Participant privacy policy Kenya

We are registered as an NGO under section 10 of the Non-Governmental Organizations Co-ordination Act in Kenya. Our registration number is: OP.218/051/17-033/10709. Our Parent Company is Ripple Effect International who are registered as a Charity in England and Wales, and whose registration number is: 299717

Together with Ripple Effect International we are joint data controllers of the personal data that we hold. We are in the process of registering as a data controller under The Office of the Data Protection Commissioner Kenya. You can find more about Ripple Effect Internationals registration here.

Any data that we collect will be used in accordance with the requirements of The Data Protection Act Kenya 2019 and the UK GDPR Data Protection Act 2018

Any electronic direct marketing communications will be made in accordance with the Privacy and Electronic Communications Regulations (PECR)

If you are a project participant and have any queries about this Notice or how we process your personal information please speak to your local extension officer on their next visit, contact your local Ripple Effect Kenya office, or alternatively you can contact dataprotection@rippleeffect.org to raise any matter with our Data Protection Group

You have the following personal data rights:

• The right to be informed how Personal Data is processed
• The right of access to your Personal Data
• The right to edit and update your personal information
• The right to have your personal information deleted
• The right to restrict processing of your personal information
• The right to object
• The right to lodge a complaint with a supervisory authority

The sections below explain more about how Ripple Effect processes your data in line with your rights as an individual.

We collect the personal information you provide us with as part of your registration on to our project.

The personal information we collect may include:

• Title & Name
• Postal address, email address, telephone number and mobile number
• GPS location data

If we collect any sensitive personal information from you, we will always ask for your consent before doing so. This data could include:

• Property status
• Marital status
• Family details (names of children/spouses or spouses/parents)
• Sex

We may ask you if we can collect further information about why you are working with Ripple Effect Kenya in order to create a case study of your progress. We will always ask your consent before doing this and we will explain how your story will be used.

We also collect and hold information about the contact you make and activities you take part in with Ripple Effect Kenya and this may consist of:

• Training registration/attendance
• Details of correspondence sent to you or received from you
• Responses to surveys you give
• Any other information provided by yourself that is relevant to your relationship with Ripple Effect Kenya

We process the personal information you provide or that we may collect from publicly available sources to support our legitimate interest in delivering Ripple Effect Kenya’s charitable mission. We process data to enable us to administer our projects and to help us build a positive relationship with you and your family.

We hold your address details so that we can visit you and your family to conduct training and project assessments in line with our project objectives.

We collect your stories, including case studies, to help us produce written materials, images and videos to supporters, funders and partners. This allows us to demonstrate the need for the project, the work that we do and the changes those we work with experience. With your permission, your story will be used to help monitor the project progress, and could be featured in reports to our donors, social media posts, publications or our website.

We will only process your data where we have a legal basis to do so. You have a right to object to how we use your data and can change your preferences at any time by contacting us.

Some of the information we keep is stored securely in our local Ripple Effect Kenya office and in some is stored on a secure database held on a server within the EU. We use a number of security measures to protect your data including conditional access policies, multi-factor authentication and permission based access. All our devices are protected with Defender XDR capabilities (extended defence and response) to defend against any malicious programs and cyber attacks. Any transfers of data will happen using encryption in transit as well as at rest.

Whenever we process data, we will always consider your personal rights. You have a right to object to the way that we use your data by contacting us on the details below

It is our policy not to sell, trade or rent your personal information to anyone. We may disclose personal data to data processors carrying out work on our behalf under a Non-Disclosure Agreement. Any such companies are acting as approved data processors for Ripple Effect Kenya, and we retain full responsibility for your personal data. Data processors will act only on our instructions. At this time we do not use any other data processors.

We may also, upon request, disclose to the project donors both personal and special category data, and aggregate statistics, and where we do we will make sure we have your consent to do this and.

Any data transferred outside of Kenya will be done following the regulations of the Kenyan Data Protection Act 2019.

If this is the case we will store your personal data securely on our servers in the EU and under the regulations imposed by the UK GDPR Data protection act 2018. Where this data is to be transferred outside of the European Union we will make sure we have your consent to do this to.

