DATA PRIVACY STATEMENT – AUGUST 2024
Policy Statement
In compliance with the Data Protection Act of 2019, Anglican Development Services North Rift Region (ADSNRR) is committed to protecting the fundamental human right to privacy. ADSNRR respects the personal information and data we collect from you through the different mediums. This Privacy Statement, applies to personal data that ADSNRR collects and handles for the purposes of maintaining and providing ADSNRR related information to the vis. For the purposes of this Privacy Statement, “Personal data” means any information relating to an identified or identifiable natural person.
Who we are.
ADSNRR of P.O Box 6495-30100 is a licensed data controller and processor by the Office of the Data Protection Commissioner (ODPC) in respect of personal data it receives in connection with the services provided under the relevant engagement with its customers.
What Personal Data Do We Collect About You?
As a Data Controller and a Data Processor, ADSNRR collects personal data directly from the Data Subject or indirectly through intermediaries, service providers and other third parties. We may collect the following personal information.
The above list is not exhaustive, and ADSNRR may collect additional personal data in the course of our interactions with you.
Where We Collect Personal Information
We use Personal Information to carry out our day-to-day activities. The purposes for which we use your Personal Information will differ based on our relationship (i.e. Employees, Partners, Board of Directors, project participants, etc.) including the type of communications between us and the services we provide.
We collect Personal Data from various sources, including:
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Individuals and their family members, online or by telephone, or in written correspondence
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Individuals’ former employers’ when conducting due diligence and reference checks
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Individual’s staff particulars forms
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Individual’s welfare membership forms
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Project Participants master list
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Individual’s pension claim forms
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Individual employment contracts
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Individuals job application documents
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Individual’s consent forms
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Our website (www.adsnorthrift.org)
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Meeting attendance list
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Social Media applications and/or tools
How we collect Data
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Direct Interactions: When you provide data to us in person, through forms, or via our website.
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Third parties: We may receive data from partners, government bodies, banks or other organizations with whom we collaborate with
Use of Your Personal Data
ADSNRR may use your personal data for the following purposes.
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Monitoring and Evaluation purposes, to assess the impact of our programs and improve service delivery.
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Employee Due Diligence (EDD)
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Fulfilling donor/partner requirements
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Communicating with partners/donors, project participants, stakeholders e.t.c.
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Fulfilling regulatory requirements such as Filing Reports with various regulators such as Office of the Data Protection Commissioner (ODPC), Retirements Benefits Authority (RBA) e.t.c
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Responding to feedback, queries and complaints that you submit through our feedback mechanisms.
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Facilitating business operations including information technology systems.
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Providing information through communication channels such as email, texts, and other platforms
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Filling returns for Board of Directors
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Payroll preparation
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Compliance purposes e.g. Filling of company returns, NHIF, NSSF, Housing Levy
Legal Justification for Our Use of Personal Data
The primary purpose for collecting and processing your personal data is to perform contractual and statutory tasks related to management of the services we are offering you. We will also process your data in connection with other tasks as required by law and statutory regulations. We commit to always identify and document without prejudice the lawful basis of processing your personal data for each specific purpose and put necessary security measures to ensure safeguarding of your personal data and the lawful purpose consented to, always applies.
How We Store and Protect Your Data
We have put in place appropriate physical, legal, technical and organization safeguards to protect the personal data we collect in connection with our services. Such measures include but are not limited to requiring confidentiality from employees and other persons authorize to handle personal data and implementing information technology security measures such as system rights, audit trails and firewalls.
You should be aware that the Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. We do not accept responsibility or liability for the confidentiality, security or integrity of your Personal Data in connection with its transmission over the Internet.
Disclosure of Personal Data.
ADSNRR undertakes to keep your personal data confidential and where it is necessary to satisfy the purpose for which it was collected or as may be required by law ADSNRR will share your data with third parties. In connection with the purposes described above we sometimes need to share your Personal Information with third parties. Please note that in addition to the disclosures that we have explained in this statement, we may disclose Personal Data for the purposes we explain in this Privacy Statement to service providers, contractors, agents that perform activities on our behalf.
