Plain language, not legal advice
The buyer wants records of how work was done. The law protects the people in those records. Both can be true at once, and this is how.
A customer list is personal data. So is a chat log with your staff's names in it, a support ticket with a phone number, an invoice with a sole trader's name. In Kenya, Côte d'Ivoire and the EU, using that data for a commercial purpose without a lawful basis is an offence.
That is why Trace never sells data that still identifies people.
Identifiers are removed: names, emails, phone numbers, account and ID numbers, addresses. Free text is checked for anything that could still point to a person. The work happens on your systems or ours, inside your country.
We sign a statement of method describing what was removed and how, and keep it with the agreement.
Before any buyer hears of you, you sign a mandate with Trace. It is exclusive for a set window, it states our share, and it says the buyer never learns who you are until the agreement is signed.
It protects you from being shopped around, and it protects the work we put in.
The Data Protection Act requires express consent before personal data is used commercially, and the regulator's standard clauses before personal data leaves the country. Anonymised data falls outside the Act, which is why anonymisation comes first.
Ink and Pixel registers with the Office of the Data Protection Commissioner as a data processor before the first Kenyan deal, and a Kenyan lawyer reviews the contract pack.
Law 2013-450 applies, and ARTCI, the regulator, must authorise in advance any transfer of personal data outside ECOWAS. Until that route has been walked with a local lawyer, no Ivorian data moves. Calls, inventories and ranges are fine; transfers are not.
If you are in Abidjan, book the call anyway. Knowing what you have is the first step and it costs nothing.
Sell data that still identifies people.
Take data that belongs to someone else, such as an outsourcer's client records.
Name a buyer, or quote a payment date we cannot keep.
Move anything before the agreement is signed.
Originals are deleted after processing. The anonymised package, the statement of method and the agreement are kept for as long as the agreement says. You can ask us at any time what we hold.