Restricted Access — For Authorised Cabinet Members Only

Legal & Compliance

Privacy Policy

How the E-Cabinet system collects, uses, protects, and manages personal information in accordance with applicable Kiribati law.

Effective Date: 1 January 2025  •  Version 1.0  •  Office of the Cabinet Secretariat

Contents

  1. About This Policy
  2. Data Controller
  3. Legal Framework
  4. Information We Collect
  5. Legal Basis for Processing
  6. How We Use Your Information
  7. Disclosure and Sharing
  8. Data Retention
  9. Security Measures
  10. Your Rights
  11. Cookies and Sessions
  12. Cross-Border Data
  13. Changes to This Policy
  14. Contact and Complaints

1 About This Policy

This Privacy Policy describes how the Government of Kiribati, through the Office of the Cabinet Secretariat, collects, processes, stores, and protects personal information in connection with the E-Cabinet digital Cabinet Management System.

E-Cabinet is a secure, restricted-access platform used exclusively by Cabinet members, Ministers, Cabinet Secretariat staff, and other authorised government officials for the management and review of Cabinet papers, agenda items, meeting records, and official deliberations.

By accessing or using E-Cabinet, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. This policy is binding on all authorised users of the system.

Scope: This policy applies to all personal information processed through the E-Cabinet system, including information collected at login, during system use, and as part of the automated audit and security logging functions of the platform.

2 Data Controller

The data controller responsible for personal information processed through E-Cabinet is:

Office of the Cabinet Secretariat
Office of Te Beretitenti
P.O. Box 68, Bairiki
Tarawa, Republic of Kiribati

Data Protection Officer: Secretary to Cabinet
Email: cabinet.secretariat@gov.ki
Telephone: +686 21183

The Cabinet Secretariat acts as data controller pursuant to its statutory functions under the Cabinet Secretariat Regulations and in accordance with the Kiribati Data Protection Act 2025.

3 Legal Framework

The collection and processing of personal information through E-Cabinet is governed by, and conducted in accordance with, the following legislation and instruments of the Republic of Kiribati:

Kiribati Data Protection Act 2025

The primary legislation governing the processing of personal data in Kiribati. The Act establishes the rights of data subjects, the obligations of data controllers and processors, lawful bases for processing, and enforcement mechanisms. All processing activities under E-Cabinet are conducted in accordance with the principles set out in this Act, including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and accountability.

Constitution of Kiribati 1979

The Constitution of the Republic of Kiribati guarantees the fundamental right to privacy for all persons. The processing of personal information through E-Cabinet is conducted in a manner consistent with these constitutional protections, limited to what is necessary for legitimate governmental functions.

Official Secrets Act (Cap. 114)

Cabinet papers, agenda items, deliberations, and all material stored within E-Cabinet may be classified information within the meaning of the Official Secrets Act. All users are bound by the obligations of confidentiality prescribed by this Act. Unauthorised disclosure of Cabinet information accessed through E-Cabinet constitutes a criminal offence.

Electronic Transactions Act 2014

The Electronic Transactions Act provides the legal basis for electronic signatures, electronic records, and digital communications used within E-Cabinet. Digital records of Cabinet deliberations and decisions created through E-Cabinet carry the same legal standing as equivalent paper records.

Public Service Act (Cap. 76)

All public servants accessing E-Cabinet remain subject to the code of conduct and obligations of confidentiality prescribed by the Public Service Act and associated regulations, including obligations relating to the handling of official information.

Cybercrime Act 2021

Unauthorised access to, interference with, or misuse of the E-Cabinet system or the data contained therein constitutes a criminal offence under the Cybercrime Act 2021. The system employs technical security measures to detect and prevent such offences, and all access activity is logged for investigative and evidentiary purposes.

4 Information We Collect

E-Cabinet collects only the personal information necessary to operate the system securely and fulfil its official governmental functions. The categories of information collected are:

4.1 Account and Identity Information

4.2 Authentication and Security Information

4.3 System Activity and Audit Records

4.4 Technical Information

Note: E-Cabinet does not collect sensitive personal information beyond what is inherently associated with an individual's official government role and identity. The system does not collect financial information, health data, biometric data (other than 2FA), or personal information unrelated to official functions.

5 Legal Basis for Processing

All processing of personal information through E-Cabinet is conducted on one or more of the following lawful bases as provided under the Kiribati Data Protection Act 2025:

5.1 Performance of a Public Task

The primary legal basis for processing is the performance of a task carried out in the public interest and in the exercise of official governmental authority vested in the Cabinet Secretariat. The collection and processing of personal information is an inherent and necessary part of operating the digital Cabinet management infrastructure of the Republic of Kiribati.

5.2 Legal Obligation

Certain processing activities — in particular the maintenance of complete audit trails, security logs, and records of Cabinet deliberations — are required by law and by the constitutional and statutory obligations of the Cabinet Secretariat to maintain proper records of Cabinet proceedings.

5.3 Consent

Where processing is not strictly required by law or public function, authorised users are notified and provide consent by virtue of their acceptance of the terms of access to the system. Access to E-Cabinet is conditional on the user's acceptance of this Privacy Policy and the associated Terms of Use.

5.4 Legitimate Interests

Processing of technical and security information (including IP addresses, session logs, and authentication events) is necessary for the legitimate interest of the Government in maintaining the security, integrity, and availability of the E-Cabinet system and the highly sensitive Cabinet information it contains.

