PRIVACY POLICY

National Union of Miners and Allied Workers (NUMAW)

Website: https://numaw.org

Effective Date: 21 October 2026 | Last Updated: 21 October 2026

1. Introduction
The National Union of Miners and Allied Workers (NUMAW), hereinafter referred to as "NUMAW", "we", "our" or "us", respects the privacy and confidentiality of its members, employees, prospective members, workers, representatives, website visitors and other individuals who interact with the Union. This Privacy Policy explains how NUMAW collects, uses, stores, protects and discloses personal information obtained through its website, membership activities, labour representation, communications and other legitimate Union operations. NUMAW is committed to handling personal information responsibly and in accordance with applicable data protection laws, including Zambia's Data Protection Act No. 3 of 2021, where applicable. By using our website or providing personal information to NUMAW, you acknowledge this Privacy Policy. Where consent is required by law, we will obtain it as appropriate.

2. Information We Collect
Depending on your relationship with NUMAW and the services you request, we may collect the following categories of personal information.
2.1 Personal Identification Information
This may include: • Full name and date of birth. • National registration or other identification details, where necessary. • Telephone number and email address. • Residential or postal address. • Emergency contact details, where necessary.
2.2 Employment and Membership Information
To administer Union membership and provide labour-related representation, we may collect:
• Employer and workplace details. • Job title, occupation, department and work location. • Employment status and relevant employment history. • Membership application details, membership number and membership status. • Union subscriptions and relevant membership payment records. • Information necessary to verify membership and administer Union services.
2.3 Labour Relations and Grievance Information
Where a member requests assistance or representation, we may collect information concerning workplace disputes, disciplinary proceedings, employment grievances, collective bargaining matters, workplace incidents and related correspondence or supporting documents. Such information will be handled confidentially and accessed only where reasonably necessary for the relevant purpose and permitted by law.
2.4 Financial and Payment Information
Where applicable, we may process information relating to membership subscriptions, authorised deductions, payments, refunds and related financial records. Payments may be handled by third-party financial institutions or payment service providers. NUMAW will take reasonable steps to protect financial information and will not intentionally retain complete payment card details unless necessary, lawful and appropriately secured.
2.5 Website and Technical Information
When you visit our website, we may collect technical information such as: • IP address. • Browser and device information. • Operating system. • Pages visited and approximate time spent on the website. • Referral information and website activity logs. • Security and diagnostic information.
The information collected will depend on the website's actual functionality and configuration.
2.6 Correspondence and Communications
We may retain information you provide when contacting us by email, telephone, online forms, official social media channels or other communication methods, including enquiries, requests for assistance and feedback.
2.7 Sensitive Personal Information
Certain Union activities may involve sensitive personal information, including information relating to trade union membership, health, disciplinary matters or other circumstances relevant to a workplace dispute. NUMAW recognises that such information requires additional protection. We will collect and process it only where necessary, supported by an appropriate legal basis and subject to applicable safeguards.

3. Purposes for Which We Use Personal Information
NUMAW may use personal information for the following purposes:
1. Processing membership applications and maintaining membership records.
2. Verifying membership and administering Union subscriptions.
3. Representing and assisting members in employment-related matters.
4. Handling workplace grievances, disciplinary cases and labour disputes.
5. Supporting collective bargaining and legitimate Union activities.
6. Communicating with members about meetings, elections, notices, campaigns and Union developments.
7. Organising Union meetings, events, training and other activities.
8. Responding to enquiries and requests for assistance.
9. Maintaining the security and proper operation of our website and information systems.
10. Meeting applicable legal, regulatory, accounting and reporting obligations.
11. Protecting the rights and legitimate interests of NUMAW and its members, where permitted by law.
NUMAW will not knowingly use personal information for purposes that are incompatible with the purpose for which it was collected unless an appropriate legal basis exists.

4. Legal Basis for Processing
Where required by applicable law, NUMAW will process personal information on a lawful basis, which may include:
• The individual's consent.
• The administration of membership or an agreement with the individual.
• Compliance with a legal obligation.
• The exercise or defence of legal claims.
• Another lawful basis recognised under applicable data protection legislation.
Because Union membership and workplace representation may involve sensitive personal information, NUMAW will apply any additional legal requirements governing such information. Where consent is the basis for processing, individuals may withdraw it subject to applicable law. Withdrawal does not invalidate processing lawfully conducted before consent was withdrawn.

5. Confidentiality of Membership and Grievance Records
NUMAW understands the importance of protecting the confidentiality of its members and the individuals it represents.
Accordingly:
• Membership information will be accessible only to authorised personnel who require it for legitimate Union duties.
• Grievance records and workplace dispute documents will be handled on a confidential basis.
• Personal information will not be disclosed to employers or other parties merely because they request it.
• Information may be disclosed where authorised by the individual, necessary for an agreed representation process, required by law or otherwise lawfully permitted.
• Reasonable safeguards will be used to prevent unauthorised access, disclosure or misuse.
Confidentiality is subject to applicable legal obligations and circumstances in which disclosure is lawfully required.

