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Introduction
Purpose and Scope The African Higher Education in Emergencies Network (AHEEN) is a nonprofit initiative dedicated to delivering academic diplomas, degrees, and employability-focused programs to refugees and internally displaced persons (IDPs) across Africa. Ho...
Data Protection Principles
AHEEN adheres to core principles from the DPA, UoN policies, and ICRC handbook, adapted for humanitarian education. Principle Description Application to AHEEN Lawfulness, Fairness, and Transparency Processing must have a legal basis (e.g., consent, vita...
Roles and Responsibilities
Data Protection Officer (DPO): Oversees compliance; reports to UoN's DPO (contact: dataprotection@uonbi.ac.ke). Conducts DPIAs and training. Staff/Volunteers: Handle data securely; report incidents immediately. Managers: Ensure team adherence; approve data sh...
Data Classification
Classify data to determine handling: Classification Examples Handling Requirements Public Aggregated program reports (no identifiers). Minimal protection; share freely. Internal General operational emails. Access limited to AHEEN staff. Confidential...
Data Lifecycle Management
Collection Obtain explicit consent where possible; use vital interests/public interest in emergencies. Provide privacy notices at collection (e.g., via intake forms). Minimize: Collect only essentials (e.g., name, emergency context for enrollment). Processin...
Cloud Storage
Cloud services enable scalable storage for AHEEN's distributed programs but introduce risks like data sovereignty and access by foreign governments (e.g., US CLOUD Act). Guidelines Approved Providers: Use UoN-vetted services (e.g., Microsoft Azure with Kenyan...
Storage on Private PCs (BYOD Policy)
Personal devices (laptops, mobiles) are common in field operations but pose risks like loss/theft in emergencies. Guidelines Approval: Register devices with IT; use only for AHEEN work. Security Measures: Full-disk encryption (e.g., BitLocker/FileVault). MFA...
Use of AI
[TBD] Use of AI for analysis. OpenSources etc
Risk Assessments
Conduct DPIAs for high-risk activities (e.g., biometric enrollment): Identify risks (e.g., data leakage in refugee camps). Assess impacts on vulnerable groups. Mitigate via minimization/proportionality. Review annually or post-incident.
Data Sharing
Legal Basis: Consent, contract, or public interest (e.g., sharing with partners for degree validation). Humanitarian Contexts: Balance urgency with "do no harm"; use aggregated data for reports. Third-Party Sharing: No sharing without a Data Processing Agree...
Incident Response
Follow UoN/DPA protocols: Detection: Monitor for breaches (e.g., unauthorized access). Containment: Isolate affected systems; notify DPO within 1 hour. Assessment: Evaluate scope/impact. Notification: Report to ODPC within 72 hours if high-risk; inform subjec...
Training and Awareness
Mandatory annual training on principles, tools (e.g., encryption). Field-specific modules for emergency contexts (e.g., data risks in camps). Awareness campaigns: Posters/notices in multiple languages.
Compliance and Auditing
Internal audits quarterly; external every 2 years. DPO reports to AHEEN Board/UoN. Violations: Disciplinary action per UoN code.
References and Appendices
Kenya Data Protection Act, 2019 University of Nairobi - Data Privacy Policy Approved 02022024 V1.pdf ICRC Handbook on Data Protection in Humanitarian Action Appendix A: DPIA Template Appendix B: Data Processing Agreement Sample For queries, contact AHEEN DPO...
AHEEN Data Protection
Quick Do's & Don'ts Guide 🌟 For All Members (Staff, Volunteers, Partners) 🌟Protecting vulnerable students & beneficiaries in emergencies – "Do No Harm" principle. Follow Kenya DPA & UoN policies.Questions? Contact DPO: dataprotection@aheen.netLast Updated: Nov...
General DPIA Checklist
Version: 1.0 | Last Updated: 11 November 2025 Purpose: This checklist guides AHEEN staff in conducting DPIAs for high-risk data processing (e.g., biometric enrollment, cloud sharing in emergencies). Required under Kenya DPA Section 31 and ICRC Handbook (Ch. 3)...
Physical Device Security Checklist
Version: 1.0 | Last Updated: November 11, 2025 Purpose: This checklist ensures staff, volunteers, and partners secure physical devices (e.g., laptops, mobiles, USBs) handling personal data (e.g., student records) in emergency contexts. Complies with Kenya DPA ...
Why an AHEEN Safeguarding Framework?
AHEEN is a whole-of-society network that promotes access, retention, and completion of Higher Education degrees by forcibly displaced youth, with a strong employability focus. Safeguarding is not a compliance exercise; it is an enabling condition that underpin...