We will keep your personal information on our database for 10 years following the end of the project. We do this to see how you and your community are doing after the project has finished. After 10 years we will either ask for your permission to keep your data longer, or delete it all.

We will keep and potentially use any stories or case studies you have provided us for 6 years. You can ask us at any time to stop using these.

We will ensure that we hold the minimum amount of data to meet the purposes of supporting Ripple Effect Kenya’s charitable mission and we might hold historical data for analysis in an anonymised format so it is no longer linked directly to your personal information.

You can ask us if we are keeping any personal data about you and you can also request to receive a copy of that personal data – this is called a Subject Access Request.

To make a Subject Access Request you will need to provide adequate proof of identity such as a copy of your passport, birth certificate, ID card, or driving license before your request can be processed. Please try to be as clear as possible about the information you are seeking.

Once we have received your Subject Access Request and proof of identity, you will receive a response from us within one month and you will be able to get copies of any information we hold on you. However, exemptions to disclosure may apply in some circumstances.

Subject Access Requests should be sent to your local Ripple Effect Kenya office or dataprotection@rippleeffect.org

Please note that repeated requests for a Subject Access Request could be subject to a small administrative charge to cover our costs.

Please contact your local Ripple Effect Kenya office or dataprotection@rippleeffect.org to make any updates to your information.

Ensuring we have the right personal information is really important to us. If you wish to correct any information about you held by Ripple Effect Kenya, please contact us on the details above

If you want to ask us to stop processing your personal data, we may continue to store your data to meet financial and other requirements. We will retain enough of your personal information to ensure that your request can be respected in the future.

If you want us to delete your data, please note that permanently removing your details means that we cannot guarantee to not contact you as we will no longer hold a record of your request.

We regularly review our privacy practices and this notice, and may make changes from time to time. Any changes made will be posted to this page on our website, and will apply from the time we post them. We will inform you directly of any significant changes.

This privacy notice was last updated on 12/10/2022

We value feedback and you have a right to object to how we process your personal information at any time. If you have a concern, please contact your local Ripple Effect Kenya office or email dataprotection@rippleeffect.org

If you wish to lodge a complaint or seek advice from a supervisory authority, please contact your local supervisory authority on the details below

info@odpc.go.ke

P.O Box 30920-00100

G.P.O Nairobi

0796954269/ 0752896867

https://www.odpc.go.ke

In order to make the Ripple Effect website easier to use and improve our service, we sometimes place small amounts of information on your computer. These are known as cookies and they are used by most major websites. We use cookies, small pieces of data stored inside a website browser, across our websites to improve their performance and to enhance your user experience. When you visit our websites, cookies allow us to collect some non-identifying basic information. This includes the total number of visitors, the pages viewed, and other anonymous information. We use this information to make your experience on our website as smooth as possible and to allow us to make any necessary improvements. Click here to find out more about the different cookies we use.

Necessary cookies 

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided.

Performance cookies

These cookies allow us to analyse how visitors use our websites and to monitor website and campaign performance so that we can provide a high quality experience and determine how effective our campaigns are. We may also use cookies at times to evaluate our ordering process and make it as customer friendly as possible.

Functionality cookies 

Our ordering system is set up to remember what you are purchasing for only one visit. For example, if you are purchasing several gifts, our system will keep track of what you are purchasing while you make your selections. To allow you to keep the items in your basket, we utilise temporary cookies to process your order.

Targeting cookies

These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website so you can be shown more relevant ads. Ripple Effect rarely uses this type of cookie. More detail on how businesses use cookies is available at www.allaboutcookies.org. If you decide you would like to disable cookies on this device, please view our information pages - How to disable cookies. However, please do be aware that some parts of the website will no longer function correctly if you disable cookies.

Emails

To enable us to determine which of our emails are more interesting to our users, Ripple Effect emails may contain a single tracking pixel. This pixel can allow us to see whether emails are opened and also which links people click the most. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, please set your email client to receive plain text emails from us.