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Privacy Policy

Effective 7 October 2026 · Last reviewed October 2026

Privacy Policy & Data Protection Notice

Data Controller(s)
Graceworld Impact Alliance (“GIA”) & Member Entities
Effective Date
7th October, 2026
Last Reviewed
October, 2026
Phone
+254 783 400 300

1. Introduction & Statutory Framework

Graceworld Impact Alliance (“GIA”, “the Alliance”, “we”, “us” or “our”) is a multi-stakeholder collaborative platform and coalition comprising partner organizations, civil society actors, non-governmental entities, and institutional allies dedicated to advancing community empowerment, sustainable development, and humanitarian interventions across Kenya and the broader region..

This Privacy Policy and Data Protection Notice (“Notice”) applies across the entire Alliance ecosystem, including Grace World Foundation and participating alliance member organizations, outlining how we collect, process, store, transfer and protect your Personal Data in compliance with: -

1.1. The Data Protection Act, 2019 (Act No. 24 of 2019, Laws of Kenya) (the “DPA”).

1.2. The Data Protection (General) Regulations, 2021.

1.3. The Data Protection (Registration of Data Controllers and Data Processors) Regulations, 2021.

1.4. The Data Protection (Complaints Handling Procedure and Enforcement) Regulations, 2021.

1.5. International data protection laws and regional frameworks, including the General Data Protection Regulation (GDPR), where regional partners, cross-border coalition activities or international donors are involved.

This Policy applies to all beneficiaries, donors, coalition partners, alliance members, job applicants, staff, volunteers, suppliers, website visitors and stakeholders who interact with GIA and its participating network entities.

2. Key Definitions

2.1. “Alliance Member / Partner Entity”: Any legally established organization, institution, or NGO that has formally joined or partnered with Graceworld Impact Alliance to execute joint humanitarian, development or advocacy programs.

2.2. “Joint Data Controllers”: Two or more Data Controllers who jointly determine the legal purposes and operational means of processing personal data within coalition projects, joint initiatives or shared databases.

2.3. “Personal Data”: Any information relating to an identified or identifiable natural person (“Data Subject”).

2.4. “Sensitive Personal Data”: Personal data revealing a natural person’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of a person’s children, parents, spouse or spouses or sex life.

2.5. “Data Controller”: A natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purpose and means of processing personal data.

2.6. “Data Processor”: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Data Controller.

2.7. “Data Subject”: An identified or identifiable living individual who is the subject of personal data.

3. Principles of Data Protection

3.1. Lawfulness, Fairness and Transparency: Collected lawfully, fairly, and in a transparent manner.

3.2. Purpose Limitation: Collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes.

3.3. Data Minimization: Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

3.4. Accuracy: Accurate and, where necessary, kept up to date.

3.5. Storage Limitation: Kept in a form which permits identification of data subjects for no longer than is necessary.

3.6. Integrity and Confidentiality: Processed using appropriate technical and organizational safeguards against unauthorized or unlawful processing, accidental loss, destruction or damage.

3.7. International Transfers: Transferred outside Kenya only where adequate data protection safeguards or consent exist.

4. What Personal Data We Collect & How We Collect It

4.1. Program Beneficiaries & Community Members

4.1.1. Identity Data: Full name, national identification number, birth certificate number, date of birth, age and gender.

4.1.2. Contact Data: Physical location/address, county, sub-county, village, phone number and email address.

4.1.3. Socio-Economic & Household Data: Household size, income level, educational background, vulnerable status and dependent details.

4.1.4. Sensitive Personal Data (where necessary for targeted aid): Health status/medical records (for medical camps and health initiatives), nutrition status, family/marital background or specific vulnerability metrics.

4.2. Donors, Grantors & Strategic Partners

4.2.1. Identity & Corporate Data: Individual/entity name, tax identification numbers, official position and organization structure.

4.2.2. Financial & Transaction Data: Mobile money (M-Pesa) numbers, bank account details, transaction reference numbers, donation history and grant agreements.

4.3. Job Applicants, Volunteers & Staff

4.3.1. Professional & Educational Data: CVs/Resumes, academic transcripts, professional qualifications, work experience, cover letters, references and police clearance/certificate of good conduct.

4.3.2. HR Data: KRA PIN, NSSF, SHIF/NHIF numbers, Next of Kin / Emergency Contact details and banking details for payroll.

4.4. Website Visitors & Digital Interactions

4.4.1. Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system and platform.