6. Sharing Personal Information
NUMAW does not sell personal information.
Where necessary and lawful, NUMAW may share relevant information with:
• Authorised Union officials, employees and representatives.
• Legal advisers and other professional advisers assisting with Union matters.
• Relevant employers or their authorised representatives when necessary for a grievance, negotiation or representation process and supported by an appropriate legal basis.
• Courts, tribunals, labour authorities and other competent public bodies where required or permitted by law.
• Financial institutions and payment providers where necessary to process authorised transactions.
• Website hosting companies, IT support providers and other service providers acting on our behalf.
• Other parties where the individual has given appropriate authorisation or disclosure is otherwise lawful.
NUMAW will seek to limit disclosures to information reasonably necessary for the relevant purpose and will take appropriate steps to protect the information shared.

7. Cookies and Website Technologies
Our website may use cookies or similar technologies to support essential functionality, improve security and understand website performance. If analytics or non-essential tracking technologies are used, NUMAW will implement appropriate notices and consent mechanisms where required by law. Visitors may be able to control cookies through their browser settings. Disabling certain cookies may affect some website functions. The specific cookies used will depend on the website's actual configuration and any third-party services integrated into it.

8. Data Security
NUMAW will take reasonable technical and organisational measures to protect personal information against accidental loss, unauthorised access, disclosure, alteration, destruction or misuse.
Depending on the information and systems involved, safeguards may include:
• Restricted access to membership and grievance records.
• Password protection and appropriate account permissions.
• Secure website connections.
• Secure storage and backup procedures.
• Staff confidentiality requirements.
• Appropriate controls over third-party service providers.
No electronic storage or transmission method can be guaranteed to be completely secure. NUMAW will nevertheless take reasonable steps to maintain the confidentiality, integrity and availability of the information it holds.
Where a personal data breach occurs, NUMAW will investigate and take appropriate remedial action, including notifications required by applicable law.

9. Retention of Personal Information
NUMAW will retain personal information only for as long as reasonably necessary for the purpose for which it was collected or as required or permitted by applicable law. Retention periods may vary according to the nature of the information, membership status, employment disputes, financial records, legal proceedings and other legitimate recordkeeping requirements. When information is no longer required, NUMAW will take reasonable steps to securely delete, destroy or anonymise it, subject to any applicable retention obligations or lawful need to preserve evidence.

10. Transfer of Personal Information
NUMAW may use service providers whose systems or infrastructure are located outside Zambia.
Where personal information is transferred or accessed across borders, NUMAW will take appropriate steps to comply with applicable data protection requirements and ensure that suitable safeguards are in place.

11. Your Privacy Rights
Subject to applicable law and any lawful restrictions, individuals may have the right to:
• Request access to personal information held about them.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal information where legally permitted.
• Object to certain forms of processing.
• Request restriction of certain processing activities where applicable.
• Withdraw consent where processing is based on consent.
• Request information about how and why their personal information is processed.
• Exercise any applicable rights relating to automated decision-making.
• Lodge a complaint with the relevant data protection authority.
Members may exercise these rights without automatically losing access to their Union membership or representation. However, some information may need to be retained or processed to fulfil legal obligations or administer an ongoing matter. To make a privacy request, contact NUMAW using the official contact details published on our website. We may request reasonable identity verification before responding to a request.

12. Children's Privacy
NUMAW's website and Union services are not intended to collect children's personal information unnecessarily. Where information relating to a child is required for a legitimate purpose, NUMAW will apply appropriate safeguards and comply with applicable legal requirements, including requirements concerning parental or guardian authorisation where relevant.

13. Third-Party Websites
Our website may contain links to third-party websites, external resources and social media platforms. These third parties operate independently and may have their own privacy policies and practices. NUMAW does not control their handling of personal information. Visitors are encouraged to review the privacy policies of external websites before providing personal information.

14. Electronic Communications
NUMAW may use email, telephone, SMS, messaging platforms and other communication channels to contact members and individuals who engage with the Union. Communications may relate to membership administration, meetings, workplace matters, Union notices, campaigns and other legitimate activities. Where required by law, NUMAW will obtain consent for non-essential promotional communications and provide an appropriate way to opt out. Essential communications relating to membership, representation, legal obligations or ongoing matters may continue where lawfully necessary.

15. Changes to This Privacy Policy
NUMAW may revise this Privacy Policy from time to time to reflect changes in its activities, website features, technology or applicable laws. Any revised version will be published on this page together with an updated revision date. Where required by law, NUMAW will provide additional notice or obtain any necessary consent.

16. Contact NUMAW About Privacy
If you have questions about this Privacy Policy, wish to exercise your privacy rights or wish to raise a concern regarding the handling of your personal information, please contact the Union through its official contact channels.
Organisation: National Union of Miners and Allied Workers (NUMAW)
Website: https://numaw.org
Privacy Email: info@numaw.org
Telephone:
Postal Address:
Data Protection Contact:
NUMAW will review and respond to privacy requests in accordance with applicable law.
Individuals may also contact the Data Protection Commission of Zambia through its official website at https://www.dataprotection.gov.zm.

17. Applicable Law
This Privacy Policy is intended to operate in accordance with applicable laws, including Zambia's Data Protection Act No. 3 of 2021, where applicable. Nothing in this policy limits any right or protection that cannot lawfully be excluded or restricted. National Union of Miners and Allied Workers (NUMAW) Protecting the privacy and confidentiality of our members and the people we serve.