Section 01
Overview & Who We Are
Talent Shapers School ("we", "us", "our", or "the School") is a private educational institution registered in Kenya, located at Mwendantu Road, Opposite YWCA, Meru Town, Meru County, Kenya.
This Privacy and Child Safeguarding Policy ("Policy") applies to:
- All current and prospective learners and their parents or legal guardians
- All staff, teaching and non-teaching, volunteers, and contractors
- All visitors to our physical campus and our website
- Community partners, suppliers, and third-party service providers
By enrolling a learner, using our website, or interacting with the School in any capacity, you agree to the terms of this Policy. If you do not agree, please contact us before providing any personal data.
This Policy is governed by the Kenya Data Protection Act, 2019 (No. 24 of 2019), the Children Act, 2022, and relevant international best practice standards for schools.
Section 02
Personal Data We Collect
We collect only the data necessary for lawful educational and administrative purposes. The categories of personal data we may collect include:
Learner Data
- Full name, date of birth, gender, nationality, and home address
- Birth certificate / Kenyan ID number (for registration purposes)
- Academic records, assessment results, and progress reports
- Attendance and disciplinary records
- Health and medical information relevant to the learner's care and safety at school (e.g. known allergies, conditions requiring medication)
- Photographs and video footage taken at school events (see Section 08)
Parent / Guardian Data
- Full name, national ID number, and contact details (phone, email, address)
- Occupation and employer information (where relevant to fee structures)
- Financial data for fee payment records (account references only — we do not store full bank account or card numbers)
- Emergency contact information
Staff Data
- Employment records, qualifications, professional references, and TSC registration details
- National ID, KRA PIN, and NSSF/NHIF numbers for payroll
- Performance evaluations and disciplinary records
- DCI (police clearance) certificates required for child protection compliance
Website Visitors
- IP addresses, browser type, pages visited, and time on site (via analytics tools)
- Contact form submissions, including name, email, phone, and message content
- Newsletter subscription data
Section 03
How We Use Personal Data
We use personal data strictly for the following purposes:
- Enrollment and registration — verifying learner identity and eligibility for admission
- Academic management — tracking learning progress, issuing report cards, and maintaining academic records
- Health and safety — ensuring learner wellbeing on campus, administering first aid, and contacting parents in emergencies
- Fee billing and financial administration — processing school fee payments and issuing receipts
- Communication — sending school notices, term updates, event invitations, and newsletters to parents and guardians
- Legal compliance — fulfilling obligations under the Kenya Education Act, Children Act 2022, and Data Protection Act 2019
- Staff management — payroll, performance management, and statutory returns to government bodies
- School marketing and profile — using photographs of school events (subject to consent; see Section 08)
- Website improvement — using anonymised analytics to improve our online content
We will not use your personal data for unsolicited commercial marketing, sell it to third parties, or use it for any purpose incompatible with those stated above without obtaining your prior consent.
Section 04
Legal Basis for Processing
Under the Kenya Data Protection Act 2019, we process personal data on the following lawful bases:
- Contractual necessity — processing required to fulfil the educational services contract (e.g. enrollment, fee billing, reporting)
- Legal obligation — processing required to comply with Kenyan law (e.g. learner registration with the Ministry of Education, TSC statutory returns)
- Vital interests — processing necessary to protect a learner's life or safety in an emergency
- Legitimate interests — processing necessary for our legitimate educational and administrative functions, where these are not overridden by the individual's rights
- Consent — for non-essential processing such as photographs for marketing purposes, newsletter subscriptions, and optional data collection on our website. Consent may be withdrawn at any time.
Section 05
Sharing & Disclosure of Data
We do not sell, rent, or trade personal data. We may share data only in the following circumstances:
- Government and regulatory bodies — the Ministry of Education, Kenya National Examinations Council (KNEC), Teachers Service Commission (TSC), and other statutory bodies as required by law
- Health service providers — in medical emergencies, relevant health information may be shared with medical personnel
- Child protection authorities — the Department of Children Services, National Council for Children's Services (NCCS), or law enforcement agencies where a safeguarding concern arises (see Section 07)
- Service providers — trusted third-party providers who assist with school operations (e.g. school management software, payroll systems, printing services), bound by confidentiality agreements and data processing agreements
- Parents and guardians — information about their own enrolled child, to the extent appropriate and lawful
- With your consent — in any other circumstance, only with explicit prior consent
All third parties with whom we share data are required to handle it in accordance with this Policy and applicable Kenyan law.
