Akwaaba Solutions – Data Protection Policy

Effective Date: 1st September 2025
Location: Akwaaba Solutions, P.O. Box SQ 228, Tema, Greater Accra Region, Ghana

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Introduction

Akwaaba Solutions (“the Company”) is committed to safeguarding the fundamental privacy rights of individuals in line with the Data Protection Act, 2012 (Act 843) of Ghana. This Data Protection Policy outlines how the Company collects, processes, stores, and protects personal data, particularly in connection with its attendance monitoring systems, which employ biometric and location-based technologies.

Clients also reserve the right to self-host the Akwaaba Software in order to manage their own data directly and avoid potential privacy or data protection concerns. In such cases, Akwaaba Solutions continues to manage the client’s subscription account while respecting the client’s ownership and custodianship of hosted data.

Purpose

This policy is designed to:

• Ensure lawful, transparent, and secure handling of personal and biometric data.

• Protect the rights of data subjects (teachers, students, staff, and other users).

• Demonstrate compliance with the principles of the Data Protection Act of Ghana.

• Build trust with clients, partners, and users of the Akwaaba platform.

Scope

This policy applies to:

• All personal and biometric data collected by Akwaaba Solutions.

• All staff, contractors, and service providers working with or on behalf of Akwaaba Solutions.

• All software, mobile applications, biometric devices, and servers (cloud or local) used for processing attendance data.

Data Collection and Categories

Akwaaba Solutions may collect the following categories of personal data:

• Full name, ID number, staff/student registration number.

• Biometric data (e.g., facial image, fingerprint).

• GPS location (for geo-fencing and attendance verification).

• Attendance records (timestamps, institution name, and device location).

• Contact details (e.g., phone number for SMS alerts).

• Device identifiers and IP addresses (for logs and system integrity).

Legal Basis for Processing

Personal data is processed under the following lawful grounds:

• Consent: Where applicable, data subjects provide informed, written consent.

• Contractual Obligation: When institutions engage Akwaaba Solutions to deliver attendance solutions.

• Legal Requirement: To comply with national education, labour, or audit regulations.

• Legitimate Interest: To ensure system security, improve service delivery, and maintain accountability in attendance management.

Data Subject Rights

Akwaaba Solutions respects and upholds the rights of all data subjects, including:

• Right to Access: Request access to personal data held.

• Right to Rectification: Request correction of inaccurate data.

• Right to Erasure: Request deletion of data, subject to contractual or legal obligations.

• Right to Object: Object to certain categories of processing.

• Right to Restrict Processing: Request temporary suspension of processing under specific conditions.

• Right to Data Portability: Receive personal data in a structured, portable format where technically feasible.

Requests may be submitted in writing to:

• Akwaaba Solutions
  Email: akwaabasolution@gmail.com
  Phone: 020 600 7255 | 054 862 9941

  Data Storage and Retention

  • Personal data is stored on secure servers located in Ghana or in jurisdictions that comply with Ghana’s cross-border data transfer requirements.

  • Biometric and attendance data is encrypted both in transit and at rest.

  • Data is retained only for as long as necessary to fulfil the stated purposes or as required by law or contractual agreement.

  Data Security Measures

  Akwaaba Solutions implements robust technical and organizational measures, including:

  • Role-based access control and strong password protection.

  • Multi-layered encryption for biometric data.

  • Firewalls and intrusion detection systems.

  • Regular vulnerability scanning and system audits.

  • Ongoing staff training on data protection and best practices.

  Data Sharing and Third Parties

  • Personal data is shared only with authorized entities such as the Ghana Education Service (GES), contracted clients, or regulatory authorities where legally required.

  • No personal data is sold or disclosed to unauthorized third parties.

  • All third-party service providers are bound by confidentiality and data protection agreements.

  Cross-Border Data Transfer

  Where data must be processed or stored outside Ghana, Akwaaba Solutions ensures that:

  • The recipient country has adequate data protection laws; or

  • Appropriate safeguards (e.g., Standard Contractual Clauses) are implemented.

  Breach Notification

  In the event of a data breach:

  • The DPO will assess the nature and impact of the breach within 72 hours.

  • Affected individuals and the Data Protection Commission will be notified in accordance with the Act.

  • Immediate corrective and preventive measures will be implemented.

  
  

  Akwaaba Software Self-Hosting Policy

  1. Purpose

  This policy outlines the rights and responsibilities of clients who choose to self-host the Akwaaba Software. It is designed to provide clear guidance on data ownership, hosting arrangements, and accountability to ensure that data protection, confidentiality, and compliance with applicable laws are maintained.

  2. Scope

  This policy applies to:

  • All clients of Akwaaba Software who elect to host the application and its associated databases on their own infrastructure.

  • Akwaaba Solutions Ltd. as the software vendor and subscription service provider.

  3. Client’s Right to Self-Host

  • Clients reserve the right to self-host the Akwaaba Software on their own servers, infrastructure, or cloud environments.

  • The purpose of self-hosting is to enable clients to retain full control and custody of their data to address any data privacy or data protection concerns.

  • Akwaaba Solutions Ltd. shall continue to manage the client’s software subscription account, license validity, and related technical support as agreed under the subscription agreement.

  4. Data Ownership and Responsibility

  1. Data Custodianship: All data generated, collected, or stored on a client’s self-hosted system remains the sole property of the client.

  2. Legal Compliance: Clients are fully responsible for ensuring that their hosting environment complies with applicable data protection and privacy laws (e.g., Ghana Data Protection Act 2012, GDPR where applicable).

  3. Data Security: Clients must implement adequate technical and organizational measures (encryption, firewalls, access controls, backups, etc.) to protect their hosted data.

  5. Akwaaba Solutions’ Role

  When clients choose to self-host:

  • Akwaaba Solutions Ltd. will:

    • Provide the licensed software package and necessary installation documentation.

    • Manage subscription accounts, licensing, and updates where applicable.

    • Provide technical support for software-related issues (not infrastructure-related).

  • Akwaaba Solutions Ltd. will not have access to the client’s hosted data unless explicitly requested and granted temporary access by the client for troubleshooting or support.

  6. Client’s Obligations

  Clients who self-host must:

  1. Maintain secure infrastructure that is regularly updated and patched.

  2. Ensure reliable backup and recovery systems for their hosted data.

  3. Protect access credentials and restrict access to authorized personnel only.

  4. Provide adequate IT personnel or third-party support for infrastructure maintenance.

  5. Inform Akwaaba Solutions promptly of any data breaches, technical vulnerabilities, or security concerns affecting the use of the software.

  7. Limitations of Liability

  • Akwaaba Solutions Ltd. is not liable for data breaches, loss, downtime, or any damage resulting from the client’s self-hosting environment, as these are outside the control of Akwaaba Solutions.

  • The company’s responsibility is limited to the provision and maintenance of the licensed Akwaaba Software application.

  8. Subscription and Licensing

  • All self-hosting clients are still bound by the Akwaaba Software Subscription Agreement.

  • Subscription fees cover licensing, updates, and software support, but do not cover costs or responsibilities associated with the client’s hosting infrastructure.

  9. Review and Amendments

  Akwaaba Solutions reserves the right to periodically review and amend this policy to reflect legal requirements, technological advancements, and best practices in data protection.