How TmpTech Credit Bureau handles personal data

Tonga does not yet have a dedicated, enacted data protection or privacy statute. A Data Protection & Privacy Bill has been in development alongside Tonga's broader digital-identity and cybersecurity legislation, but as of the date at the top of this page it has not come into force, and no data protection authority or commissioner has been established.

Until that changes, this policy is not a recitation of statutory obligations — it is TmpTech Credit Bureau's own commitment, written to the standard a data protection act would ordinarily require: collect only what is needed, use it only for credit reporting purposes, keep it secure, and give people a real way to see and correct their own record. We rely on the confidentiality conditions attached to our National Reserve Bank of Tonga (NRBT) licensing as a credit information provider, on ordinary contract and confidentiality law, and on these commitments themselves. We will update this policy to reflect Tonga's Data Protection & Privacy Bill once it is enacted.

TmpTech Credit Bureau does not collect personal data from the public directly. Almost everything on file arrives from a member institution — a bank or lender you already have, or had, a credit relationship with. We hold:

• Identity data: full name, national ID / business registration number, date of birth, subject type (individual or business), and contact details as submitted by a member institution.
• Trade line data: the credit facilities themselves — account type, limit, balance, payment history, delinquency status, and account status — as reported by the institution that holds the account.
• Enquiry data: a record of which member institution asked about you, when, for what purpose, and against what consent reference.
• Derived data: a credit score and score history, calculated from the above.
• Portal account data: for member institution staff and bureau staff who log in — name, email, and role, held separately from credit-subject data.

Personal data on the register is used only to:

• Compile and maintain a credit file and credit score for each subject.
• Respond to enquiries from member institutions assessing a credit application.
• Detect and flag delinquency, disputed accounts, and suspected fraud, so both the bureau and member institutions can act on it.
• Meet our own regulatory, audit, and record-keeping obligations as an NRBT-licensed credit information provider.

We do not sell personal data, use it for marketing, or share it with anyone outside the register except as described in the next section.

Access is scoped by institution and role, enforced on every request, not just in the screen you happen to be looking at:

• A member institution can see the trade lines it submitted in full, and can see other institutions' trade lines on a shared subject only in summary — balance and status, not always the reporting institution's identity — depending on the enquiry type and consent on file.
• Bureau staff can see the full register, for operating and supervising it.
• Every enquiry and record view is logged against the user and institution that made it. That log is what lets us tell a subject who has looked at their file.

A member institution must hold the subject's consent before making an enquiry against the register, and must record a consent reference against that enquiry. We do not independently verify each consent at the point of enquiry — that obligation sits with the member institution making the request, as a condition of its membership — but the consent reference is retained on our side as part of the enquiry record, so it can be produced if a subject disputes that an enquiry was authorised.

The register is built on a permission model, not a promise:

• Role- and institution-level access control, enforced on every read and write, not only in the interface.
• Encrypted transport for every connection to the portal and the API.
• Token-based authentication and rate limiting for API access.
• An audit trail of who viewed, submitted, or changed a record, and when.

Credit history is retained for as long as it is relevant to assessing creditworthiness — this is the basis on which a credit bureau is useful at all, and mirrors standard credit-reporting practice in jurisdictions with a mature framework. A disputed entry is not simply deleted on request: it is flagged as disputed, investigated, and corrected or confirmed, so the record stays accurate rather than merely convenient. Portal account data for staff who leave a member institution is disabled, not silently left active.

You may ask us for:

• A copy of your own credit file.
• A list of who has enquired against your file, and when.
• Correction of information you believe is wrong, out of date, or not yours.

The fastest route is usually through the member institution you have a direct relationship with, since they can raise a dispute against a specific trade line directly. You can also contact the bureau directly using the details below. Because Tonga does not yet have a statutory deadline for this kind of request, we commit to acknowledging any request within 5 business days and resolving straightforward corrections within 30.

There is no independent data protection authority in Tonga to escalate a complaint to at present. If you are not satisfied with how we have handled a request, first raise it with us in writing using the contact details below; as the bureau's prudential regulator, the National Reserve Bank of Tonga may also be a relevant contact for complaints about a licensed credit information provider. We will update this section once a data protection authority exists.

We will revise this policy as our practices change, and materially rewrite it once Tonga's Data Protection & Privacy Bill takes effect. The version and effective date at the top of this page will always reflect the current text; we do not apply changes retroactively to how data already collected was handled.

Requests, corrections, and complaints: privacy@tmptech.to. General enquiries: info@tmptech.to.