ALPHAX ACADEMY
MASTER DATA PROTECTION & PRIVACY POLICY
Policy Version:
v1.0
Commencement Date:
18 May 2026
Approved By:
Board of Directors, Alphax Academy
Policy Owner:
Data Protection Officer (DPO)
Regulatory Jurisdiction:
Republic of Kenya (Data Protection Act, 2019)
In this document, ‘the School’ means Alphax Academy and includes its management, staff, agents, and authorized third parties acting on its behalf.
  1.  INTRODUCTION
This Data Protection Policy ('Policy') is formally adopted by the School to ensure full compliance with the Data Protection Act, 2019 of Kenya, the Data Protection (General) Regulations, 2021, and the statutory ODPC Guidance Note on Processing Children’s Personal Data. The School is fully committed to safeguarding the foundational rights, privacy, and digital security of its students, parents, staff members, and institutional partners.
  1.  DEFINITIONS
  1.  PRINCIPLES OF DATA PROTECTION
The School mandates that all operational entities process personal data strictly under the following statutory principles:
  1.  LAWFUL BASIS FOR PROCESSING
All institutional processing activities must be grounded in at least one of the following statutory bases:
  1.  PROCESSING OF CHILDREN’S DATA
As an educational institution processing data belonging to minors, the School enforces specialized safeguards aligned with ODPC guidance:
  1.  RIGHTS OF DATA SUBJECTS
The School formally recognizes and upholds the following statutory rights of data subjects under Section 26 of the DPA:
6.1 Statutory Rights Execution Window & Turnaround Protocols

Data subjects or their legal guardians may exercise their rights free of charge by filing an official request to the Data Protection Officer. The School shall acknowledge all requests immediately and complete the formal execution process within thirty (30) calendar days from the date of identity verification.

6.2 Right to Lodge a Formal Complaint with the Regulator

If a data subject feels that the School has not addressed a data privacy concern adequately, they retain the statutory right to file a regulatory appeal directly with the Office of the Data Protection Commissioner (ODPC) via complaints@odpc.go.ke or through www.odpc.go.ke.
  1.  PHOTOGRAPHY AND SOCIAL MEDIA
  1.  DATA RETENTION SCHEDULE
The School enforces an absolute data minimization standard. Internal storage limits are strictly categorized as follows:
  1.  THIRD-PARTY DATA SHARING
The School shall not share, lease, or distribute personal data to third parties unless a valid lawful basis applies. All external data processing entities - including automated school transport trackers, cloud-hosted platform hosts, software-as-a-service providers, and security vendors - must be legally bound by formal, comprehensive Data Processing Agreements (DPAs) executed in compliance with Section 42 of the Data Protection Act.
  1.  INTERNATIONAL DATA TRANSFERS & LOCALIZATION
In accordance with the Data Protection (Relations) Regulations, the School ensures that core identity and health processing systems reside within localized servers inside the Republic of Kenya. Cross-border transfers (e.g., foreign curriculum management like IGCSE/IB platforms, or core system providers like Google Workspace or Microsoft 365) shall only be executed if the destination jurisdiction guarantees adequate regulatory oversight or the vendor satisfies approved Standard Contractual Clauses (SCCs) endorsed by the ODPC.
  1.  DATA BREACH MANAGEMENT & NOTIFICATION TIMELINES
  1.  PHYSICAL, TECHNICAL, AND ORGANIZATIONAL SAFEGUARDS
The School implements rigorous multi-layered defense controls to preserve the integrity of personal records:
  1.  INSTITUTIONAL GOVERNANCE & EXECUTION CONTACTS
  1.  DATA PROTECTION OFFICER (DPO) CONTACTS
For any inquiries regarding this policy, to exercise your statutory data subject rights, or to submit formal compliance queries, please reach out directly to our designated compliance desk: