– Unofficial translation from French –
Protection of personal data
“TOGO SAFE” application
TOGO SAFE is a mobile application designed by the Togolese government to help stem the spread of COVID-19 in Togo. The application facilitates tracing close contacts of confirmed cases of COVID-19 by helping the local health authority to quickly inform users who may have been exposed to them.
With your consent, the application exchanges encrypted and anonymized Bluetooth signals with nearby phones with the same application installed. This allows you to be informed if you were in close proximity to another user who later tests positive for the virus. We are committed to protecting your privacy and will only use your data for contact tracing purposes.
TOGO SAFE uses geolocation to monitor the movements of people who have been ordered to self-isolate/quarantine, particularly travellers who just arrived in Togolese territory. This allows public health authorities to monitor the compliance of these individuals to isolation or quarantine orders.
How do we use your data?
The only identity data we store is your mobile phone number, personal ID data you provide and a randomised anonymous user ID.
When you register, a random identifier is generated and associated with your mobile phone number and personal ID data. Your mobile phone number, personal ID data and anonymised user ID are stored in a secure server and are never shown to the public.
The application works by exchanging anonymous proximity information between phones on which it is installed via Bluetooth® Low Energy (BLE) signals. It records and stores this information which the Ministry of Health can use to alert users who have been in contact with a person who has tested positive for COVID-19.
Purposes and responsibility for data processing
The development of the application is entrusted to the Ministry of Digital Economy, in coordination with the Ministry of Health.
The “TOGO SAFE” application process data collected in order to :
1º identify persons who may have been exposed to COVID-19;
2º contact, test and isolate these people quickly before they can infect others;
3º monitor the spread of the pandemic across the country; and
4º improve monitoring of quarantine compliance by the use of digital geolocation.
Legal basis of the data processing
This data is processed within the context of a public health mission to help preserve the health of the Togolese population. This data processing is implemented and protected in accordance with Togolese law n°2019-014 of 29 October 2019 relating to the protection of personal data (in French).
Types of data processed :
- an authentication key shared between the application and the central server;
- a unique identifier associated with each downloaded application randomly generated by the central server and known only to that server, where it is stored;
- the log of proximity;
- the log of duration of user exposure to persons later diagnosed or tested positive for COVID-19, stored on the secure central server;
- the risk status i.e. contacts at risk of infection;
- the date of the last queries to the secure central server;
- the geolocation of a user who is under quarantine or isolation order.
Receiver of the information from data processed
Users of the application who have been identified as contacts at risk of infection are informed that they have been in close proximity to at least one other user diagnosed or tested positive for COVID-19.
Duration of data storage
The data is kept for processing until the coronavirus (COVID-19) pandemic is over.
Users’ rights over their data
Access, rectification and limitation cannot be exercised because the data processed are anonymised in order to avoid any re-identification of persons. The exercise of these rights would require identification of the data subject, which would considerably weaken the security of the entire application.
However, if you have any questions about the processing and/or deletion of your data, please send an email to firstname.lastname@example.org.