Privacy Policy

1Who we are

Ebenezer Happy Home runs a children's home, a school and alumni support programmes for vulnerable children and young people on Mfangano Island, Lake Victoria, Kenya.

Policy owner: Board of Management, Ebenezer Happy Home.
Policy custodian: Department of Data Protection & Cybersecurity.

You can contact us about your data at info@ebenezerhappyhome.org. Contact details for our Data Protection Officer will be published here before launch.

2Our commitment

Ebenezer Happy Home is committed to protecting personal and sensitive data in compliance with the Data Protection Act of Kenya (2019). We handle all personal data according to these principles:

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Security and confidentiality

3Information we hold

Through our work we hold:

• Children's personal and case data
• Staff and alumni records
• Health, education and psychosocial information

We treat any personal data about a child's health, education, family, protection status or identity as sensitive data.

4Information collected through this website

We only ask for what we need for each purpose:

• Contact form: your name, email address, subject and message.
• Newsletter: your email address.
• Event registration: your name, email address, phone number (optional), number of people attending and any access needs you share.
• Mission registration: group or organisation name, leader's name, email address, phone number (optional), country, group size, preferred dates, skills offered and any notes.
• Sponsorship request: your name, email address, country and the child reference you choose.
• Donations: your name, email address and gift details. Card and M-Pesa payments are processed by the payment provider, not stored by EHH.

5How we use your information

• To reply to your messages.
• To organise events and mission visits, including safeguarding checks for visitors.
• To set up and manage sponsorships and donations.
• To send news from the home, only if you subscribe. You can unsubscribe at any time.

We do not sell your personal data, and we only use it for the purpose it was collected for.

6Children's information and images

Children's information is never published on this website in a way that identifies them.

• Children waiting for a sponsor are shown by reference code only, never by name.
• Written consent is required before capturing or sharing any child's image or story.
• We do not publish stigmatising, exploitative or identifying content, or any sensitive information about a child.
• Staff, volunteers and alumni may not post content involving children without authorisation.

7Who can access your information

• Access is limited to authorised personnel, using role-based access and strong authentication.
• Payment providers process payments on our behalf.
• Where the law requires, child protection concerns are referred to the relevant government authorities under national child protection case management and referral procedures. Such information is shared on a need-to-know basis only.

8How we protect your information

• Personal data is kept in secure digital and physical storage.
• Our ICT systems are protected under our Cybersecurity Policy, including access control and a ban on unauthorised software and devices.
• All data breaches must be reported immediately, and we follow our incident response procedures: isolation, investigation and recovery.

9How long we keep your information

We keep personal data only for as long as it is needed for the purpose it was collected for, or as required by law. EHH will publish specific retention periods for each type of record before launch.

10Artificial intelligence

Our AI Use & Emerging Technologies Policy requires human oversight, transparency, and child safety and dignity. We do not:

• Use AI to monitor or watch children.
• Make automated decisions affecting a child's welfare without human oversight.
• Upload sensitive child data into public AI platforms.

11Your rights

Under the Data Protection Act, 2019 you have the right to:

• Be informed about how your personal data is used.
• Access the personal data we hold about you.
• Object to the processing of all or part of your personal data.
• Have false or misleading data corrected.
• Have false or misleading data deleted.
• Withdraw your consent at any time, where we rely on consent.

To use these rights, email info@ebenezerhappyhome.org. If you are unhappy with how we handle your data, you can complain to the Office of the Data Protection Commissioner (ODPC) in Kenya.

12Cookies

See our Cookie Policy for how this website uses cookies and similar technologies.

13Review of this policy

This policy is reviewed every two (2) years, or sooner if the law requires. Non-compliance by staff, volunteers or partners leads to disciplinary and legal action.