Section 06
Data Retention
We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law. Our general retention periods are as follows:
- Learner academic records — retained permanently as part of the school's historical records; copies may be provided to former learners upon request
- Health and medical records — retained for the duration of enrolment plus 7 years (or until the learner turns 21, whichever is later), in line with Kenyan health law
- Financial records — retained for 7 years in accordance with the Kenya Revenue Authority requirements
- Staff employment records — retained for the duration of employment plus 7 years
- CCTV footage — retained for 30 days unless required for an investigation, in which case it may be retained longer
- Website enquiry data — retained for 12 months from the date of submission, unless the enquiry results in enrolment
- Newsletter subscriptions — retained until you unsubscribe
When data is no longer required, it is securely deleted or anonymised.
Section 07
Child Safeguarding & Protection
Our safeguarding commitment: Talent Shapers School is unconditionally committed to the protection, safety, and dignity of every child in our care. Child safeguarding is not a compliance exercise — it is a core part of who we are as a school community.
Our Safeguarding Framework
- All teaching and non-teaching staff undergo child protection training as part of induction and annual refresher training
- All staff are required to submit a valid DCI Police Clearance Certificate prior to commencement of employment
- The School maintains a designated Child Protection Champion (CPC) responsible for overseeing safeguarding implementation
- A Safeguarding and Child Protection Policy is maintained separately and made available to all staff and parents upon request
Mandatory Reporting
Under the Children Act 2022 (Kenya), all school staff are mandatory reporters. This means that if any member of staff has reasonable grounds to suspect that a child is being abused, neglected, or is at risk of harm, they are legally obligated to report this to the relevant authorities — including the Department of Children Services and, where necessary, the Kenya Police Service.
In such circumstances, the School may need to share a learner's personal data with child protection authorities without prior parental consent. This is a legal requirement and overrides our general data-sharing restrictions.
What Constitutes a Safeguarding Concern?
- Physical, emotional, or sexual abuse — whether by a staff member, fellow learner, or third party
- Neglect — where a child's basic physical, educational, or emotional needs are not being met
- Bullying and cyberbullying — including intimidation, harassment, or exclusion
- Exploitation — including child labour or early/forced marriage
- Any situation where a child expresses fear for their safety
Reporting a Concern
If you have a safeguarding concern about a learner at Talent Shapers School, please contact us immediately:
- Phone: 0704 764 306 (school office hours)
- Email: talentshapers96@gmail.com
- In person: speak to any member of staff, who will escalate to the Child Protection Champion
- National Hotline: Department of Children Services — 116 (toll-free, 24/7)
Section 09
Cookies & Website Data
Our website uses cookies and similar tracking technologies to improve user experience and analyse website traffic. The types of cookies we use include:
- Strictly necessary cookies — essential for the website to function correctly. These cannot be disabled.
- Analytics cookies — used to understand how visitors interact with our website (e.g. which pages are most visited). Data is anonymised and aggregated. We use Google Analytics for this purpose.
- Functional cookies — used to remember your preferences (e.g. language settings).
You may control cookie preferences through your browser settings. Disabling analytics cookies will not affect your ability to use the website. Our website does not currently use advertising or retargeting cookies.
Section 10
Your Data Rights
Under the Kenya Data Protection Act 2019, you have the following rights in relation to your personal data (and, where applicable, your child's personal data):
- Right of access — you may request a copy of the personal data we hold about you or your child
- Right to rectification — you may request that inaccurate or incomplete data be corrected
- Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected (subject to our legal retention obligations)
- Right to object — you may object to processing based on legitimate interests, including marketing communications
- Right to withdraw consent — where processing is based on your consent (e.g. photographs, newsletters), you may withdraw consent at any time without affecting the lawfulness of prior processing
- Right to lodge a complaint — you have the right to lodge a complaint with Kenya's Office of the Data Protection Commissioner (ODPC) at www.odpc.go.ke
To exercise any of these rights, please submit a written request to our Data Protection contact (see Section 13). We will respond within 21 days of receipt, as required by law.
Section 11
Data Security
We take the security of personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. Our security measures include:
- Physical security of school premises, including controlled access to administrative offices and records storage areas
- Password-protected school management systems with role-based access controls
- Secure disposal of paper records containing personal data (shredding)
- Staff training on data handling and confidentiality obligations
- Regular review of data security practices
In the event of a data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the Office of the Data Protection Commissioner within 72 hours, and affected individuals without undue delay, as required by law.
Section 12
Changes to This Policy
We review and update this Policy periodically to reflect changes in our practices, legal requirements, or operational context. When we make material changes, we will:
- Post the updated Policy on this page with a revised "Last Reviewed" date
- Notify parents and guardians via the school's official communication channels (SMS, email, or notice board)
- Where changes significantly affect how we process children's data, seek renewed consent where required
We encourage you to review this Policy periodically. Continued use of our services after notification of changes constitutes acceptance of the updated Policy.
Talent Shapers School • Privacy Policy v2.0 • Effective 1 January 2026