Greenfield Academy
Privacy Policy
How we collect, use and protect personal data on this system · Last updated: May 2025
This system is operated by Greenfield SMS on behalf of your school. All data collected belongs to the school. We process it only to run the school management system. We are registered with the Ghana Data Protection Commission under the Data Protection Act, 2012 (Act 843).
1. Who We Are

This School Management System is provided by Greenfield SMS, a software service operating under the Data Protection Act, 2012 (Act 843) of Ghana. We act as a data processor on behalf of your school, which is the data controller.

Contact: info@greenfieldsms.com · Accra, Ghana

2. What Personal Data We Collect

We collect and process the following categories of personal data:

3. Why We Collect This Data (Lawful Basis)

We collect personal data under the following lawful grounds as defined in Section 20 of Act 843:

4. Data Minimality (Section 19, Act 843)

We only collect what is necessary to run the school management system. We do not collect health records, political opinions, religious beliefs, ethnicity, or any other special category data as defined under Section 37 of Act 843.

5. How We Protect Your Data (Section 28, Act 843)

We take the following technical and organisational measures to protect personal data:

6. Who Has Access to the Data

We do not sell, share, or disclose personal data to any third party for any commercial purpose. This is prohibited under Sections 88 and 89 of Act 843.

7. Data Retention (Section 24, Act 843)

Student and academic data is retained for the duration of the school's subscription. When a school ends its subscription, all data is deleted within 30 days unless the school requests a data export before deletion. The school is responsible for keeping their own archives.

8. Cross-Border Data Transfer

Data is stored on Google Firebase servers located in Europe (eur3). This transfer is necessary to provide the cloud-based service. Google operates under internationally recognised data protection standards and the data is protected under their processing agreements.

9. Your Rights as a Data Subject (Sections 32–35, Act 843)

Under the Data Protection Act, 2012, you have the right to:

To exercise these rights, contact your school admin directly. The school is the data controller and will respond within 40 days as required by Section 35(10) of Act 843.

10. Security Breach Notification (Section 31, Act 843)

In the event of a data breach, we will notify the school and the Data Protection Commission as soon as reasonably practicable. The school will then notify affected data subjects as required by law.

11. Data Protection Commission Registration

Greenfield SMS is registered with the Ghana Data Protection Commission as a data processor under the Data Protection Act, 2012 (Act 843). Each school using this system is also required to register as a data controller.

Ghana Data Protection Commission
Pawpaw Street, East Legon, Accra · P.O. Box CT 7195, Cantonments
📞 +233(0)302-222-929 · 📧 info@dataprotection.org.gh
🌐 www.dataprotection.org.gh
Questions about this Privacy Policy?

Contact Greenfield SMS at info@greenfieldsms.com
Or speak to your school's Head Teacher who is the data controller for all school records.
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