Privacy Policy

1.Introduction

This Privacy Policy explains how TOMS (Traffic Offence Management System) ("TOMS," "the Platform," "we," "us," or "our") collects, uses, shares, and protects personal data when you use the Platform - whether as a member of the public checking, paying, or appealing a fine, or as an authorised Officer.

This Policy should be read together with our Terms of Service. By using the Platform, you acknowledge that your personal data will be processed as described here.

2.Who We Are

TOMS is operated by GH-TOMS ("we," "us"). For the purposes of Ghana's Data Protection Act, 2012 (Act 843), we act as the data controller responsible for personal data processed through the Platform.

3.What Personal Data We Collect

3.1 Information You Provide

• If you pay a fine: your name and, optionally, an email address, together with details of the payment method used.
• If you submit an Appeal: your written statement, any supporting evidence you provide, and your contact details if given.
• If you take part in our optional post-payment feedback survey: your ratings and any comments you choose to add.
• If you are an Officer: your name, officer ID, station, email address, and password (stored in encrypted/hashed form, never in plain text).

3.2 Information Collected Automatically

• The vehicle registration number, offence type, amount, and photographic evidence of the vehicle's plates, captured by an issuing Officer at the time of the citation.
• The GPS location of the offence, captured automatically at the point of issue.
• Standard technical information such as your IP address, browser type, and device information, used for security purposes (for example, to rate-limit repeated requests) and diagnostics.

3.3 Information We Do Not Collect

We do not ask for or store your full bank account or card details, or your national ID number, through the Platform. Payments are made directly through your own bank or mobile money provider; we only record a reference to the transaction in order to verify it.

4.How We Use Your Data

We use personal data to:

• create, independently review, and process traffic offence citations;
• verify and confirm payments, and issue receipts;
• process and decide Appeals;
• operate Officer accounts and control access to the Platform according to role;
• maintain a security and audit trail of actions taken on the Platform;
• understand and improve the experience of paying a fine, through the optional post-payment survey;
• detect and prevent fraud, abuse, and unauthorised access.

5.Legal Basis for Processing

We process personal data connected to the issuing, review, payment, and appeal of traffic offence citations on the basis that it is necessary for the exercise of an official public function relating to road traffic enforcement, and to comply with our legal obligations. Where you choose to take part in the optional feedback survey, we rely on your consent, which you may withdraw at any time simply by not participating.

6.Who We Share Your Data With

We do not sell your personal data. We may share personal data with:

• the Ghana Police Service and its Motor Traffic and Transport Department (MTTD), and other relevant government authorities, for the purposes of traffic law enforcement;
• your bank or mobile money provider, solely to verify a payment you have made;
• service providers who host and maintain the Platform's technical infrastructure, under obligations to protect your data;
• a court, regulator, or other authority, where required by law.

7.Data Retention

Traffic offence records, including evidence photographs and payment records, are retained for as long as necessary to serve as an official enforcement and audit record, and in accordance with any applicable legal or regulatory retention requirements. Officer account information is retained for as long as the account remains active, and for a reasonable period afterward for audit purposes. Survey responses are retained in a form that supports service improvement and reporting.

8.How We Protect Your Data

We apply a number of technical and organisational measures to protect personal data on the Platform, including:

• storing photographic evidence in a private location that is never publicly browsable;
• role-based access control, so that Officers, Control Officers, and administrators only see the information relevant to their role;
• independent review of every fine by someone other than the issuing Officer, creating a built-in check on how data is used;
• rate-limiting and other safeguards on public-facing pages to deter automated abuse;
• an audit log of key administrative actions;
• encrypted storage of account passwords.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we work to protect your data using appropriate safeguards.

9.Your Rights Under Ghana's Data Protection Act, 2012 (Act 843)

Subject to applicable exceptions, you have the right to:

• be informed of the personal data we hold about you and how it is used;
• request access to a copy of your personal data;
• request that inaccurate personal data be corrected;
• object to the processing of your personal data in certain circumstances;
• request that your personal data be deleted, where we are not required to keep it for legal, enforcement, or audit purposes.

To exercise any of these rights, please contact us using the details in Section 14. If you are not satisfied with our response, you have the right to complain to Ghana's Data Protection Commission.

10.Cookies and Similar Technologies

The Platform uses a small number of technical cookies that are necessary for it to function - for example, to keep you signed in and to protect forms against fraudulent submission. We do not use the Platform to serve advertising, and we do not use tracking cookies for marketing purposes.

11.Children's Privacy

The Platform is intended for use by adults, in connection with the operation of motor vehicles. It is not directed at children, and we do not knowingly collect personal data from children.

12.International Data Transfers

Where the Platform's technical infrastructure, such as hosting or email delivery, is located outside Ghana, your personal data may be processed in that location. Where this occurs, we take steps to ensure your data continues to receive an appropriate level of protection.

13.Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this page periodically.

14.Contact Us

If you have questions about this Privacy Policy, or wish to exercise any of your data protection rights, please contact us at: hello@ghtoms.com

If you have concerns about our handling of your data that we have not been able to resolve, you may also contact Ghana's Data Protection Commission.