en English
ar Arabiczh-CN Chinese (Simplified)nl Dutchen Englishfr Frenchde Germanit Italianpt Portugueseru Russianes Spanish
follow me on facebook follow me on twitter follow me on youtube follow me on linkedin
Membership | Get involved | Tenders | Jobs | Contact us |
Donations

DATA PRIVACY & PROTECTION POLICY

Date of Revision Two years after approval
Policy Owner Chief Executive / Operating Officer
Status Public
Next Review Date Bi-Annually

Version Control

Draft Submitted   Revision Summary Approved
Version 1 DPO 16 May 2023 New Policy  
         

1. Data Protection & Privacy Policy

This policy document sets out how KeNAAM collects, stores, and uses the personal data you share with us. It describes the information we collect, how long we will retain it for, who will have access to it and your rights, such as your right to access the information we hold about you. When designing and executing our research, it is our policy to take all necessary steps to ensure that personal information you provide is processed fairly and lawfully.

2. Policy Summary

2.1       Please read our policy setting out how KeNAAM collects, stores and uses the personal    information you share with us. It describes what information we collect, how long we will   retain it for, who will have access to it and your rights. This is a summary of the policy:

2.2       We collect personal information when you join us as family members, including you, your family member and other members of your immediate family.

2.3       We collect personal information when you participate in our surveys eg names, telephone numbers, location, address, email address national identification numbers etc.

2.4       We collect information about our survey participants to enable us and our partners design community and public health interventions needed to overcome barriers to healthier lives for the benefit of your community.

2.5        You may also give us your permission to contact you separately about topics related to community and public health.

2.6       We only collect the information we need to provide the best possible service to our survey participants. Information you provide may also benefit other survey families.

2.7       We protect the security of the data you provide us, including using the latest encryption technologies and secure backups. Our IT contractors have robust policies in place and we                       would be happy to share these with you on request.

2.8       We will never sell or otherwise share your personal data with third parties for marketing purposes. Personal (i.e. identifiable), data would only be shared for other purposes if we were required by law to do so or we had your explicit, express consent. Any third parties we work with are contracted to keep your data secure and treat it in the strictest confidence, using the latest security.

2.9       We use the data we hold on family members and their effects in anonymous format to research and design community health interventions / recommendations, provide support and information and raising awareness of malaria to our survey participants.

2.10      Only designated staff members can access to the personal information.

2.11      You have a number of rights, including the right to access the data we hold about you and the right to ask us to delete all data we hold about you at any time.

2.12      We may change this policy from time to time, e.g., to reflect changes in the law or guidelines from appropriate regulators. Please check our website (kenaam.org) regularly for details of any changes

Full Data Protection & Privacy Policy

1.    Who We are

    • 1.1  KeNAAM is a network of non-state actors working towards preventing, controlling, and reducing the high death rate as a result of malaria. It was founded in 2001, prompted by the realization that the fight against malaria required concerted effort. In the face of emerging challenges posed by high levels of poverty, KeNAAM has expanded to integrate maternal and child health initiatives in a bid to alleviate suffering.
    •  
    • 1.2  In this policy, ‘we’, ‘us’, ‘our’ or ‘KeNAAM’ refers to KeNAAM and its affiliates (only referred to as KeNAAM); ‘you’ or ‘your’ means any person(s) from or about whom we collect personal information/data. Personal information/data is information that can be used to identify a living individual, for example name, address, telephone number or email address.
    •  
    • 1.3  We take your privacy seriously and adhere to the Principles of the Data Protection Act, 2019 & the Regulations made thereunder together with all relevant Guidelines and Directives. For help and guidance about any aspect of the law relating to privacy and data protection, visit the Office of the Data Protection Commissioner’s website at odpc.go.ke