4.4.2. Usage Data: Information on how you use our website, pages viewed, page response times, and clickstream patterns via cookies and analytical tools.

5. Lawful Bases for Data Processing

5.1. Consent: Where you have given explicit, informed and unambiguous consent.

5.2. Performance of a Contract: Processing necessary data for executing or performing an agreement (including Alliance Membership Agreements, Joint Operating Agreements, grant agreements or employment contracts).

5.3. Legal Obligation: Compliance with statutory duties under the law.

5.4. Vital Interests: Protecting the vital interests or safety of data subjects or third parties during emergency relief, disaster response or humanitarian interventions.

5.5. Public Interest: Execution of humanitarian functions and community development carrying significant public benefit.

5.6. Legitimate Interests: Necessary for our legitimate interests (such as joint Alliance monitoring, cross-organizational impact evaluations, donor reporting, platform security and fraud prevention) where not overridden by your fundamental rights.

6. Processing of Sensitive Data & Children's Data

6.1. Sensitive Personal Data

GIA enforces heightened safeguards for Sensitive Personal Data under the DPA. We only collect health data, family information or social vulnerability metrics when strictly necessary for targeted health camps, nutrition distribution, psychosocial support or WASH interventions, subject to explicit consent or vital public interest.

6.2. Children’s Data (Protection of Minors)

Account registration on GIA Connect is restricted to individuals aged 18 and older. Any personal data relating to minors processed by the Foundation is strictly collected offline or through authorized parents/guardians for community beneficiary programs.

7. How We Use Your Data

7.1. Joint Program Implementation: Delivery of regional and community food security, educational bursaries, WASH initiatives, livelihoods training, and healthcare outreach across Alliance member operations.

7.2. Alliance Monitoring, Evaluation, Accountability and Learning (MEAL): Measuring aggregated coalition impact, auditing cross-partner operational efficacy and ensuring institutional accountability.

7.3. Donor & Statutory Reporting: Aggregating anonymized data for grant reporting, regulatory submissions to relevant supervisory bodies and internal audits.

7.4. Fundraising, Advocacy & Alliance Communications: Processing donations, issuing tax receipts, acknowledging support, coordinating coalition campaigns and sending updates (where consented to).

7.5. Human Resources, Volunteer Roster & Network Directory: Assessing recruitment applications, executing employment terms, managing payroll and maintaining the Alliance expert and volunteer rosters.

7.6. Regulatory Compliance & Dispute Resolution: Addressing legal claims, audits, fraud detection and regulatory obligations.

8. Data Sharing, Disclosures & Cross-Border Transfers

8.1. Data Sharing

GIA does NOT sell, rent or trade personal data. We may share personal data under strictly governed Data Processing Agreements (DPAs) or Inter-Entity Data Sharing Frameworks with: -

8.1.1. Alliance Member Entities & Joint Controllers: Where programs are jointly executed, partner entities process data under binding Joint Data Controller Agreements that bind all parties to equivalent protection standards under the DPA.

8.1.2. Authorized Service Providers & Data Processors: Cloud hosting providers, IT support, payment processors and external audit firms.

8.1.3. Government & Regulatory Authorities: The Office of the Data Protection Commissioner (ODPC), NGO Co-ordination Board, Kenya Revenue Authority (KRA) or law enforcement agencies when compelled by valid legal processes.

8.1.4. Institutional Donors & Partners: Aggregated, anonymized or pseudonymized impact assessment reports.

8.2. Cross-Border Data Transfers

Where personal data is transferred, hosted or accessed by Alliance partner offices outside Kenya, GWF ensures full compliance with the DPA by verifying that: -

8.2.1. The destination jurisdiction maintains adequate data protection laws comparable to Kenya’s DPA.

8.2.2. Standard Contractual Clauses (SCCs), Inter-Alliance Data Transfer Agreements or binding corporate rules approved by the ODPC are executed with the recipient.

8.2.3. Explicit consent is obtained from the Data Subject after disclosure of potential risks, where applicable.

9. Data Storage, Security Measures & Retention

9.1. Security Measures

GIA implements robust organizational, physical and technical measures to protect personal data against unauthorized access, loss, alteration or disclosure, including: -

9.1.1. Technical Safeguards: End-to-end encryption of sensitive data at rest and in transit, multi-factor authentication (MFA), strict access controls and regular system vulnerability scans.

