Privacy Policy

Effective Date: September 2025
Last Updated: [27th of August, 2025]

Inclusive Pathways Hub is committed to protecting the privacy and confidentiality of families, schools, and learners we serve. This Privacy Policy outlines how we collect, use, store, and safeguard your personal information in compliance with the Kenya Data Protection Act (2019).

1. Information We Collect

• Family & Learner Information: Names, contact details, learner profiles, educational history, special educational needs (SEN) or support requirements, and Individualized Education Plans (IEPs).
• School Information: Institutional contact details, department frameworks, staff training needs, and learning support structures.
• Professional Records: Assessments, reports, referrals, and related educational documentation provided to us with parental or school consent.
• Technical Data: Information from our website (cookies, IP address, device type, browser type, and usage data) to improve user experience.
• Communication Data: Emails, phone calls, discovery call notes, and service agreements.

2. How We Use Your Information

• Supporting families with school placement, IEP advisory, assessments, shadow teacher sourcing, and parent coaching.
• Partnering with schools to design, strengthen, and sustain Learning Support & SEN departments.
• Facilitating professional consultations, discovery calls, and follow-ups.
• Preparing documentation such as progress updates, frameworks, and closure packs.
• Complying with legal and regulatory obligations under the Kenya Data Protection Act (2019).

3. Legal Basis for Processing

• Consent: Provided by parents, guardians, or schools before sharing learner data.
• Contractual Necessity: Where information is required to fulfill consultancy services.
• Legitimate Interest: To improve our services and communication while safeguarding privacy.
• Legal Obligation: Where disclosure is required by law or regulatory authority.

4. How We Share Information

• With schools, therapists, or specialists directly involved in learner support, with parental consent.
• With shadow teachers, assessors, or consultants engaged under confidentiality agreements.
• With regulatory authorities where legally required.

All third parties are required to comply with data protection obligations and maintain confidentiality.

5. Data Storage & Security

• All digital records are stored securely on password-protected and encrypted systems.
• Physical records (if any) are stored in locked and controlled access spaces.
• We implement technical and organizational safeguards to prevent unauthorized access, alteration, or misuse of information.

6. Data Retention

• Family and learner information is retained only as long as necessary to deliver services or as required by law.
• Assessment reports and IEP records are securely archived or deleted once no longer relevant.
• Families and schools may request data deletion at any time (subject to legal obligations).

7. Your Rights Under the Kenya Data Protection Act (2019)

As a data subject, you have the right to:

• Access the personal information we hold about you.
• Request correction or deletion of inaccurate data.
• Withdraw consent at any time.
• Object to certain forms of processing.
• File a complaint with the Office of the Data Protection Commissioner (ODPC) if your rights are infringed.

Requests may be submitted via: contact@inclusivepathwayshub.com or +254 717435035.

8. Cookies & Website Use

Our website may use cookies and tracking tools to improve functionality, user experience, and analytics. You may disable cookies in your browser settings, though some site features may be affected.

9. International Data Transfers

If we share information with professionals, schools, or institutions outside Kenya, we ensure that adequate safeguards are in place to protect your data in line with the Kenya Data Protection Act (2019).

10. Updates to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on our website with the revised date. Continued use of our services constitutes acceptance of the updated policy.