Privacy policy
Pathways of Promise Kenya
Organisation Registration Date: 21 October 2024
Effective Date: 14 October 2026
Last Updated: 14 October 2026
1. Introduction
Pathways of Promise Kenya is committed to protecting the privacy, dignity and personal information of the children, families, donors, partners, website visitors and other individuals with whom we engage.
Our work focuses on supporting and advocating for children affected by parental incarceration, particularly children whose mothers are incarcerated, and the families who care for them.
We recognise that the information entrusted to us may concern sensitive family circumstances, children's welfare, education, health, financial needs and other personal matters. We therefore take our responsibility to handle such information carefully and confidentially.
This Privacy Policy explains how we collect, use, store, disclose and protect personal information through our website, programmes, field activities, welfare visits, research, fundraising and other organisational activities.
We process personal information in accordance with applicable Kenyan data protection laws, including the Data Protection Act, 2019, and applicable regulations.
2. Who We Are
Pathways of Promise Kenya is a Kenyan nonprofit organisation committed to supporting and advocating for children affected by parental incarceration.
Where Pathways determines the purposes and means of processing personal information, it acts as a data controller under applicable data protection law.
Organisation: Pathways of Promise Kenya
Website: https://pathwaysofpromisekenya.org
Email: info@pathwaysofpromisekenya.org
For questions, concerns or requests relating to personal information, please contact us using the email address above.
3. Personal Information We Collect
The information we collect depends on how you interact with Pathways of Promise Kenya.
3.1 Website Visitors
When you visit our website, we may collect technical and usage information, including:
Internet Protocol (IP) address.
Browser type and device information.
Operating system and general technical information.
Pages visited, time spent on pages and referring websites.
Information collected through cookies or similar technologies, where these are used.
Information you voluntarily provide through website forms.
3.2 Donors and Supporters
When you make a donation or express an interest in supporting our work, we may collect:
Name and contact details.
Donation amount and date.
Transaction references and payment confirmations.
Donation and communication preferences.
Information necessary for accounting, financial reporting and legal compliance.
Donations may be processed through third-party payment service providers, banks or mobile money services. Payment information collected by these providers is also subject to their applicable privacy policies.
We do not ask donors to disclose their mobile money PINs, online banking passwords or other confidential payment credentials to us.
3.3 Children and Families
In carrying out our programmes, we may collect limited personal information relating to children affected by parental incarceration and the families or caregivers who support them.
Depending on the purpose of the activity, this information may include:
Names or other identifiers where necessary.
Age or date of birth.
Caregiver and family contact details.
General caregiving and household circumstances.
Educational needs and school-related information.
Welfare needs and assistance provided.
Referral and follow-up records.
Relevant health or psychosocial information where necessary and appropriately protected.
Photographs, recordings or personal stories where collection and use are justified and appropriately authorised.
Information concerning a child's family circumstances, health, welfare or parental incarceration may be particularly sensitive.
We seek to collect only information that is necessary for a clearly defined and legitimate purpose. We do not collect detailed information about children merely because it may be useful for publicity or general organisational purposes.
3.4 Welfare Visits and Field Activities
During prison visits, community engagement, welfare checks and follow-up activities, we may record information necessary to understand needs, coordinate appropriate support, document activities and assess outcomes.
Such records are handled confidentially, with access restricted to authorised individuals who require the information for their responsibilities.
Information gathered during field activities is not automatically intended for publication on our website, social media platforms or other public channels.
3.5 Research, Advocacy and Publications
Where we conduct or support research, we may process information necessary for research planning, data collection, analysis, reporting and advocacy.
Depending on the project, this may include interviews, survey responses, observations, demographic information and other research material.
Where appropriate, we use anonymisation or pseudonymisation to reduce the risk of identifying participants.
Research involving human participants will be conducted in accordance with applicable legal requirements, relevant research approvals, ethical requirements and participant information and consent procedures, where applicable.
Information collected for research is not automatically used for unrelated publicity, fundraising or other purposes.
3.6 Staff, Volunteers and Partners
We may collect professional and contact information from staff, volunteers, consultants, service providers, institutional partners and individuals who collaborate with us.
This may include names, contact details, qualifications, organisational affiliations, application information and records necessary to manage the relevant relationship.