9.1.2. Organizational Safeguards: Mandatory staff and partner organization training on data protection, execution of non-disclosure agreements (NDAs), regular data audits and role-based access restrictions across shared Alliance software systems..

9.1.3. Physical Safeguards: Locked physical filing cabinets for paper records, secure access protocols for server rooms and clean desk policies.

9.2. Data Retention

Personal data is retained only for as long as necessary to fulfill the operational purposes for which it was collected, or to meet statutory, tax, legal and accounting requirements: -

9.2.1. Beneficiary Program Data: Retained for the duration of the project plus 7 years for MEAL auditing and statutory compliance.

9.2.2. Financial & Donor Records: Retained for 7 years in accordance with tax and accounting legislation.

9.2.3. Job Application Records (Unsuccessful): Retained for up to 12 months for prospective talent recruitment, subject to consent or immediately purged upon request.

9.2.4. Employee Records: Retained for 7 years post-termination of employment in compliance with Labor Laws.

Upon expiration of the applicable retention period, data is securely destroyed, permanently deleted or irreversibly anonymized.

9.3. Your Rights as a Data Subject

9.3.1. Right to Information: To be informed of the use to which your personal data is to be put.

9.3.2. Right of Access: To access your personal data in our custody and request copies.

9.3.3. Right to Object: To object to the processing of all or part of your personal data.

9.3.4. Right to Rectification: To request correction or updating of false, misleading or outdated personal data.

9.3.5. Right to Erasure: To request the deletion or destruction of personal data that is irrelevant, excessive or unlawfully obtained, subject to statutory retention exceptions.

9.3.6. Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format or request its transfer to another controller.

9.3.7. Automated Decision-Making: Right not to be subject to a decision based solely on automated processing that produces legal or significant effects.

10. How to Exercise Your Rights

To exercise any of these rights, please submit a written request to our Data Protection Officer (DPO) at info@graceworldimpact.org / info@graceworldfoundation.africa. GIA will verify your identity and respond to your request within fourteen (14) calendar days, as required by law.

11. Media, Photography & Filming Notice

During community programs, field visits, medical camps, alliance launches, multi-partner summits and public events, GIA representatives may capture photographs, audio and video footage for documentation, donor reporting and awareness creation.

11.1. Explicit Consent: Photos or videos identifying beneficiaries, especially children, vulnerable individuals or sensitive health settings, are taken and published only with signed/thumb-printed media consent forms.

11.2. Withdrawal: You retain the right to withdraw media consent at any point, after which GIA and its member entities will cease further publication of the relevant media across digital platforms.

12. Direct Marketing & Cookies

12.1. Direct Marketing: We will only send you newsletters, alliance updates, event invitations or joint fundraising campaign notices if you have explicitly opted in. You can opt out at any time by clicking the "Unsubscribe" link in our emails.

12.2. Cookies Policy: Our website uses cookies to enhance browsing experience and analyze web traffic. You can manage your cookie preferences through your browser settings.

13. Data Breach Notification Management

In the event of a personal data breach that poses a risk to the rights and freedoms of data subjects occurring within GIA systems or any participating Alliance member entity, GIA will: -

13.1. Notify the Office of the Data Protection Commissioner (ODPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with the DPA.

13.2. Communicate the breach in writing to the affected Data Subject(s) without undue delay, outlining the nature of the breach, potential consequences and corrective actions taken.

14. Amendments to This Notice

GIA reserves the right to review and update this Privacy Policy periodically to reflect operational changes, alliance expansion, statutory amendments or legal precedents. Updated versions will be published on our website with a revised "Effective Date".

15. Enquiries & Complaints

15.1. If you have questions, concerns or wish to lodge a complaint regarding GIA’s or any member entity’sprocessing of your personal data, please contact us first: -

Data Protection Officer (DPO)

Graceworld Impact Alliance

CR Group HQ, 2nd Mugumoini Drive, House No. 11, Garden Estate

P.O. Box 6848-00100, Nairobi, Kenya

Email: info@graceworldimpact.org / info@graceworldfoundation.africa

Telephone: +254 783 400 300

15.2. If you are unsatisfied with our response, you retain the statutory right to lodge a complaint directly with the regulator: -

Office of the Data Protection Commissioner (ODPC)

14th Floor, Britam Tower, Hospital Road, Upper Hill

P.O. Box 30920 - 00100, Nairobi, Kenya

Email: info@odpc.go.ke / complaints@odpc.go.ke

Website: www.odpc.go.ke