Privacy Policy
Effective Date: October 1, 2024
Last Updated: October 1, 2024
Introduction
Welcome to OpenCHS (Open Child Helpline System). We are committed to protecting the privacy and confidentiality of children, families, and individuals who contact child helpline services. This Privacy Policy explains how we collect, use, store, and protect your personal information.
OpenCHS is operated by BITZ IT Consulting LTD in partnership with UNICEF Venture Fund and child protection organizations across Kenya, Tanzania, Uganda, and Lesotho.
Who We Are
Service Provider: BITZ IT Consulting LTD
Registered Address: Nairobi, Kenya
Email: privacy@openchs.org
Data Protection Officer: dpo@openchs.org
Information We Collect
When You Call the Helpline
Contact Information:
- Phone number (automatically collected)
- Your name (if you choose to provide it)
- Your location (if you choose to share it)
Call Information:
- Date and time of call
- Call duration
- Call recordings (for quality and training purposes)
- Transcripts of conversations
Case Information:
- The nature of your concern or issue
- Details you share about your situation
- Age and gender (if relevant and shared)
- Any follow-up actions or referrals
Automatically Collected Information
Technical Data:
- IP address (for web-based services)
- Browser type and version
- Device information
- Access times and dates
System Data:
- Call quality metrics
- System performance data
- Error logs
Information We Don't Collect
We do NOT collect:
- Credit card or payment information (our services are free)
- Social media profiles
- Marketing preferences
- Unnecessary personal details
How We Use Your Information
Primary Purposes
To Provide Help: We use your information to understand your situation and provide appropriate support, guidance, and referrals.
To Ensure Safety: When there is immediate danger to a child, we may need to share information with child protection services or law enforcement.
To Improve Services: We analyze anonymized data to understand trends, improve our services, and train our counselors.
Quality Assurance: Call recordings may be reviewed by supervisors to ensure high-quality service and counselor training.
Secondary Purposes
Research: Anonymized, aggregated data may be used for research to improve child protection services globally.
Reporting: We create statistical reports for funders and partners showing service impact (never including identifiable information).
Legal Compliance: We may use information to comply with legal obligations or respond to lawful requests.
Legal Basis for Processing
We process your personal information based on:
Vital Interests: Processing necessary to protect the life or safety of a child.
Legitimate Interests: Providing helpline services, improving child protection, and training staff, balanced against your privacy rights.
Legal Obligation: Complying with child protection laws and regulations.
Consent: Where we ask for your explicit consent for specific purposes (you can withdraw consent at any time).
How We Protect Your Information
Security Measures
Technical Security:
- Encryption of data in storage and transmission
- Secure servers with restricted access
- Regular security audits and updates
- Multi-factor authentication for staff
- Intrusion detection systems
Organizational Security:
- Background checks for all staff
- Mandatory confidentiality training
- Strict access controls based on job role
- Regular security awareness training
- Confidentiality agreements for all personnel
Physical Security:
- Secure data center facilities
- Controlled office access
- Secure document disposal
- Clean desk policies
Access Controls
Only authorized personnel with a legitimate need can access your information:
- Counselors handling your case
- Supervisors for quality assurance
- Technical staff for system maintenance (no access to case content)
- Management for anonymized reporting
How Long We Keep Your Information
Call Recordings: Up to 12 months for quality assurance, then deleted unless needed for ongoing case management.
Case Records: Retained for 7 years as required by child protection regulations, then securely deleted.
Anonymized Data: Kept indefinitely for research and reporting (cannot be linked back to you).
System Logs: Retained for 90 days for security monitoring, then automatically deleted.
You can request earlier deletion of your information, subject to legal obligations to retain child protection records.
Sharing Your Information
When We Share
We only share your personal information when necessary:
Child Protection Services: If a child is at risk, we may need to share information with relevant authorities.
Emergency Services: In life-threatening situations, we may contact emergency services.
Referral Partners: With your consent, we may share relevant information with healthcare providers, social workers, or other support services.
Legal Requirements: If required by law or court order.
Service Providers: Technical providers who help us operate the system (under strict confidentiality agreements).
When We Don't Share
We will NEVER:
- Sell your information to third parties
- Share your information for marketing purposes
- Disclose your information to unauthorized persons
- Share information publicly without complete anonymization
International Transfers
Your data is primarily stored and processed in Kenya. If international transfers are necessary:
- We ensure adequate protection measures
- We use secure transfer mechanisms
- We comply with applicable data protection laws
Your Rights
Right to Access
You can request a copy of the personal information we hold about you.
