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Policies

Media Policy

How ZAPF engages with the media, runs its official channels and protects personal data in photographs, video and publications.

Version 1.0 · Effective 1 October 2026

Purpose and scope

This policy sets out how the Zimbabwe Association of Pension Funds (ZAPF) communicates with the media and the public, and how it protects the personal information of the people who appear in, or are mentioned in, its communications.

It applies to Council members, the Director General, secretariat staff, and anyone authorised to act or speak on ZAPF's behalf. It covers newspapers, radio, television, online publications, this website, the ZAPF mobile app, newsletters and ZAPF's social media channels.

Legal framework

ZAPF conducts its media and communications activities in accordance with the laws of Zimbabwe, including:

  • The Cyber and Data Protection Act [Chapter 12:07], which governs the collection, processing and sharing of personal information. Under the Act, the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) is the Data Protection Authority.
  • The Cyber and Data Protection (Licensing of Data Controllers and Appointment of Data Protection Officers) Regulations, 2024 (Statutory Instrument 155 of 2024), which require data controllers to be licensed by POTRAZ and to appoint a Data Protection Officer.
  • The Postal and Telecommunications Act [Chapter 12:05], which establishes POTRAZ.
  • The cyber offences introduced by the Cyber and Data Protection Act into the Criminal Law (Codification and Reform) Act, including offences relating to the electronic transmission of false or harmful data messages.
  • Copyright and other intellectual property law, in respect of photographs, video, logos and publications.

Where this policy and the law differ, the law prevails.

Who speaks for ZAPF

Only the following people may speak to the media on ZAPF's behalf:

  • the Chairperson, on matters of policy and the Association's official positions;
  • the Director General, on operational matters, events, training and member services;
  • other Council members or staff, when specifically authorised by the Chairperson or Director General for a particular matter.

Members of staff and Council who are approached by journalists should refer the enquiry to the secretariat rather than comment personally. Views expressed by individual trustees, member funds or service providers are their own and do not represent ZAPF unless stated in an official ZAPF statement.

Media enquiries

Journalists should direct enquiries to the ZAPF secretariat by email at zapf@zapf.co.zw or by phone on +263 77 617 4138. We aim to acknowledge every enquiry within one working day and to respond fully within the journalist's deadline wherever possible.

ZAPF does not comment on the affairs of individual pension funds, members or pensioners, or on matters before the regulator or the courts. Questions about an individual's pension should be directed to the relevant fund, and regulatory matters to the Insurance and Pensions Commission (IPEC).

Official channels and social media

ZAPF's official channels are this website, the ZAPF mobile app, the ZAPF newsletter and the social media accounts linked from this website. Statements published elsewhere are not official unless confirmed through one of these channels.

  • Official channels are managed by the secretariat, and content is approved before publication.
  • Staff and Council members using personal social media accounts must not present personal views as ZAPF positions or share confidential or members' information.
  • ZAPF may remove comments on its channels that are abusive, discriminatory, misleading or that disclose personal information.

Photography, video and personal data

ZAPF photographs and films its conferences, general meetings, training sessions and other events. These images are personal information, and ZAPF handles them in line with the Cyber and Data Protection Act.

  • Notice: event registration forms and venue signage tell attendees that photography and filming will take place, why, and where images may be published.
  • Lawful purpose: images are used to report on ZAPF's activities and to promote its events, training and pension awareness work. They are not sold or given to third parties for marketing.
  • Consent: ZAPF seeks consent before publishing close-up images of identifiable individuals for promotional purposes. Attendees may ask the photographer not to photograph them.
  • Children: ZAPF does not publish identifiable images of children without the written consent of a parent or guardian.
  • Sensitive information: ZAPF does not publish information about individuals' pension benefits, health, finances or identity numbers.
  • Retention: images are kept only as long as needed for the purposes above and the Association's historical record.

Your rights over your personal data

Under the Cyber and Data Protection Act, you have the right to be informed about how your personal information is used, to access it, to have inaccurate information corrected, and to object to or ask for the deletion of information about you, subject to the limits set out in the Act.

To ask for a photograph or other information about you to be removed from a ZAPF channel, or to exercise any of these rights, contact ZAPF's Data Protection Officer through the secretariat at zapf@zapf.co.zw. We will respond within a reasonable time and, for removal requests, take the image down from ZAPF's channels while the request is considered.

If you are not satisfied with ZAPF's response, you may complain to the Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) as the Data Protection Authority.

Responsible content

Everything ZAPF publishes must be accurate, fair and respectful. ZAPF will not publish content that:

  • is false or misleading, or presented in a way likely to mislead members or the public;
  • is discriminatory, abusive or incites violence;
  • discloses personal or confidential information without a lawful basis;
  • infringes another person's copyright or other rights.

Use of the ZAPF name, logo and images

The ZAPF name, logo, publications and photographs belong to the Association. Media organisations may use ZAPF press statements and photographs supplied for publication, with credit to ZAPF. Any other use, including in advertising or to suggest endorsement, requires written permission from the secretariat.

Accuracy and corrections

If ZAPF publishes something inaccurate, it will correct it promptly on the channel where it appeared. If a media report misrepresents ZAPF or its positions, the secretariat will contact the publication to request a correction or right of reply.

Breaches and incidents

Any suspected unauthorised disclosure of personal information through ZAPF's channels must be reported to the Data Protection Officer immediately. ZAPF will contain the incident, assess its impact and notify POTRAZ and affected individuals where the Cyber and Data Protection Act requires.

Breaches of this policy by staff or Council members are dealt with under ZAPF's disciplinary and governance procedures.

Review of this policy

The Council reviews this policy every year, and sooner if the law or ZAPF's communications channels change. Questions about the policy should be sent to the secretariat.