Sovereign Educational Data Protection Charter

Data Protection & Statutory Compliance Charter

Institutional legal and technical charter safeguarding student, family, and faculty records across global deployments. Certified compliance with Ghana Act 843, Nigeria NDPR/NDPA, UEMOA directives, UK/EU GDPR, and FERPA/COPPA principles.

Version 4.2 · Updated October 2026DPO: dpo@encore-sms.com100% Zero-Monetization Policy

1. Core Principles of Data Governance

Throughout all operations of the Encore SMS cloud infrastructure, the processing of personal data belonging to educational institutions is governed by six fundamental tenets:

Lawfulness & Educational Purpose

Data is strictly processed for the administration, pedagogy, health oversight, and physical safety of the contracting school.

Data Minimisation Standard

Only information strictly necessary for academic progression, family communications, and statutory reporting is collected.

Accuracy & Permanent Rectification

Guardians and students can inspect and rectify contact profiles and emergency numbers in real-time through verified self-service.

Integrity, RLS & AES-256

Cryptographic database isolation via PostgreSQL Row Level Security; AES-256 at rest and TLS 1.3 in transit.

2. Data Controller vs. Data Processor Architecture

A strict statutory boundary is established under global data protection jurisprudence:

The Contracting School = Data Controller

The institution maintains exclusive proprietary ownership of all pupil rosters, fees, and marks. The school alone determines what data is collected, for which term, and governs parental authorizations.

Encore SMS = Data Processor

Encore SMS processes data strictly upon the verified programmatic instructions of the school. We never monetize, aggregate, sell, or profile student data for third-party advertising or commercial brokerage.

3. Regional Statutory Alignment

  • Ghana — Data Protection Act 2012 (Act 843): Full compliance with the Data Protection Commission (DPC) standards for independent academies and GES/CAIE institutions.
  • Nigeria — Nigeria Data Protection Act 2023 (NDPA / NDPR): Strict enforcement of NDPC mandates regarding minor consent, encrypted auditability, and sovereign regional processing.
  • UEMOA & Côte d'Ivoire — Loi n° 2013-450: Guaranteed compliance with West African Francophone data protection charters governing private and international schools.
  • UK & European Union — UK DPA 2018 & EU GDPR (2016/679): Gold-standard compliance guaranteeing data subject rights, right to data portability, and robust Standard Contractual Clauses.

4. Individual Data Subject Rights

Every parent, adult student, and faculty member retains enforceable rights under our platform architecture:

Right of Access:Inspect the complete digital cumulative record, ledger balance, and attendance tally.
Right to Erasure:Request deletion of non-statutory records upon student withdrawal or school transfer.
Right to Portability:Receive official academic transcripts in portable, structured digital formats.
Right to Rectification:Correct misspelled names, updated guardian delegates, and medical allergies instantly.

5. Incident Response & 72-Hour Breach SLA

Encore SMS maintains a zero-compromise incident protocol. In the event of a verified or suspected security vulnerability impacting tenant data, our technical team is bound by SLA to notify designated school leadership within 72 hours with forensic telemetry and mitigation countermeasures.

6. Educational Cloud & Google Workspace Integration

When schools connect Google Workspace for Education and Google Classroom, pupil identities (name, class section, institutional email) and homework marks are synchronized strictly for instructional purposes. All OAuth 2.0 credentials and refresh tokens are encrypted at rest using AES-256-GCM cryptographic vaults. In strict conformance with the Google Classroom API Terms of Service, student data is never used for commercial profiling or advertising. Institutions maintain full autonomy to revoke permissions and purge credentials at any time from the Integrations Hub.

Office of the Data Protection Officer
Encore SMS International Data Protection Division
Direct Email: dpo@encore-sms.com
Supervisory Inquiries: privacy@encore-sms.com
Accra · Lagos · Abidjan · London