Privacy Policy

1. Introduction

St. Philip Neri Primary and Junior School ("SPN", "we", "our", or "us") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, share and protect information about our students, parents, guardians and website visitors, in accordance with the Data Protection Act, 2019 of Kenya. It covers both data we hold as a school and data collected through this website (www.spns.sc.ke), including analytics and cookies.

2. Data Controller

The Data Controller responsible for your personal data is:
St. Philip Neri Primary and Junior School
Joska, Off Kangundo Road, Machakos County, Kenya
Email: info@stphilipnerischool.sc.ke
Phone: 0711 999 111 | 0719 221 401

3. Information We Collect

3.1 Student Data

Full name, date of birth, gender, admission details, academic records, attendance, health information, photographs, and emergency contact details.

3.2 Parent/Guardian Data

Names, contact information (phone, email, address), identification documents, and financial information for fee processing.

3.3 Health Data

Medical conditions, allergies, vaccination records, and medication information necessary for student welfare.

3.4 Information You Give Us Through the Website

• Contact forms: your name, phone number, email address and the message you write to us. We use it solely to reply to your enquiry.
• Newsletter subscription: your email address, plus an internal record of where the subscription came from (for example, the site footer or the newsletter popup) and the date you subscribed, so we can manage the subscription list and honour unsubscriptions.
• Consent choices: the cookie consent choice you pick ("Accept All" or "Necessary Only").

3.5 Information Collected Automatically (Website Analytics)

When you browse the Website, our systems and analytics tools automatically collect limited technical data, including:

• IP address (which may indicate your approximate region or city, never your precise location);
• Browser type and version, device type (desktop/tablet/mobile) and operating system;
• Pages viewed, time spent on each page and your navigation path through the site;
• The referring website or link that brought you to us, and whether you arrived via a search engine;
• Date and time of each visit;
• Broadly aggregated traffic counts (for example, visits this week, most-viewed pages).

4. Why We Collect It — and How

4.1 School Operations

Student, parent and health data is collected to manage enrolment, provide educational services, safeguard students, provide medical care, administer fees and communicate with parents about school life and progress.

4.2 Website Analytics and Measurement

Why we measure: we use aggregated analytics to understand how the Website is used — which pages are most helpful to parents, whether visitors find information (such as fees, admissions and term dates), how our newsletters and downloads are used, and how fast pages load. This helps us improve content, fix what is not working, and plan what to publish next. We do NOT use analytics to build advertising profiles or to identify individuals.

How we measure: analytics is delivered through cookies and similar technologies. Where optional analytics is involved (for example, Google Analytics cookies such as _ga and _gid), those tools only run when you choose "Accept All" on our consent banner. If you choose "Necessary Only" or do not interact with the banner, the essential website still works and optional analytics stays off.

How we use the data at a practical level: we review summaries such as most visited pages, traffic sources and browser/device mix; no automated decisions are made about individuals, and we never sell analytics data.

4.3 Cookies and On-Device Storage

The Website uses the categories of cookies described in our Cookie Policy:

• Essential: the PHP session cookie (PHPSESSID) that keeps the site functioning securely for the duration of your visit;
• Consent record: your banner choice is stored in your browser's session storage and kept only for the current browsing session. Once you answer the banner in a session it stays hidden for the rest of that session; the question returns in your next session;
• Popup preferences: to avoid interrupting you repeatedly, temporary session-storage flags mark when you have seen the announcements and the newsletter popup; these also reset when your session ends;
• Optional analytics cookies: set only with your "Accept All" consent.

5. Legal Basis for Processing

We process your data based on:

• Performance of a contract (enrolment agreement) for student and fee administration;
• Compliance with legal obligations applicable to schools in Kenya;
• Legitimate interests of SPN for essential website operation, security and activity logging;
• Consent for optional analytics, newsletter subscriptions, marketing and photography.

6. Who We Share Data With

We do not sell or rent your personal data. Data may be shared only with:

• Service providers: our hosting provider and website developer (The Stark Nexus) who operate the Website on our behalf, and analytics providers whose services we only use as described above;
• Authorities: law-enforcement, courts or regulators where legally required;
• Communication tools: if you contact us through WhatsApp, Facebook or Instagram, that interaction is also subject to those platforms' own policies.

7. How Long We Keep Data

• Student and parent records: retained for as long as required by education and child-safeguarding regulations, then securely deleted;
• Analytics data: used in aggregate form; tool-specific cookies expire on their published schedules (for example, _ga within about 2 years);
• Contact-form messages: kept while we respond to and handle your enquiry, then promptly deleted;
• Newsletter records: kept until you unsubscribe or the address becomes invalid;
• Consent and popup preferences: session storage only — cleared automatically when your browsing session ends.

8. Your Rights

Under the Data Protection Act, 2019, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Object to data processing
• Withdraw consent (including for analytics and newsletters) at any time
• Data portability, where applicable
• Lodge a complaint with the Office of the Data Protection Commissioner

9. Data Security

SPN implements appropriate technical and organizational measures to ensure the security of your personal data, including HTTPS encryption in transit, HttpOnly session cookies with SameSite protection, access controls for data-handling staff, and regular security assessments.

10. Photography and Videography

SPN may capture photographs and video images of students, staff, and parents for:

• Sharing student achievements and celebrating success
• Internal magazines, publications, and displays
• The SPN website and social media channels
• External marketing and media coverage

Consent is obtained through our Audio-Visual Consent Form. You may withdraw consent at any time by submitting a written request to our Data Protection Officer.

11. Contact Us

To exercise your data protection rights or for any privacy-related queries, contact our Data Protection Officer:
Email: info@stphilipnerischool.sc.ke
Phone: 0719 221 401
Address: St. Philip Neri School, Joska, Off Kangundo Road, Kenya

12. Complaints

If you believe SPN has not correctly attended to your rights, you may lodge a complaint with the Office of the Data Protection Commissioner (DPC) of Kenya.

13. Related Policies

This policy should be read together with our Terms and Conditions and Cookie Policy.

14. Policy Review

This policy is reviewed every 3 years or as required by changes in legislation.