Governance
Data about people, handled as if it already mattered.
These systems are not yet holding anyone's data. That is precisely when the governance decisions get made — and when they are cheap to make properly.
The legal backdrop
Fiji has no comprehensive data protection act. We do not treat that as permission.
Personal data in Fiji is protected principally by section 24 of the 2013 Constitution, which provides a right to personal privacy including the confidentiality of personal information, supported by sector-specific provisions in instruments such as the Banking Act 1995 and the Cybercrime Act 2021. There is no general data protection statute and no national data protection authority.
The practical effect is that a company handling Fijian personal data faces fewer binding obligations than it would in most comparable jurisdictions. That is a gap in the law, not a licence to exploit it. We design to the standard a data protection regime would impose, on the assumption that Fiji will legislate and that systems built to a lower standard will have to be rebuilt.
For credit reporting specifically, the Fair Reporting of Credit Act 2016 already provides consumers with rights to obtain a copy of the information held about them, to challenge its accuracy and to require correction. Those rights are the starting point of the product design rather than a compliance obligation added to it.
Standing commitments
Five commitments that apply across every venture.
01
The subject can see the record
Any system we build that holds information about a person is designed so that person can see it, challenge it, and have it corrected. This is a design requirement, not a support process bolted on later.
02
Aggregate surfaces cannot re-identify
Government-facing reporting applies k-anonymity suppression at the architecture level. Small cells are suppressed rather than rounded, and the surface produces no re-identifiable output. It is not a configuration setting that can be relaxed under pressure.
03
Collect against a purpose, not against a possibility
Data is collected for a stated purpose with a stated retention period. Where a field is not needed to serve the purpose, it is not collected — including fields that would be commercially interesting later.
04
Residency and recovery are decided in the open
Where data is held, in which jurisdiction, and where it fails over to are questions that affect a Fijian consumer's rights. They are settled with legal advice and stated, not left implicit in an infrastructure diagram.
05
Errors are corrected on the record
A material correction to a published document or to this site is dated and visible. Silent edits to a claim that turned out to be wrong are a form of misrepresentation.
Security posture
What is true today
No production system in this portfolio is live, and none holds consumer data. Security work to date is architectural: threat modelling, access control design, encryption and key management design, residency and disaster recovery planning, and audit logging requirements.
We hold no security certification. Where a certification such as ISO 27001 or SOC 2 becomes a requirement of a counterparty or a regulator, it will be obtained and evidenced — and only claimed once it is held.
Independent technical review is welcome. We would rather have a design torn apart by a ministry’s security team before it is built than defend it afterwards.
Policy and research work
What has been written
These documents exist. Most are not published openly; they can be shared on request with a relevant ministry, regulator, donor or research body.
Research
Fiji fintech gap analysis
Assessment of gaps in Fiji's financial technology landscape and where infrastructure is missing rather than under-served.
Strategy
Integrated Fiji national strategy
A cross-sector strategy document linking financial, digital and land policy.
Submission
Reserve Bank of Fiji consultation submission
Written response to a Reserve Bank of Fiji consultation.
Submission
National Identity Bill submission
Written submission on Fiji's National Identity legislation.
Submission
Education (Foundational Literacy and Numeracy) Regulations 2026 — drafting submission
A drafted regulatory instrument submitted in connection with Education Act reform.
Policy paper
National Bank of Fiji revival proposal
Proposal examining the case for and structure of a revived state-linked banking function.
Concept note
Viti People's Bank concept note
Concept note and capitalisation model for a community-oriented banking proposition.
Research
Land tenure and informal settlements thesis
Positions informal settlement growth as a tenure problem, and sequences microfinance after tenure security rather than before it.
A written submission is a submission. It does not imply that any recommendation in it was adopted, or that the recipient body endorses this group.