Page 61 - ITU-T Focus Group Digital Financial Services – Consumer Experience and Protection

ITU-T Focus Group Digital Financial Services
Consumer Experience and Protection

Box 3: Data protection

Uganda: Mobile Money Regulations, Regulation 12(c) Data protection-

(i) A mobile money service provider, as well as its agents, shall uphold privacy and confidentiality of
customer information and data;

(ii) The conditions under which customer information and data will be kept shall be disclosed before
the customer enters into agreement with the mobile money service provider.
Comment:

Contracts reviewed (Utl M-sente and MTN Uganda) did not include affirmations that providers would keep
customer information confidential/protected, nor to with which entities consumer data would be shared.

2.2.3 Reversal of transactions

Human error can result in customers making mistakes when they are effecting transactions. Yet, only 6 per
cent of the contracts reviewed had a clause advising customers about whether and how they could reverse
erroneous transactions. Some contracts provide that the customer could reverse transactions in the case of
payments to the wrong person, as long as the other party had not yet withdrawn the amount in question.
The problem is that fraudulent actors may promptly cash out, leaving no recourse for victimized customers
who can ill-afford to bear such loses.

Figure 3: Reversal

2.2.4 Variations of contract terms
Providers often reserve the right to modify terms and conditions, including those relating to fees and costs,
after the initial acceptance of terms by a customer.

As shown in Figure 4, for a significant majority of the contracts reviewed, 72 per cent, there was no clause
stating that customers would be given prior notice of a change of terms. This large percentage is of concern as
it suggests that many providers may be introducing contract changes that customers are not aware of, which
could be eroding consumer rights or protections that were available in the original contracts, and which might
have caused customers to not enter the contracts if they had been disclosed in the first place.

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