1.0 Data protection principles
Sole Limited is committed to processing data in accordance with its aim to be
a safe, fair, transparent and leading FinTech finance solution and payments
system service provider in Fiji.

2.0 General provisions
2.1 This policy applies to all personal data on both paper and digital records
processed by Sole.
2.2 The Chief Risk Officer shall take responsibility for Sole’s ongoing compliance
with this policy.
2.3 This policy shall be reviewed as and when needed or at least annually.

3.0 Lawful, fair and transparent processing
3.1 To ensure its processing of data is lawful, fair and transparent, Sole shall
maintain a Register of Systems.
3.2 The Register of Systems shall be reviewed at least annually.
3.3 Individuals have the right to access their personal data and any such
requests made to Sole shall be dealt with in a timely manner.

4.0 Lawful purposes
4.1 All data processed by Sole must be done on one of the following lawful
bases: consent, contract, legal obligation, regulatory requirements, vital
interests, public task or legitimate interests.
4.2 Sole shall note the appropriate lawful basis in the Register of Systems.
4.3 Where consent is relied upon as a lawful basis for processing data, evidence
of opt-in consent shall be kept with the personal data.
4.4 Where communications are sent to individuals based on their consent, the
option for the individual to revoke their consent would be clearly available
and systems will be in place to ensure such revocation is reflected
accurately in Sole’s systems.

5.0 Data minimisation
5.1 Sole shall ensure that personal data are adequate, relevant and limited to
what is necessary in relation to the purposes for which they are processed.
5.2 Notwithstanding 5.1, Sole shall make every reasonable effort to comply with
the Reserve Bank of Fiji Financial Sector Development Policy on Financial
Inclusion Disaggregated Data.

6.0 Accuracy
6.1 Sole shall take reasonable steps to ensure personal data is accurate.
6.2 Where necessary for the lawful basis on which data is processed, steps shall
be put in place to ensure that personal data is kept up to date.
6.3 Sole shall where possible rely on third party verification of personal details, in
particular, by Government Agencies in Fiji and Licensed Financial Institutions
supervised by the Reserve Bank of Fiji.

7.0 Archiving/Removal
7.1 To ensure that personal data is kept for no longer than necessary, Sole shall
put in place an archiving policy for each area in which personal data is
processed and reviewed annually.
7.2 The archiving policy shall consider what data should/must be retained, for
how long, and why, after retention of all records for 7 years.

8.0 Security
8.1 Sole shall ensure that personal data is stored securely using modern
software that is kept up to date.
8.2 Access to personal data shall be limited to personnel who need access and
appropriate security should be in place to avoid unauthorised sharing of
information.
8.3 When personal data is deleted this should be done safely such that the data
is irrecoverable.
8.4 Appropriate back-up and disaster recovery solutions shall be in place.

9.0 Breach
9.1 In the event of a breach of security leading to the accidental or unlawful
destruction, loss, alteration, unauthorised disclosure of, or access to,
personal data, the Organisation shall promptly assess the risk to people’s
rights and freedoms and if appropriate report this breach to the Reserve
Bank of Fiji.

August 2022