2.  What information do we collect?

    • 2.1 We collect various different types of personal information:
    •  
    • 2.1.1 When you participate in a KeNAAM household survey:
        • 2.1.1.1        The information we collect about you and your family members include contact details, including your name, address, telephone number, location, email address, date of birth, gender, place of work. It also includes educational and social care correspondence, health, development and behaviour, positive aspects, school attended, work placement. We also collect data on racial/ethnic origin of families joining us. This is an optional question but it helps us to ensure equality of access to our services and to take proactive steps where necessary to attempt to address any disparities.
        •  
        • 2.1.1.1        This information is only collected and stored with your consent, gained when you first provide the data. Your choices relating to your consent for us to store and use your data are stored on our electronic database.
        •  
        • 2.1.1.3        We collect information about our survey participants to enable us and our partners design public health interventions needed to overcome barriers to healthier lives for the benefit of your community. We:
          • 2.1.1.3.1 Identify top public health concerns in your area.
          •  
          • 2.1.1.3.2 Work with the government, its agencies and partners to design interventions to address resource gaps in your community.
          •  
          • 2.1.1.3.3 Educate you on the benefits of preventive and healthy behaviors to facilitate life changes.
          •  
          •  
          • 2.1.1.3.4 Help you gain access to resources.
          •  
          • 2.1.1.3.5 Advocate for improved care for at risk populations to county and state policy makers.
          •  
          • 2.1.1.3.6 Work with other community agencies to address community unique characteristics.
          •  
        • 2.1.1.4 We only collect this information from you if you choose to provide it to us – (consent is our lawful basis for processing these data). You can choose to terminate your participation in our survey or ask us to delete any data at any time by emailing info@kenaam.org.
        •  
        • 2.1.1.5 KeNAAM can continue processing data in special categories such as health information outside of the usual consent requirements, when in the public interest. This means that once we have your consent to process the data you provided us when you joined as KeNAAM survey participants, we will continue to process these data until you tell us otherwise.
        •  
    • 2.1.2 When you browse the KeNAAM website:
      • 2.1.2.1 We collect anonymous, non-personal information about the users of our website. Whenever you access our website or download information, the web server automatically records the following non-personal information: the date and time you accessed our website, how long you were on the site, your Internet domain name and the internet browser you use. This information helps us to improve our website service.
      •  
      • 2.1.2.2 We make use of cookies. A cookie is a series of characters that is generated by our website and stored on your computer when you visit our site. The cookie does not collect or contain personal information about you, but allows us to track how often you return to our site. The cookie does not track your movements on other websites. You do not have to accept our cookie in order to be able to use our website.
      •  
      • 2.1.2.3 Currently we are using Google Analytics to analyze the audience of the website and improve our content. No personal information is collected from Google Analytics. For further information on the privacy policy concerning Google Analytics, please visit: https://policies.google.com/privacy/update?hl=en
      •  
    • 2.1.3 When you are employed by KeNAAM or become a council member/manager/director:
      • 2.1.3.1 We hold personal information about our current and past employees and council members/directors/managers, including name, address, telephone number, email address, date of birth, employment history, bank account information, tax and national insurance and pensions, details of other trusteeships, directorships and declarations of interest
      • 2.1.3.2 This information enables us to meet our legal requirements in relation to employment and take decisions on employee and trustee recruitment and employment, future strategy and to enable us to further our aims.
      •  
    • 2.1.4 When you are engaged as contractor/vendor/service provider who are sole proprietors or partnerships:
      • 2.1.4.1 We hold personal information about contractors/vendors/service providers, including name, address, telephone number, email address, bank account information, tax and declarations of interest.
      •  
      • 2.1.4.2 This information enables us to meet our legal requirements in relation to employment and take decisions on their recruitment and engagement to enable us to further our aims.

3. Legal Basis for Processing Your Data

  • 3.1 Each time we process your data, we must have a ‘Legal Basis’ for doing so. DPA,19 states that in order to collect, store or process different categories of data, organisations who are ‘data controllers’ need to meet one or more of a number of ‘legal bases for processing’ data. This includes Specific, Informed Consent (i.e. where you have given your consent, such as when you participate in our surveys or agree to us contacting you about other relevant topics), Meeting our Legitimate Interests as an NGO (except where this would override your individual rights or interests), Meeting our Legal Requirements (e.g. to maintain accurate financial statements under the Companies Act) and Carrying out the requirements of a Contract
  •  

4. Data Security and Access

  • 4.1 Working with our IT contractors, we have implemented technology and policies to protect your privacy from unauthorised access and improper use. This includes use encryption technology. These are constantly kept under review and will be updated as necessary to comply with legal requirements. Any health information we collect and store is classified as sensitive under the DPA,19 and therefore has a higher level of security.
  •  
  • 4.2 Data provided as part of your KeNAAM survey participation is stored securely on a server in Kenya. Regular back-ups of data are taken at secure facilities, arranged by our IT contractors and also located in the Kenya. Any paper records are stored securely in Kenya.
  •  
  • 4.3 We have a contractual relationship with a provider of bulk email, survey and event registration services and store limited data (email addresses, not health or other sensitive data) on their secure servers located in Kenya to enable us to communicate with you cost effectively.
  •  
  • 4.4 While we cannot absolutely guarantee that loss, misuse or alteration of data will not occur, we use our very best efforts to prevent this.
  •  
  • 4.4 While we cannot absolutely guarantee that loss, misuse or alteration of data will not occur, we use our very best efforts to prevent this.
  •  

5. Who can access your data?

  • 5.1 Our members of staff have access to your basic personal information but only those staff members who require access to carry out their job roles are able to access participant information.
  •  
  • 5.2 We may use third party companies to provide services on our behalf. This could include services such as survey providers and bulk email services, in order that we can conduct our surveys and / or communicate with survey participants and supporters in the most cost-effective way. In these cases, data will be stored on the third parties’ servers and we will ensure that we have undertaken appropriate due diligence and have contracts in place which commit them to high levels of data security and confidentiality.
  •  
  • 5.3 We may also contract with companies or make use of volunteers to provide services including answering customer’s questions’ about products or services, sending postal mail, e-mails and text messages and analysing data. We will only provide those third parties with the information they need to deliver the service and they are prohibited from using it for any other purpose. We require all third parties to treat your personal information as fully confidential and to comply with all applicable UK Data Protection and consumer legislation.
  •  
  • 5.4 We may disclose personal information if required to do so by law or if we have reasonable grounds to believe that such action is necessary to protect and defend the rights, property or personal safety of KeNAAM, our survey participants, any child or vulnerable adult, our staff or any visitor.
  •  
  • 5.5 Except as indicated above we will not use or transfer this data to any third parties without your express permission.
  •  

