator requiring review.

7. Data Isolation Between Tenants

PVT Results is designed to keep tenant workspaces logically separated.

Users may only access data within the workspace, role, and permissions assigned to them.

Tenant administrators are responsible for assigning access appropriately.

The platform operator may access tenant data only where necessary for:

1. platform operation;
2. technical support;
3. security monitoring;
4. discrepancy investigation;
5. compliance;
6. legal obligations;
7. enforcement of the Terms of Use;
8. service improvement consistent with this policy.

8. Data Retention

Unless a different period is agreed in writing, PVT Results will retain Tenant Data, evidence, audit logs, validation records, and related election records for 10 years from the date of submission or the relevant election event.

The 10-year retention period supports:

1. auditability;
2. dispute review;
3. historical analysis;
4. investigation of discrepancies;
5. legal and compliance needs;
6. institutional memory for tenants;
7. platform integrity and accountability.

After the retention period expires, data may be deleted, anonymised, aggregated, or archived according to platform procedures, applicable law, and any enterprise agreement.

Some records may be retained longer where required for legal claims, investigations, court orders, regulatory obligations, security incidents, unpaid accounts, or unresolved disputes.

9. Personal Data Minimisation

Users and tenants should avoid uploading unnecessary personal data.

Unless expressly required, users should not upload:

1. National Registration Card numbers;
2. voter personal details;
3. private home addresses;
4. unnecessary phone numbers;
5. biometric data;
6. sensitive personal information unrelated to election monitoring;
7. private communications not required for verification.

Where evidence documents contain unnecessary personal data, tenants should consider lawful redaction before upload, provided the redaction does not obscure or alter the election result record needed for verification.

10. Sensitive Data

Election-related data may, in some contexts, reveal political affiliation, political opinions, campaign roles, observer roles, or organisational affiliation.

Users and tenants must treat such data carefully and lawfully.

The platform operator will apply reasonable technical and organisational measures to protect such data, but tenants remain responsible for ensuring they have lawful authority to collect and upload data relating to their agents, verifiers, observers, candidates, or representatives.

11. Legal Bases and Consent

Where consent is required, tenants are responsible for obtaining appropriate consent from their users, agents, employees, volunteers, representatives, or other data subjects before submitting their personal data to the platform.

The platform may also process data where necessary for:

1. performance of a contract;
2. legitimate platform operation;
3. tenant-requested services;
4. legal compliance;
5. security and fraud prevention;
6. public-interest election monitoring activities, where applicable and lawful;
7. establishment, exercise, or defence of legal claims.

12. User Rights

Subject to applicable law, users may have rights to:

1. access personal data held about them;
2. request correction of inaccurate personal data;
3. request deletion where legally applicable;
4. object to certain processing;
5. restrict processing in certain circumstances;
6. request portability of certain data;
7. withdraw consent where processing is based on consent;
8. complain to the relevant data protection authority.

Requests should be sent to: contact form

The platform may need to verify identity before responding.

Some requests may need to be handled through the relevant tenant administrator where the tenant controls the workspace and user relationship.

13. Security Measures

PVT Results will use reasonable technical and organisational safeguards to protect data, which may include:

1. role-based access control;
2. authentication controls;
3. audit logs;
4. encryption in transit;
5. encryption at rest where supported;
6. access monitoring;
7. backups;
8. administrative access controls;
9. secure development practices;
10. incident response procedures;
11. periodic review of security controls.

No platform can guarantee absolute security. Users and tenants must protect their credentials and promptly report suspected compromise.

14. Breach Notification

If the platform operator becomes aware of a security incident affecting personal data, it will investigate and take appropriate remedial steps.

Where legally required, the platform operator will notify affected tenants, users, and/or the relevant authority within applicable legal timelines.

Tenants must promptly notify the platform operator if they suspect unauthorised access, credential compromise, data leakage, evidence manipulation, or misuse of the platform.

15. Service Providers

The platform operator may use trusted service providers to host, secure, operate, maintain, analyse, or support the platform.

Service providers may only process data as authorised by the platform operator and must be subject to appropriate confidentiality, security, and data protection obligations.

16. International Storage and Transfers

Where data is stored, processed, backed up, or accessed outside Zambia, the platform operator will take reasonable steps to ensure that such transfer or processing is lawful and protected by appropriate safeguards.

Tenants with specific data-residency requirements should enter into a written agreement with the platform operator.

17. Aggregated and Anonymised Data

The platform operator may use aggregated, anonymised, or de-identified data to:

1. improve platform performance;
2. improve validation rules;
3. understand system usage;
4. improve election workflow design;
5. produce non-identifying statistical insights;
6. strengthen discrepancy detection.

Such data will not reasonably identify a tenant, user, agent, or individual unless permitted by the tenant, required by law, or necessary for enforcement or security purposes.

18. Disclosure of Data

PVT Results may disclose data only where:

1. authorised by the tenant;
2. necessary to provide the platform;
3. required by law, court order, or lawful authority;
4. necessary to investigate misuse, fraud, manipulation, or security incidents;
5. necessary to enforce the Terms of Use;
6. necessary to protect the rights, safety, or integrity of the platform, tenants, users, or the public;
7. part of a merger, acquisition, restructuring, or transfer of the platform, subject to appropriate safeguards.

We will not disclose one tenant’s private workspace data to another tenant merely because their submissions relate to the same polling station.

19. Data Export and Deletion

Tenants may request export of their Tenant Data in a reasonable format supported by the platform.

Deletion requests may be subject to:

1. the 10-year retention policy;
2. legal obligations;
3. audit requirements;
4. unresolved disputes;
5. security investigations;
6. backup retention cycles;
7. contractual obligations.

Where deletion is not possible immediately, access may be restricted, data may be archived, or data may be anonymised where appropriate.

20. Tenant Administrator Responsibilities

Tenant administrators must:

1. assign roles carefully;
2. remove users who no longer require access;
3. ensure agents understand data submission requirements;
4. obtain required consents from users and agents;
5. avoid uploading unnecessary personal data;
6. verify data before organisation-wide release;
7. report suspected misuse or compromise;
8. ensure that public communications based on platform data are lawful and accurate.

21. Children and Minors

The platform is not intended for use by children.

Tenants must not create accounts for minors unless they have lawful authority and the platform operator has expressly approved such use in writing.

22. Changes to this Policy

The platform operator may update this Data & Privacy Policy from time to time.

Material changes will be communicated through the platform, website, email, or another reasonable method.

Continued use of the platform after the effective date of an updated policy constitutes acceptance of the updated policy.

23. Contact

For privacy, data protection, or data access requests, contact:

contact form