Following my previous two articles on the COVID Alert SA app – a deep dive review of the COVID Alert SA app and then, whether technology is the right solution for contact tracing South Africa. Instead of believing all the media hype around the app, let us make an informed decision if COVID-19 contact tracing has failed in South Africa. Also, we will look at if location tracking is still a concern for users of apps developed by corporate companies. 

A screenshot of an actual exposure notification from the COVID Alert SA app

My personal experience with the Android app

The experience was rather mundane. In all the time that I’ve had the COVID Alert SA app installed and running on my phone, no exposure notifications were triggered since installing it in September 2020.

The GAEN (Google/Android Exposure Notifications) framework does all the heavy lifting meaning I wasn’t able to intercept any of the data that was uploaded. The network traffic that I could intercept did not contain any location data. It is impossible to say what the GAEN framework uploads without deeper analysis. Since this component is part of the Google Play Services a separate review of the framework is needed.

The GAEN (Google/Android Exposure Notifications) Framework

Since the deep dive of the app, a new version has since been released. This version 1.4.0 for Android and iOS was released on 19 October 2020. According to the release notes, it includes a Forgot PIN journey, bug fixes and enhancements.

During his address 3 December address to the nation, Cyril Ramaphosa said that there had been 1 million downloads of the COVID Alert SA app to date. The international benchmark for app contact tracing is at least a 60% adoption rate for the app to be effective. Also, South Africa only has 20 – 22 million people who own smartphones, or about ⅓ of the population.

Since the app was built for the Department of Health by Discovery, there is legislation that protects personal information, including location data. Or are there exceptions?

Landing page on the website promoting the app –

FNB App introduces location tracking

Ivo Vegter, journalist and columnist first brought this to attention on social media. I also posed the question to FNB to clarify why the bank introduced location tracking in the latest version of its app.

“The use of location for security is increasingly being employed by many organisations around the world as a valuable tool to protect customers. While we understand your trepidation, we take great care to safeguard your data.”

”The Bank uses the data within a security framework and does not share this data. Our primary concern is ensuring that you have a safe banking experience. Location is simply one additional layer of security that we have added to our award-winning channels. RB”

POPI Act and COVID-19 amendments

According to the Protection of Personal Information Act (POPIA), location information is protected under the act.

However, according to FirstRand Bank, the holding company of FNB, we can read the following in Section 8 of their Privacy Policy:

“Where required, each member of the FirstRand group may share your personal information with the following persons…”

“…regulatory authorities, industry ombudsmen, government departments…”

Turns out, COVID-19 is an exception

According to the Information Regulator of South Africa’s guidance note on the processing of personal information during the COVID-19 pandemic:

5.1 Can Electronic Communication Service Providers process (provide) location-based data to the Government to process (use) for the purpose of tracking data subjects to manage the spread of COVID-19?


Has contact tracing failed in South Africa?

Professor Shabir Madhi of Wits University who leads South Africa’s vaccine trials says contact tracing has never been successful in South Africa even before an app.

“When it comes to tracing, we have never been able to reach a target for that strategy to be successful. Around 75% of close contacts need to be traced, and on average, each person has 120 close contacts. We have never come close to those targets.”

However, Madhi said the app was little more than “wishful thinking” and it is a “false belief that technology is going to save the day”.

Despite being an outspoken critic of contact tracing, he is the lead researcher in South Africa’s COVID-19 vaccine trial. 

Professor Shabir A. Madhi

Why the COVID Alert SA app won’t work in South Africa

In a study done by Dr Isobel Braithwaite and her colleagues at the University College London, the following reasons were given for the failure of automatic contact tracing using an app

  • Requires a large scale uptake of the population
  • Only in support of manual contact tracing
  • Strict compliance with the quarantine advice to reduce transmissions
  • Potential privacy concerns like location tracking
  • Technology can exclude sectors of the population such as the elderly and homeless
  • High level of smartphone ownership

International COVID-19 Travel App

Global airline lobby company IATA is working on a COVID-19 app called “The Travel Pass”.

This group wants to standardise global testing and vaccination records of the virus for all international travellers. A test program is already planned to start this year.

IATA Travel Pass Initiative


The question is not whether the COVID Alert SA app tracks its users. The fact remains that service providers are required by law to hand over location data whether users are explicitly being tracked or not.  

Further reading

FirstRand Group Privacy Policy.

Guidance Note on the Processing of Personal Information in the Management and Containment of COVID-19 Pandemic in Terms of the Protection of Personal Information Act.

COVID-19 Contact Tracing Still a Pipe Dream, says Prof.

Automated and Partly Automated Contact Tracing: A Systemic Review to Inform The Control of COVID-19.

“COVID passports” Could Revive International Travel.

South African COVID-19 Mobile Track and Trace Laws – Should We Be Worried?

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