6. How long do we keep your information?

  • 6.1 We keep your information for only as long as is necessary or until you ask us to erase it. We will contact KeNAAM survey participants periodically to ask you to update us about the data we hold in our database about you and/or your family member. You will receive a copy of the data we hold (using a ‘database form’) and you will be asked to update this. We will erase any data on request.
  •  
  • 6.2 Where you have provided it, we will seek to refresh your consent to contact you about topics outside of your KeNAAM survey participation from time to time. If you do not give consent, we will assume you do not wish to be contacted and will record this electronically and cease communication with you about these topics outside your survey participation. This will not affect your KeNAAM survey participation and providing you with support and information services if you are a survey participant.
  •  
  • 6.3 If you apply for a position with KeNAAM and do not join KeNAAM, we will retain the data you provide, solely for recruitment and will not use it for marketing purposes. It is retained in order that we can answer any queries relating to the recruitment process.
  •  

7. Your Rights

  • 7.1 Under the GDPR, individuals have a number of rights concerning their personal information and we will adhere to these:
    • 7.1.1 You have the right to be informed about how and why we collect, store and use your information. We will do this when we collect your information, e.g. when you join us as survey particpants or when you sign up to receive emails through our website. This Privacy Policy is available on the KeNAAM website or as a hard copy by request.
    •  
    • 7.1.2 You have the right to access the personal information we hold about you. You can request this verbally or in writing and when we receive such a request we will endeavour to respond quickly but within a maximum of one month. This is called a Subject Access Request (SAR) and there is no charge. Following this you have a right to request that any data held about you that you feel is inaccurate is rectified or completed if incomplete. You also have the ‘right to be forgotten’, i.e. for all data we hold about you to be erased and also to require us to restrict or ‘suppress’ how we use your data (you might for example be happy for us to store it but not process it for certain purposes). Again, we will respond as quickly as we can to such requests but within a maximum of one month.
    •  
    • 7.1.3 To make a request, for example to access the information we hold about you, email dpe.dpo@mzizi-africa.com or you can write to us at the address at the end of this policy document.
    •  
    • 7.1.4 For full information about your rights under DPA,19, please visit the Information Office of the Data Protection Commissioner’s website at https://www.odpc.go.ke
    •  
    • 7.1.5 Should you feel unhappy about the ways in which we have collected, stored or processed your data and wish to make a complaint to a supervisory authority, please contact the office of the Information Commissioner https://www.odpc.go.ke
  •  

8. Who has access to your information?

  • 8.1 KeNAAM operates ‘hierarchical’ access to data stored, meaning that only those staff who need to access certain data are able to. For example, only staff requiring access to carry out their roles, e.g. assisting families on our telephone and email helpline, or writing information guides, are able to access the health information provided by KeNAAM survey participants and stored on our database. For security, data is only accessible on a ‘need to know’ basis.
  •  
  • 8.2 This is necessary in order to process the information and to send you the information you have requested. Information submitted by you may be transferred by us to our other offices and to other reputable third party organisations as referred to in this Policy, and these may be situated outside the Kenya.
  •  

9. Do we collect information about children and vulnerable adults?

  • 9.1 Yes, we collect personal and medical information provided to us by survey participants about children or vulnerable adults in their care. We place great importance on the security and accuracy of this information and only store this information in our secure database. Whenever possible, we obtain the consent of the guardian or responsible adult before collecting information about children and/or vulnerable adults. Our staff will make all reasonable attempts to ascertain whether an adult has the necessary capacity to consent to submit their information to us and for us to retain that information on our secure database. Only designated senior members of staff have access to this information.
  •  

10. Links to other websites

  • 10.1 KeNAAM’s website (https://www.kenaam.org/) may contain links to selected websites which we feel may be of interest. Please note that once you use one of these links to leave our website, we do not have any control over that other website. Please exercise caution and refer to their privacy policy and/or terms & conditions of use before providing any personal information as we cannot be held responsible for the protection or privacy of any information you provide to a third party.
  •  

11. Changes to this Policy

  • 11.1 We may make changes to this policy from time to time, for example to update it to reflect changes in the law or guidelines from appropriate regulators. Please check our website (www.kenaam.org) regularly for details of any such changes.
  •  

12. Changes to this Policy

  • 12.1 If you have any questions or concerns about how we protect your personal information, please contact us at.
  •  

The Data Protection Officer
P.O. Box 3336 – 00100
Nairobi – KENYA
Email: dpe.dpo@mzizi-africa.com