ADSNRR shall not disclose your personal information to any third parties such as service providers other than with your prior consent, for a legitimate reason or for the performance of a contract.
Consent
In order to facilitate the provision of our services including payroll preparation, submission of insurance claims, preparation of reports, preparation of success stories, documenting project participants master list among others, we rely on the data subject’s consent to process personal sensitive information, such as pictures, identification numbers, date of birth, details of spouses and children, medical records e.t.c. This consent allows us to share the information with other service providers, partners, donors, stakeholders to mention but a few that may need to process the information in order to undertake their role.
The affected individual’s consent to this processing of personal information is a necessary condition for ADSNRR to be able to provide the services the client requests. Where you are providing us with information about a person other than yourself, you agree to notify them of our use of their Personal Data and to obtain such consent for us.
Individuals may withdraw their consent in writing to such processing at any time. However, doing so may prevent ADSNRR from continuing to provide the services. In addition, if an individual withdraws consent to processing of their Personal Data, it may not be possible for the ADSNRR services to continue.
Transfer of Your Personal Data
ADSNRR may transfer your personal information for the purpose of effecting/implementing, administering, and securing services that you have applied for or for other purpose set out in this privacy statement. We may transfer or disclose the personal data we collect to regulatory, or supervisory authority, third party contractors, subcontractors, and/or their subsidiaries and affiliates who provides support to ADSNRR in providing its services. The third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by ADSNRR, and to flow those same obligations down to their sub-processors.
Cross-border Transmission of Your Personal Data
Your data is primarily stored in our data centers located within the country where you are located. From time to time, we may need to transfer your personal information outside the country. This includes countries that do not have laws that provide specific protection to your personal data.
Where we send your information outside the country, we will make sure that there is proof of adequate data protection safeguards in the recipient country or consent from you on transfer of your personal information. Prior to transferring personal data outside the country, we shall ascertain that the transfer is based on the provided legal and regulatory standards.
Retention of Personal Data
Personal Data is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. Retention periods may differ depending on the data in question and the provision of retention policy in place.
ADSNRR may also retain your contact information for the purposes of reaching out to you for pension claim updates, post project evaluations, future job vacancies e.t.c
You are responsible for the confidentiality of any password you have put in place to allow you to access machines, services and products.
Your Data Protection Rights
We will collect, process and store your personal data in accordance with your rights under the Data Protection Act and attendant Regulations. Under certain circumstances, you have the following rights in relation to your personal data:
In exercising your right as provided above, we may request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Enforcing Your Rights
If you wish to enforce any of your rights as highlighted above as provided under the Data Protection Act 2019 and attendant Regulations, then please contact us.
Complaints and Feedback Contact Information
If you feel we have not complied with your right to privacy and other provided rights regarding your personal data, you have a right to complain to us through: complaints@adsnorthrift.org or call our Toll Free Line: 0800720603 or you may pay us a visit at our site offices in Nandi, West Pokot, Turkana, Elgeyo Marakwet and our Head Office in Eldoret where you can drop in your complaints in our complaints boxes stationed in the said offices. You however have the right to contact the Office of the Data Commissioner or such other data supervisory authority in the jurisdiction we operate in.
Cookies
Cookies are small text files which are stored on your computer when you visit certain web pages. ADSNRR may use cookies and similar technologies on our websites and apps, and in our emails. When you return to the website or app, or visit websites and apps that use the same cookies, they recognize these cookies and your device.
We use cookies to do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your online experience. We also use cookies in some of our emails to help us understand how you interact with our emails, and to help us improve our future email communications.
Changes to This Data Privacy Statement
ADSNRR reserves the right to change the provisions of this Privacy Statement at any time. Where the changes will have a fundamental impact on the nature of the processing of your data or your rights, we shall notify you in advance. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Statement.
Your use of the Website and applications following the posting of such revised Statement shall constitute your acceptance of any such changes. We encourage you to review our Privacy Statement whenever you visit the Website and application(s) to guarantee your understanding of how your information may be collected, processed and used.
Rights of Data Subjects and Obligations of Data Controllers/Processors under the Act