Data Protection and Privacy Policy

1. Data Collection

Types of Data Collected:

• Personal Information: Includes the student’s name, student ID, guardian’s name, contact information, and relationship to the student.
• Biometric Information: Facial recognition data collected solely for secure authentication during transactions. This data is collected only with the guardian's informed consent.
• Usage Data: Information related to student spending patterns, transaction logs, and device information for monitoring transaction security and detecting potential fraud.

Data Collection Process:

• Data is collected directly from guardians during registration or from students under parental consent.
• Biometric data is securely collected on registered devices, ensuring only authorized devices capture this data.

Guardian Consent:

• Guardians are informed about the data collection process, its purposes, and its uses. Explicit consent is required before any biometric data is collected.
• Consent forms outline the specific purposes and limitations of biometric data use, ensuring compliance with Shariah and data protection standards.

2. Data Usage

Purpose of Data Usage:

• Authentication: Biometric data is used exclusively to authenticate the student’s identity during school-based transactions, ensuring secure access and reducing fraud risks.
• Transaction Processing: Personal data is used to authorize and record transactions within SchoolPay.
• Spending Management: Usage data helps monitor and implement daily spending limits set by guardians, promoting controlled and responsible spending.

Restrictions on Data Usage:

• Prohibited Uses: Data is not used for unauthorized purposes like marketing, profiling, or sharing with third parties for commercial gain.
• Data Anonymization: Usage data may be anonymized and aggregated to analyze general spending patterns. Individual identities are not revealed.
• Access Control: Only specific, authorized personnel access sensitive data, limited to their roles.

Data Minimization:

• SchoolPay collects and retains only the minimum necessary data for each transaction.
• Unnecessary data fields or identifiers are not stored, reducing exposure risks in data breaches.

3. Data Protection

Data Encryption:

• All data, including biometric data, is encrypted during collection, transmission, and storage using AES-256 and TLS.
• Biometric templates are stored as encrypted hashes, ensuring raw biometric data is never stored or accessible.

Access Management:

• Data access is controlled through multi-factor authentication (MFA) for personnel accessing sensitive data.
• Regular access reviews ensure only authorized individuals access personal and biometric data.
• Role-based access controls (RBAC) restrict access based on job roles.

Data Storage and Backups:

• Data is stored on secure servers compliant with industry data protection standards.
• Routine backups are encrypted and stored securely to prevent unauthorized access and data loss.
• Biometric data is stored separately from other personal data for additional security.

Data Retention and Deletion:

• Data is retained only as long as necessary to fulfill its intended purpose or meet legal requirements.
• Upon guardian request or account termination, all associated data is permanently deleted following industry protocols.

4. User Rights

• Right to Access: Guardians can request access to their personal data and their child’s biometric data after verifying their identity.
• Right to Rectification: Guardians can request corrections to inaccurate or outdated data.
• Right to Data Deletion: Guardians can request deletion of their child’s biometric data, which will be permanently erased promptly.
• Right to Withdraw Consent: Guardians may withdraw consent for biometric data use at any time, though this may affect certain features.
• Data Portability: SchoolPay may provide data portability options, allowing guardians to obtain their data in a standard format upon request.

5. Compliance and Monitoring

• Regular Data Protection Audits: Conducted annually or when data handling practices change, these audits assess compliance and identify vulnerabilities.
• Incident Response Plan: Includes notifying affected parties, mitigating harm, and implementing corrective measures in case of data breaches.
• Shariah Compliance Verification: Regular reviews by a Shariah advisory board ensure alignment with Islamic principles.
• Policy Updates: This policy is reviewed periodically to reflect regulatory changes. Guardians are notified of significant updates.