Privacy policy

Last updated: TODO — date of publication

This is a draft skeleton. It has not been reviewed by anyone qualified and must not be published in this state. Every TODO needs filling in, and the whole document needs checking against Kenya's Data Protection Act 2019 and Google Play's policies for apps handling children's data.

Who we are

SkoolHub is operated by TODO — registered company name, of TODO — registered address, Kenya. You can reach us at TODO — contact address.

TODO — if you are required to register with the Office of the Data Protection Commissioner as a data controller or processor, say so here and give the registration number.

Who the data belongs to

SkoolHub is used by schools. A school decides what records it keeps about its pupils and who at the school may see them; we hold and process those records on the school's instructions. Where a pupil's records are concerned, the school is responsible for deciding how they are used and we act on its behalf.

What we collect

An email address, which is how you sign in. There are no passwords: we email a six-digit code that is valid once and expires after ten minutes.
A name, so the school knows who you are.
A phone number, where you have given one, so a fee payment prompt can be sent to it.
Records the school keeps about your child — fees and payments, attendance, marks, timetable, and notices the school sends.
Payment records from M-Pesa when a fee is paid, so the school can match the money to the right pupil.

What we do not do

We do not sell personal data, and we do not share it for advertising.
The app contains no advertising and no third-party analytics or tracking.
We do not use this data to build profiles or to train anything.

Who can see a child's records

Each school's data is kept separate from every other school's, and that separation is enforced by the database itself rather than by application settings. Within a school, staff see only what their role allows: a class teacher sees their own class, and staff handling fees do not see registers or marks. A parent sees only the children they are recorded as a guardian of.

Who else the data reaches

Safaricom (M-Pesa), when a fee is paid, so the payment can be taken and matched.
Our email provider, to deliver sign-in codes and fee notices.
TODO — name the hosting provider and where the servers are.

How long we keep it

TODO — a retention period, agreed with the schools. Sign-in codes are deleted or invalidated within ten minutes. A sign-in session on a phone lasts up to 180 days, and a school can end it sooner.

Your rights

Under the Data Protection Act 2019 you may ask for a copy of the personal data we hold about you, ask for it to be corrected, or object to how it is used. Because a school owns its pupils' records, requests about a child are usually answered by the school; ask the school first, and contact us at TODO — contact address if that does not resolve it. You may also complain to the Office of the Data Protection Commissioner.

Keeping it safe

Traffic between the app and our servers is encrypted. Sign-in codes are stored only as a keyed hash and never in a readable form. Access to a school's data requires a valid sign-in, and a school can sign a lost or sold phone out immediately.

Changes

If this policy changes we will update this page and the date at the top.