Registration in Senegal
There is no country-wide system of registration in Senegal. However, the processing of personal data may be subject to prior notification to, or authorization/prior approval from the CDP.
Notification regime
Businesses must notify the CDP in respect of their processing activities, except in the following cases:
- Non-profit processing for religious, philosophical or political associations, or trade unions (when the data corresponds to the purpose of the association or trade union, concern only their members and are not disclosed to third parties).
- Processing for the sole purpose of keeping a register (by law, this is intended exclusively to provide public information and is open to consultation for any person with a legitimate interest.)
(Article 18 of the Act)
Authorization/prior approval regime
Prior approval from the CDP is required for processing of:
- Genetic data
- Data relating to offences, convictions or security measures
- Data that involve an interconnection of files
- Data that include a national identification number
- Biometric data
- Data that are of public interest, particularly for historical, statistical or scientific purposes.
Authorisation is, however, not required in the following cases:
- Data processing for private purposes only.
- Temporary data copies for transmission, network access and automatic storage purposes, provided they are made to improve network user access.
- Data processing by non-profit organisations for religious, philosophic, political or union purposes only.
- Data processing for public register purposes.
Notice/opinion regime ('Avis')
The automated processing of personal information carried out on behalf of the State, a public institution or a local authority or a legal person under private law managing a public service is decided by regulatory act taken after a reasoned opinion from the CDP. Such processing relates to:
- State security, defense or public safety;
- the prevention, investigation, recording or prosecution of criminal offences or the execution of criminal sentences or security measures;
- the population census;
- personal data that reveal, directly or indirectly, the racial, ethnic or regional origins, parentage, political, philosophical or religious opinions or trade union membership of persons, or that relate to the health or sexual life of persons when they are not covered by provisions related to interconnexion of data;
- the processing of salaries, pensions, taxes, and other settlements.
(Articles 20 and 21 of the Act)
