Last amended February 13, 2018
Introduction
The Association of African Universities (AAU) is committed to fair information practices in relation to individuals whose information it collects, uses, discloses and retains in the course of its operations.
This Privacy Policy outlines the Principles and guidelines by which Association of African Universities operates to protect the personal information of individuals that we collect, use, disclose and retain in the course of our operations.
This Privacy Policy does not apply to personal information about employees, former employees and potential employees (all referred to as “employees”) of Association of African Universities.
Internet Aspects
Personal information may be collected when:
- a user conducts activities on or related to all Association of African Universities websites, including at the aau.org and *.aau.org websites e.g. blog.aau.org, forum.aau.org etc., as well as our online application systems, or Directory of African Universities listings (all referred to as “Association of African Universities websites”).
- you subscribe online to receive the AAU News
- you complete an online application form for scholarships/grants or international programmes administered by Association of African Universities
- you voluntarily register online for events organized by the Association of African Universities
- you pay online for your registration to the Association of African Universities events. We share personal and financial information with our merchant account and banking vendors only to the extent necessary to process the registration and payment*.
*Note: The Association of African Universities does not store personal financial information on its servers.
Use of Cookies
The Association of African Universities websites automatically recognize your domain name, IP address, browser version, operating system, and other salient data about your computer, as well as the site you passed through to reach us. The Association of African Universities uses a browser feature called a “cookie” to collect information anonymously and track user patterns on the Association of African Universities websites. This cookie is a small text file that is placed on your hard disk by our website and remains there unless it is deleted by you.
“Cookies” contain a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our websites. Cookies tell us which pages of our websites are
visited and by how many people. Which in turn assists us to improve on our systems. They also allow us to save your settings and preferences for future visits, enabling you to customize your experience of our websites. Information gathered through the use of cookies is not related to any personally identifiable details.
The use of cookies is an industry standard, and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie.
Advertisers and Links
Third-party advertising providers may use cookies when hosting advertisements on the aau.org, blog.aau.org and database sites. In some cases, advertisements from third-party advertisers are delivered to users (in conjunction with Association of African Universities services) by such third-party advertisers, or by separately contracted advertising providers on their behalf, and not by Association of African Universities websites; as such, the third-party advertisers’ use of cookies is subject to their own privacy policies, not the Association of African Universities Privacy Policy, and users should consult the privacy policies of such third-party advertisers, which are clearly identified there.
Blogs
The Association of African Universities web sites contains links to independent Blogs, forums and websites. These blogs represent the views and perspectives of their individual authors and do not necessarily represent the views of the Association of African Universities.
Summary of Principles
Principle 1 – Accountability
Association of African Universities is responsible for all personal information under its control, including personal information transferred to third parties for processing.
Principle 2 – Identifying the purposes for personal information collection
The Association of African Universities will identify the purposes for which personal information is collected at or before the time the information is collected.
Principle 3 – Obtaining consent
The Association of African Universities will obtain the consent of individuals before or when it collects, uses, discloses and retains personal information, except where authorized by law.
Principle 4 – Limiting the collection of personal information
The Association of African Universities will limit the collection of personal information to that which is necessary for the purposes identified by Association of African Universities. The Association of African Universities will collect personal information by fair and lawful means.
Principle 5 – Limiting use, disclosure and retention of personal information
The Association of African Universities will not use, disclose or retain personal information for purposes other than those for which it was collected, except with the consent of the individual, or as required or as authorized by law. Personal information will be retained only as long as necessary for the fulfilment of those purposes.
Principle 6 – Keeping personal information accurate
The Association of African Universities will keep personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
Principle 7 – Safeguarding personal information
The Association of African Universities will protect personal information with security safeguards appropriate to the sensitivity of the information.
Principle 8 – Being open about policies and procedures
The Association of African Universities will make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
Principle 9 – Providing access to personal information
On written request, and subject to exemptions stipulated by law, the Association of African Universities will inform an individual of the existence, use, disclosure and retention of their personal information and will provide access to that information. An individual will be entitled to challenge the accuracy and completeness of the information and have it amended where inaccuracies exist.
Privacy Policy in detail
Principle 1 – Accountability
Association of African Universities is responsible for all personal information under its control, including personal information disclosed to third parties for processing.
1.1 The Association of African Universities Privacy Officer is responsible for compliance with this Policy, even though other individuals within the Association of African Universities may be responsible for the day to day collection and processing of personal information, and may be delegated to act on behalf of the Association of African Universities Privacy Officer.
1.2 The identity of the individuals designated by Association of African Universities to oversee compliance with this Policy will be made known internally and will be made available externally on request.
1.3 The Association of African Universities will use contractual or other means to protect personal information that has been transferred to service providers for processing, for example, for storage.
1.4 Where the Association of African Universities acts as a processor of personal information or as a service provider to others, Association of African Universities will comply with this Privacy Policy and any Privacy Statements issued by the Association of African Universities in question in respect of the personal information it collects, uses, discloses and retains on behalf of third parties or that is transferred to it.
Principle 2 – Identifying the purposes for personal information collection
The Association of African Universities will identify the purposes for which personal information is collected, used, disclosed and retained at or before the time the information is collected.
2.1 The Association of African Universities programs subject to this Privacy Policy will collect, use, disclose and retain personal information for the following purposes:
2.1.1 to process and evaluate scholarship applications, select scholarship recipients and administer the scholarships and scholarship payments once the scholarships are awarded and to assess the efficacy of scholarship programs;
2.1.2 to develop aggregate information and statistics in relation to the scholarship awards program;
2.1.3 to maintain a scholarship alumni contact list and administer subscriptions to the AAU Newsletter;
2.1.4 to market our publications to potential purchasers or subscribers;
2.1.5 to identify and offer information services and products to meet subscriber needs or preferences;
2.1.6 to develop information and statistics for our member universities;
2.1.7 to comply with legal requirements;
2.1.8 to respond to inquiries about publications or our programmes received by telephone, email or by the Association of African Universities website.
2.2 The Association of African Universities collects and uses primarily business names and addresses of individuals and subscribers for purposes of marketing publications of interest to the higher education sector. The Association of African Universities collects from and discloses to third parties the names and mailing addresses of potential or existing subscribers to its publications. The Association of African Universities will require vendors of such information to represent that they have complied with applicable privacy legislation in disclosing this information to Association of African Universities. The Association of African Universities will provide an opportunity to all individuals and subscribers to consent to or opt-out of the collection, use, disclosure and retention of their names and addresses for these purposes. (see Section 3.7 below).
2.3 Individuals will be advised of the purposes for which the information is collected at the time information is collected, or as soon as practicable thereafter. An individual may, at any time, request or be given an explanation of how their personal information is being used.
2.4 If the Association of African Universities proposes to use, disclose or retain personal information for a purpose not previously identified, the new purpose will be identified and documented prior to the new use. Unless the new purpose is required or permitted by law, the consent of the individual will be obtained before the information can be used, disclosed or retained for that purpose. (See Obtaining Consent below)
Principle 3 – Obtaining consent
The Association of African Universities will obtain the consent of individuals before or when it collects, uses, discloses or retains personal information, except where authorized by law.
3.1 The Association of African Universities may collect, use, disclose or retain personal information without the knowledge or consent of individuals. All of the circumstances in which the Association of African Universities may collect, use, disclose or retain personal information without the knowledge or consent of an individual shall be only as specified and permitted by legislation.
3.2 In obtaining consent, the Association of African Universities will use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used, disclosed and retained. Purposes will be stated in a manner that can be reasonably understood by the individual.
3.3 Generally, the Association of African Universities will seek consent to use, disclose and retain personal information at the same time it collects the information. However, the Association of African Universities may seek consent to use and disclose personal information after it has been collected, but before it is used, disclosed or retained for a new purpose.
3.4 The Association of African Universities will require individuals to consent to the collection, use, disclosure and retention of personal information as a condition of the supply of information or services to the individual only if such collection, use, disclosure and retention is necessary to provide the information or services.
3.5 In determining the appropriate form of consent, the Association of African Universities will take into account the sensitivity of the personal information and the reasonable expectations of individuals in relation to the purposes for use, disclosure and retention of the information by Association of African Universities.
3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact the Association of African Universities for more information regarding the implications of withdrawing consent.