4. How We Use Personal Information
We may use personal information for the following purposes:
Responding to enquiries and requests for information.
Processing donations and maintaining financial records.
Planning and delivering programmes, welfare visits and follow-up activities.
Identifying and responding to children's needs within the scope of our work.
Coordinating appropriate referrals and support.
Communicating with caregivers, partners, donors and stakeholders.
Conducting research, analysing findings and preparing reports or policy recommendations.
Monitoring programme activities and evaluating outcomes.
Publishing organisational updates, reports and authorised stories.
Managing events, training, conferences and partnership activities.
Maintaining website functionality, security and performance.
Meeting applicable legal, regulatory, accounting and safeguarding obligations.
Protecting the rights and safety of children, families and other individuals.
We identify an appropriate lawful basis for each processing activity as required by applicable law. Depending on the circumstances, this may include consent, a legal obligation, a legitimate interest permitted under the law, or another applicable lawful basis.
We do not use personal information for purposes incompatible with the purpose for which it was collected unless permitted by law.
5. Protection of Children's Personal Information
Children's privacy, safety and best interests are central to our approach.
We recognise that children affected by parental incarceration may face stigma, discrimination, emotional distress or other risks if their personal circumstances become known without appropriate safeguards.
Pathways of Promise Kenya is committed to:
Collecting children's information only where there is a justified and clearly defined need.
Applying appropriate safeguards when processing children's personal information.
Obtaining parental or guardian consent where required by law and ensuring that the child's best interests are protected.
Considering children's age, understanding, views, dignity and safety in decisions affecting their information.
Limiting access to children's records to authorised individuals.
Avoiding unnecessary disclosure of a child's identity, family circumstances, location, school or other identifying details.
Using anonymised or de-identified information for public reporting wherever appropriate.
Obtaining appropriate consent and authorisation before publishing photographs, interviews or stories involving children, in accordance with applicable law and safeguarding requirements.
We will not make a child's access to appropriate support conditional on agreeing to publicity or promotional use of their personal information.
Where consent is not an appropriate or sufficient lawful basis for a particular activity, we will assess the applicable legal requirements before proceeding.
6. Photographs, Stories and Media
Pathways of Promise Kenya may publish photographs, videos, interviews, stories and reports to document its activities, share learning and communicate its work.
We recognise that photographs and stories can reveal a person's identity even when their name is omitted.
Before publishing material involving children or vulnerable families, we consider:
Whether publication is necessary and appropriate.
Whether the individual could be identified directly or indirectly.
Whether the material could cause embarrassment, stigma, discrimination or harm.
Whether the necessary consent and authorisations have been obtained.
Whether anonymisation or an alternative image would be safer.
Whether publication is consistent with the child's best interests and our safeguarding responsibilities.
We will not knowingly publish identifying details about a child simply to make a fundraising appeal more compelling.
Where consent is the basis for publication, individuals may contact us to withdraw that consent. Withdrawal does not affect processing that was lawful before withdrawal. Removing material from third-party websites or copies already redistributed may not always be possible.
7. How We Share Personal Information
Pathways of Promise Kenya does not sell personal information to third parties.
We may share information where necessary and lawful with:
Authorised staff, volunteers or representatives responsible for relevant activities.
Payment service providers and financial institutions processing donations.
Website hosting, technical support, email, analytics and other service providers supporting our operations.
Research collaborators or institutions where the relevant arrangements and lawful requirements permit sharing.
Organisations or professionals involved in an appropriate referral or support arrangement, where disclosure is lawful and appropriately authorised.
Auditors, professional advisers or regulators where required for legitimate organisational or legal purposes.
Public authorities where disclosure is required or permitted by applicable law, or where necessary to address an applicable safeguarding or safety obligation.
Where third parties process information on our behalf, we seek appropriate contractual and organisational safeguards.
We limit information shared to what is necessary for the relevant purpose. Children's welfare records, family details and research participant information are not disclosed for general publicity or fundraising without an appropriate lawful basis and safeguards.
8. Donations and Payment Processing
Donations made through our website may be processed by third-party payment providers, banks or mobile money services.
These providers may process information under their own terms and privacy policies in addition to the arrangements applicable to Pathways of Promise Kenya.
