Unwanted Witness is strongly concerned by Uganda Revenue Authority’s (URA) attempt to acquire customer data from the National Water and Sewerage Corporation (NWSC) without conducting a Data Protection Impact Assessment (DPIA). This action, aimed at improving tax compliance and identifying unregistered taxpayers constitutes a grave violation of the right to privacy enshrined in Article 27 of the Constitution of Uganda, 1995, and breaches Uganda’s data protection laws and principles.
Legal Concerns with the Proposed Data Integration
Regulation 12 of the Data Protection and Privacy Regulations, 2021, requires URA to conduct a DPIA before processing personal data. This includes a systematic description of the processing purpose, an assessment of risks, disclosure of processing operations. No evidence indicates compliance with this statutory obligation, reflecting poor governance and undermining accountability.
Section 29(2) of the Data Protection and Privacy Act and Regulation 15 of the Data Protection and Privacy Regulations, 2021, require data controllers and processors to register with the Personal Data Protection Office (PDPO). NWSC has not met this requirement, violating data protection principles and eroding public trust.
Article 27 of the 1995 Constitution of Uganda enshrines the right to privacy, shielding individuals from unwarranted data intrusion. The broad scope of the requested data collection exceeds what is necessary to achieve URA’s objectives and is neither reasonable nor proportionate in a democratic society.
The blanket request for personal data lacks specificity and fails to demonstrate probable cause for targeting individuals suspected of tax non-compliance. Such sweeping measures are unwarranted and
incompatible with the principles of justice.
For further information, please contact:
THE UNWANTED WITNESS – Uganda |
P. O. Box 71314 Clock Tower K’la Uganda | Plot 26, Ssentema Road |
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