3.7 Individuals may opt-out or refuse to consent to the use, disclosure or retention of their personal information for marketing purposes by contacting Association of African Universities at AAU Officer on Telephone Number: +233-302-774495 / 761588 or by writing to Privacy Officer, Association of African Universities, and Postal Address: African Universities House, Trinity Avenue, East Legon, Accra.
Principle 4 – Limiting collection of personal information
The Association of African Universities shall limit the collection of personal information to that which is necessary for the purposes identified by Association of African Universities. The Association of African Universities will collect personal information by fair and lawful means.
4.1 The Association of African Universities collects personal information primarily from individuals directly.
4.2 The Association of African Universities may also collect personal information from other sources including:
4.2.1 publishers, list brokers or other associations;
4.2.2 The Association of African Universities may collect personal information about an individual’s family members or beneficiaries from that individual for purposes of providing benefits administration services to the individual, employer, and will in such circumstances rely on the individual to obtain the consent of these other parties.
Principle 5 – Limiting use, disclosure and retention of personal information
The Association of African Universities will not use, disclose or retain personal information for purposes other than those for which it was collected, except with the consent of the individual, or as required or authorized by law. Personal information will be retained only as long as necessary for the fulfilment of those purposes.
5.1 The Association of African Universities may disclose personal information about an individual to the following for the purposes set out in Section 2:
5.1.1 a person who, on the basis of a written authorization from a scholarship applicant or recipient, is seeking the information as an agent of the applicant or recipient;
5.1.2 to the employers using Association of African Universities payroll and benefit services in relation to their employees;
5.1.3 to third parties, for marketing or readership audit purposes (see Sections 2.2);
5.1.4 to a third party, where the individual consents to disclosure or where disclosure is required or authorized by law.
5.2 The Association of African Universities has a records retention policy that specifies the length of time that records are maintained. All personal information is accessible only by Association of African Universities’ personnel, or service providers, who need access to that information for the performance of their duties or services.
Principle 6 – Keeping personal information accurate
The Association of African Universities will keep personal information as accurate, complete and up to date as necessary for the purposes for which it is to be used.
6.1 Information will be sufficiently accurate, complete and up to date so as to minimize the possibility that inappropriate information may be used to make a decision about an individual.
6.2 The Association of African Universities will update personal information about individuals on an on-going basis, only when necessary to fulfill the purposes identified in this Code, or upon notification by the individual.
Principle 7 – Safeguarding personal information
The Association of African Universities will protect personal information with security safeguards appropriate to the sensitivity of the information.
7.1 The Association of African Universities will protect personal information against loss or theft as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held, using appropriate security safeguards.
7.2 The Association of African Universities shall protect personal information transferred to third parties providing services to Association of African Universities through contractual measures or other arrangements stipulating the confidentiality of the information, restricting the purposes for which the information is to be used and prohibiting its disclosure to third parties upon direction from Association of African Universities in accordance with this Privacy Policy.
Principle 8 – Being open about policies and procedures
The Association of African Universities will make readily available to individuals specific information about the Association of African Universities policies and procedures relating to the management of personal information.
8.1 The Association of African Universities will be open about its policies and procedures with respect to the management of personal information. Individuals will be able to acquire information about our policies and procedures at minimal or no cost and without unreasonable effort. This information will be made available in a form that is generally understandable.
Principle 9 – Providing access to personal information
On written request, and subject to the exemptions stipulated by law, the Association of African Universities will inform individuals of the existence, use, disclosure and retention of their personal information and provide access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended where inaccuracies exist.
9.1 In certain situations, the Association of African Universities may not be able to provide access to all of the personal information that it holds about an individual. These situations shall be limited to those required or stipulated by law.
9.2 When an individual successfully challenges the accuracy or completeness of personal information, the Association of African Universities will correct, delete or add information as required. When appropriate, the amended information will be transmitted to any third parties having access to the information in question.
Individuals will be able to obtain more information on the Association of African Universities’ privacy practices, or make a complaint, by contacting:
Privacy Officer
Association of African Universities
African Universities House, Trinity Avenue, East Legon, Accra
Phone: +233-302-774495 / 761588