Right to Correction
You can ask us to correct inaccurate or incomplete information.
Right to Deletion
You can request deletion of your information, subject to legal obligations to retain child protection records.
Right to Object
You can object to certain types of processing, particularly automated decision-making.
Right to Data Portability
You can request your information in a portable format (where technically feasible).
Right to Withdraw Consent
If we're processing your information based on consent, you can withdraw it at any time.
How to Exercise Your Rights
Contact us:
- Email: privacy@openchs.org
- Phone: Contact your local helpline
- Online: Submit a request through our website
- Mail: BITZ IT Consulting LTD, Nairobi, Kenya
We will respond to your request within 30 days. Identity verification may be required.
Special Protections for Children
Age-Appropriate Communication
We provide privacy information in clear, simple language that children can understand.
Enhanced Consent
For certain processing activities, we may seek parental or guardian consent where appropriate and safe to do so.
Best Interests
All data processing decisions prioritize the best interests and safety of the child.
Limited Automated Processing
Automated decision-making is limited and always includes human oversight for decisions affecting children.
Cookies and Tracking
What We Use
Essential Cookies: Required for the website and system to function (e.g., authentication, security).
Performance Cookies: Help us understand how the system is used to improve it (anonymized).
We do NOT use:
- Advertising cookies
- Social media tracking
- Third-party marketing cookies
Your Choices
You can control cookies through your browser settings. Disabling essential cookies may affect system functionality.
Third-Party Services
We use carefully selected third-party services:
Cloud Hosting: AWS/Azure for secure, reliable hosting Communication: Telephony providers for call routing Analytics: Privacy-focused analytics tools (no personal data shared) Security: Security monitoring services (under confidentiality agreements)
All third parties are bound by strict data protection agreements.
Changes to This Policy
We may update this Privacy Policy to reflect:
- Changes in our services
- New legal requirements
- Improved privacy practices
When we make changes:
- We'll update the "Last Updated" date
- Significant changes will be communicated to users
- Continued use of services constitutes acceptance
Previous versions are available on request.
Children's Privacy
OpenCHS is designed specifically for children and young people. We:
- Provide age-appropriate privacy information
- Apply enhanced protection measures for children's data
- Limit data collection to what's necessary for child protection
- Ensure staff are trained in child safeguarding
- Prioritize children's safety in all decisions
Parents/guardians can contact us regarding their child's information, but we balance this with the child's right to confidentiality in seeking help.
Anonymous Service
You do NOT need to provide your real name or detailed personal information to receive help. Our counselors are trained to help you regardless of what information you choose to share.
If you're in immediate danger, we encourage you to share location information so we can send help, but this is your choice.
Your Choices
What You Control
What You Share: You decide what information to tell us during calls.
Recording: In some jurisdictions, you can request that your call not be recorded (quality assurance may be affected).
Referrals: You can accept or decline referrals to other services.
Follow-up: You can choose whether to participate in follow-up contacts.
What You Can Request
- Access to your information
- Correction of your information
- Deletion of your information (subject to legal obligations)
- Restriction of processing
- Information about how we use your data
Complaints
If you're not satisfied with how we handle your information:
Contact Our DPO: dpo@openchs.org
Supervisory Authority: You can lodge a complaint with:
- Kenya: Office of the Data Protection Commissioner
- Tanzania: Personal Data Protection Commission
- Uganda: Personal Data Protection Office
- Lesotho: Data Protection Commission
UNICEF: As our partner, UNICEF can receive complaints about data handling.
Contact Us
For questions about this Privacy Policy or our data practices:
Email: privacy@openchs.org
Data Protection Officer: dpo@openchs.org
Mail: BITZ IT Consulting LTD, Nairobi, Kenya
Phone: Contact your local helpline
Transparency
OpenCHS is an open-source project. Our code is publicly available on GitHub, demonstrating our commitment to transparency in how we handle data.
GitHub: https://github.com/openchlai
Documentation: https://docs.openchs.org
Languages
This Privacy Policy is available in:
- English
- Swahili
- Sesotho
- Other local languages upon request
If there are any inconsistencies between translations, the English version prevails.
Remember: You are never alone. Our helpline is here to listen, support, and help you find solutions. Your privacy and safety are our top priorities.
If you're in immediate danger, please call emergency services in your country or your local child protection hotline.