6 How We Use Your Information

Personal information collected through E-Cabinet is used solely for the following purposes:

Personal information is not used for commercial purposes, marketing, profiling unrelated to official functions, or any purpose not described in this policy.

7 Disclosure and Sharing

The Cabinet Secretariat treats all personal information processed through E-Cabinet as strictly confidential. Personal information will not be disclosed to third parties except in the following circumstances:

7.1 Within Government

Information may be shared with other authorised officers within the Office of Te Beretitenti and relevant Ministries strictly on a need-to-know basis and only to the extent necessary to perform official functions.

7.2 Legal and Regulatory Requirements

The Cabinet Secretariat may disclose personal information where required to do so by law, court order, or the direction of a competent authority, including in the context of criminal investigations under the Cybercrime Act 2021 or other applicable legislation.

7.3 Technical Service Providers

Where third-party technical service providers (e.g. hosting or infrastructure providers) are engaged to support the operation of E-Cabinet, such providers are bound by strict confidentiality obligations and data processing agreements consistent with the Kiribati Data Protection Act 2025. They are not permitted to use personal information for any purpose other than providing the contracted technical service.

7.4 Cabinet Records

Records of Cabinet deliberations, decisions, and proceedings stored within E-Cabinet are subject to the classification and disclosure rules applicable to Cabinet papers under the Official Secrets Act (Cap. 114) and Cabinet Secretariat regulations. The identities of Cabinet members are part of the public record of government and are not treated as confidential in that context.

E-Cabinet does not sell, rent, trade, or otherwise transfer personal information to any commercial third party.

8 Data Retention

Personal information is retained for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following retention schedules:

Upon expiry of the applicable retention period, personal information will be securely deleted or anonymised in accordance with the data minimisation requirements of the Kiribati Data Protection Act 2025.

9 Security Measures

Given the highly sensitive and classified nature of Cabinet information, the E-Cabinet system implements a comprehensive set of technical and organisational security measures:

9.1 Technical Measures

9.2 Organisational Measures

Notwithstanding these measures, no system is completely immune to security risks. In the event of a data breach affecting personal information, the Cabinet Secretariat will notify affected individuals and any relevant authority in accordance with the breach notification obligations under the Kiribati Data Protection Act 2025.

10 Your Rights

Subject to the limitations applicable to the processing of personal information for official governmental and public interest purposes, authorised users of E-Cabinet have the following rights under the Kiribati Data Protection Act 2025:

Right of Access

You may request a copy of the personal information held about you in E-Cabinet.

Right to Rectification

You may request correction of inaccurate or incomplete personal information held about you.

Right to Erasure

You may request deletion of personal information where it is no longer necessary, subject to overriding retention obligations under law.

Right to Restriction

You may request that processing of your personal information be restricted in certain circumstances.

Right to Object

You may object to processing based on legitimate interests, subject to the overriding public interest in maintaining Cabinet records and system security.

Right to Complain

You have the right to lodge a complaint with the relevant data protection authority in Kiribati.

To exercise any of these rights, please contact the Data Protection Officer at the address set out in Section 2. The Cabinet Secretariat will respond to requests within 30 calendar days of receipt. Certain rights may be restricted or limited where their exercise would conflict with the Cabinet Secretariat's legal obligations, official functions, or the requirements of the Official Secrets Act.

11 Cookies and Sessions

E-Cabinet uses session cookies that are strictly necessary for the operation of the system. These cookies:

No third-party analytics, advertising, or tracking cookies are used on the E-Cabinet platform. The system does not use cookies that require consent under applicable law because only strictly necessary session cookies are deployed.

12 Cross-Border Data Transfers

E-Cabinet is operated on servers located within or on behalf of the Government of Kiribati. Where technical infrastructure or service providers result in personal information being processed or stored outside of Kiribati, such transfers are made only where:

The Cabinet Secretariat is committed to ensuring that any cross-border transfers of personal information comply with the requirements of the Kiribati Data Protection Act 2025 and do not compromise the security or confidentiality of Cabinet information.

13 Changes to This Policy

The Cabinet Secretariat may update this Privacy Policy from time to time to reflect changes in law, technology, or the operational requirements of the E-Cabinet system. Where changes are material, authorised users will be notified via the system or through official government communication channels.

The current version of this Privacy Policy is always available at /privacy-policy within the E-Cabinet system and on the official website of the Office of Te Beretitenti. The effective date at the top of the document indicates when the current version came into effect.

Continued use of E-Cabinet following notification of a material change constitutes acceptance of the updated policy.

14 Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal information, please contact:

Data Protection Officer
Office of the Cabinet Secretariat
Office of Te Beretitenti, Bairiki
Tarawa, Republic of Kiribati

Email: cabinet.secretariat@gov.ki
Telephone: +686 21183

If you are not satisfied with the response to your complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority established under the Kiribati Data Protection Act 2025.

All complaints will be acknowledged within 5 working days and resolved, where possible, within 30 calendar days of receipt.

Disclaimer: This Privacy Policy is provided for informational purposes and reflects the Cabinet Secretariat's current data handling practices. It does not constitute legal advice. References to specific sections of the Kiribati Data Protection Act 2025 and other legislation are indicative; users should consult the official text of applicable legislation for authoritative provisions. This document should be read alongside the E-Cabinet Terms of Use and any applicable Cabinet Secretariat directives governing system access and use.