We may receive transaction confirmations, payment references, donation amounts and other information needed to acknowledge donations and maintain accurate financial records.
We encourage donors to review the privacy and security information of the payment provider they use.
We do not request mobile money PINs, online banking passwords or card security credentials by email, telephone or messaging applications.
9. Cookies and Website Analytics
Our website may use cookies or similar technologies to maintain website functionality, understand visitor interactions, improve performance and measure the effectiveness of our communications where applicable.
Information collected may include browser information, device information, pages visited and general website usage patterns.
Where non-essential cookies or analytics technologies require consent, we will provide an appropriate mechanism to obtain and manage that consent.
You may also be able to manage cookies through your browser settings. Disabling certain cookies may affect some website functions.
The specific cookies, analytics services and tracking technologies used will depend on the website's actual configuration.
10. Data Storage, Security and Retention
We take reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.
Depending on the information and systems used, these measures may include access restrictions, password protection, secure storage, confidentiality obligations, backups and appropriate staff guidance.
Access to sensitive welfare records and children's information should be limited to authorised persons with a legitimate need to access them.
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, accounting, research, safeguarding and recordkeeping requirements.
When information is no longer required, we seek to delete it securely, anonymise it or otherwise dispose of it appropriately.
Retention periods may differ between donation records, website logs, programme records and research material.
11. International Transfers of Personal Information
Some of our website, communications, payment or storage service providers may process or store information outside Kenya.
Where personal information is transferred outside Kenya, we will take the steps required by applicable Kenyan data protection law, including ensuring that the relevant transfer conditions and safeguards are satisfied.
We will consider the sensitivity of the information and the risks associated with the transfer, particularly where children's information or sensitive family and welfare records are involved.
12. Your Data Protection Rights
Subject to applicable law and any relevant limitations, you may have the right to:
Be informed about how your personal information is used.
Request access to personal information we hold about you.
Request correction of inaccurate or misleading information.
Request deletion of personal information where the law permits.
Object to certain processing activities.
Request restriction of processing where applicable.
Withdraw consent where processing is based on consent.
Request data portability where the applicable legal conditions are met.
Lodge a complaint with the Office of the Data Protection Commissioner in Kenya.
These rights are subject to the conditions and limitations established by law. For example, we may need to retain certain financial or organisational records where a legal obligation applies.
To exercise your rights, contact us using the email address provided in this policy. We may need to verify your identity or authority before responding.
Requests concerning a child may need to be made by a parent, guardian or another person legally authorised to act on the child's behalf, subject to applicable law and the child's best interests.
13. Research Confidentiality
We recognise the importance of confidentiality when conducting research involving children, families, incarcerated mothers or other potentially vulnerable participants.
Where applicable, research participants will receive relevant information about the purpose of a study, the information being collected, how it will be used and any relevant confidentiality limitations.
We will take appropriate steps to avoid identifying research participants in publications, reports and presentations unless identification is properly authorised and lawful.
Where research is subject to ethics review, research licensing or institutional approval, the relevant requirements will apply to the project.
Information collected for research will not automatically be used for unrelated publicity, fundraising or other purposes.
14. Links to Other Websites
Our website may contain links to external websites, including partner organisations, research institutions, payment providers and social media platforms.
We are not responsible for the privacy practices, content or security of websites operated by third parties.
When visiting an external website or using a third-party service, we encourage you to review its privacy policy.
15. Changes to This Privacy Policy
We may update this Privacy Policy as our programmes, website features, legal obligations or data processing practices evolve.
The latest version will be published on our website, together with its updated revision date.
Where required by law, we will provide additional notice or obtain consent for material changes to the way personal information is processed.
16. Contact Us
If you have a question, concern or request relating to this Privacy Policy or the handling of personal information by Pathways of Promise Kenya, please contact us:
Pathways of Promise Kenya
Website: https://pathwaysofpromisekenya.org
Email: info@pathwaysofpromisekenya.org
If you believe your personal information has been handled unlawfully and your concern has not been adequately resolved, you may also contact the Office of the Data Protection Commissioner in Kenya through its official website:
https://www.odpc.go.ke/
Pathways of Promise Kenya is committed to protecting the privacy, dignity and best interests of the children and families whose lives and experiences are connected to our work.