Where is data stored in compliance software, and is foreign hosting allowed under the CDPA?
Short answer
Any compliance tool is itself a data processor for you, so the same rules apply to it as to your accountant or cloud host: a written processing agreement, appropriate security and, if the servers are outside Zimbabwe, compliance with the trans-border transfer rules in sections 28 and 29 of the Cyber and Data Protection Act plus notification of the transfer to POTRAZ.
What the law says
Section 18 requires the controller to choose processors that provide sufficient security guarantees and to bind them by written contract; SI 155 section 10 requires a "written data processing agreement or contract". Section 28 permits transfers to countries with an adequate level of protection; section 29 permits transfers elsewhere on listed grounds, including the data subject's consent and necessity for a contract. SI 155 section 10 requires the controller to notify POTRAZ of international data transfers.
Example
A Tier 2 insurance broker in Harare evaluates two compliance tools. Vendor A hosts on servers in South Africa, provides a signed processing agreement, encryption details and an access log, and explains that the broker must record the transfer in its processing record and notify POTRAZ. Vendor B cannot say where the data is or who can see it. The broker chooses A and completes the notification; the compliance tool itself becomes the first entry in its processor register.
In practice
Ask every vendor, including Business Science Institute, three questions: where is the data hosted, who can access it, and what does the contract say? We provide a data processing agreement and hosting details with every subscription so that the answers go straight into your processor register and your POTRAZ notification.
General information, not legal advice. This page covers Zimbabwean law only: the Cyber and Data Protection Act [Chapter 12:07], Statutory Instrument 155 of 2024 and POTRAZ’s 2025 Implementation Guidelines. It is not the EU GDPR and not South Africa’s POPIA. Fees, fine levels and deadlines are as gazetted and published by POTRAZ at 9 September 2026; check the latest POTRAZ notices before acting. Businesses named in examples are fictional.