Learner Data & Children's Privacy Policy
Effective Date: 1 October 2026
Many GISE Africa learners, especially on our O-Level and A-Level courses, are under 18. This policy adds to our Privacy Policy. It explains how Global Institute For Skills And Excellence Africa ("GISE Africa," "we," "us," or "our") handles learners' educational records, and what extra protections apply to children.
Under the Kenya Data Protection Act, 2019, a "child" is anyone under 18. Section 33 of the Act says a child's personal data may be processed only with the consent of a parent or guardian, and only in a way that protects the child's rights and best interests.
1. Parent and Guardian Consent
- A learner under 18 may use the Services only with the consent of a parent or guardian.
- A parent or guardian can create the account for the learner or register them for a cohort, or can give consent when the learner signs up.
- By registering a learner under 18, or paying for their place, the parent or guardian confirms that they consent to the processing described in this policy.
- We may contact the parent or guardian to confirm their consent. If we find that a child has an account without it, we will suspend the account until consent is given, or delete it.
2. What We Collect About Learners
We collect only what is needed to teach, assess and support a learner:
- Identity and contact details: name, email address, phone number and, for children, the parent or guardian's contact details
- Registration details: course, cohort, and any licences chosen
- Learning records: lessons completed, module progress, quiz and exam answers, scores, results and certificates
- Communications: messages with our team and in-app notifications
We do not ask learners for national ID numbers, health information, or other sensitive personal data. Please do not include such information in exam answers, projects or messages.
3. How We Use Learner Data
Learner data is used only for education, to:
- deliver lessons and unlock modules as the learner progresses
- mark quizzes and exams and give feedback
- let the learner's mentors and our academic staff support them
- issue certificates and confirm them when asked
- keep parents or guardians informed where the learner is under 18
- improve our courses, using aggregated or anonymised information wherever possible
We never:
- sell learner data or share it with advertisers
- show targeted advertising to learners
- build profiles of learners for anything other than their learning
- publish a child's name, photo, results or work without a parent or guardian's consent
4. Who Can See Learner Records
| Who | What they can see |
|---|---|
| The learner | Their own profile, progress, results and certificates |
| Parent or guardian (under-18 learners) | On request: the learner's registration, progress and results |
| The cohort's mentors | The learner's name and their progress and results in that cohort, to teach and support them |
| GISE Africa administrators | What their role needs to run courses, handle payments and support learners. Administrator actions are logged. |
Mentors are approved only after we check their identity and qualifications (see the Mentor Policy). Mentors may use learner information only to teach that cohort.
5. Safeguarding
- Mentors must communicate with learners only through GISE Africa's channels, or through channels we have approved for the cohort.
- Mentors must not ask learners under 18 for personal contact details, photos or meetings outside the course.
- For physical cohorts, teaching takes place at the published venue during scheduled sessions.
- Report any concern about a learner's safety or a mentor's conduct to [email protected] with the subject "Safeguarding". We treat these reports as urgent and confidential.
6. Retention
Learning records are kept while the learner's account is open. Certificate records (name, course, certificate number and date) are kept for 10 years so they can be confirmed later. Other retention periods are set out in our Privacy Policy. A parent or guardian may ask us to delete a child's data at any time. We will do so, except for records we are required by law to keep, such as payment records.
7. Rights of Learners, Parents and Guardians
Learners, and the parents or guardians of learners under 18, can ask to:
- access a copy of the learner's data
- correct inaccurate data
- delete data we no longer need
- withdraw consent (which may mean the learner can no longer take the course)
- receive the learner's data in a portable format
Email [email protected] with the subject "Learner Data Request". We will confirm the requester's identity and relationship to the learner, then respond within 30 days.
8. Security and Breaches
Learner data is protected by the measures described in our Privacy Policy. If a data breach is likely to put a learner at risk, we will notify the learner and, if the learner is under 18, their parent or guardian. We will also report it to the authorities where the law requires.
9. Contact Us
GISE Africa · [email protected] · +254 727 427839 · Bimz Plaza, CFSK road, Utawala, Nairobi, Kenya