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Legal

Privacy
Policy.

How we handle personal data across CInHEd websites, applications, and learning services.

Last updated: September 18, 2026

Cunningham Institute of Higher Education ("CInHEd", "we", "us", or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you visit our websites, create an account, apply to a programme, use the learning portal, contact us, or otherwise use our services.

CInHEd is based in Ghana and this policy is intended to reflect the requirements and principles of Ghana's Data Protection Act, 2012 (Act 843). The Data Protection Commission is Ghana's data-protection regulator. This policy does not replace advice from a qualified Ghanaian lawyer or the organisation's obligations to register, maintain records, appoint responsible personnel, or implement operational controls where required by law.

1. Who is responsible for your data?

CInHEd is the data controller for personal data we collect and use for our own institutional, admissions, academic, account, payment, communications, and website purposes. For some services, a third-party provider may process data on our instructions or act as an independent controller under its own privacy notice.

2. Personal data we collect

Depending on how you use our services, we may collect:

  • Identity and contact data: name, title, date of birth, gender, nationality, email address, phone number, and contact or address details.
  • Account data: username, login and security records, email-verification status, password-reset records, and account preferences. Passwords are stored in protected form and are not intended to be readable by staff.
  • Admissions and academic data: educational history, programme choices, application information, student records, results, communications, and supporting documents.
  • Identity and sensitive documents: passport or national ID details, uploaded documents, photographs, and information needed for admissions, verification, visas, graduation, or related services.
  • Payment and transaction data: invoices, payment status, receipts, references, fee information, and related correspondence. Payment providers may collect payment credentials under their own terms.
  • Communications: messages, enquiry details, support requests, survey responses, and information you provide in forms or email.
  • Technical and usage data: IP address, browser and device information, approximate location derived from technical data, pages or features used, timestamps, security events, and cookies or similar technologies.

3. How we collect data

We collect data directly from you when you register, apply, submit documents, make an enquiry, use the portal, make or reference a payment, or contact us. We may also receive data from authorised representatives, partner institutions, payment or communication providers, public sources, and other people or organisations involved in an application or academic service.

4. Why we use personal data

We use personal data to:

  • create and secure accounts, authenticate users, and provide the learning portal;
  • process admissions, enrolment, applications, verification, academic administration, and student support;
  • provide requested programmes, services, documents, communications, and customer support;
  • process fees, invoices, payments, refunds, scholarships, and related financial administration;
  • send service notices, academic updates, administrative messages, and—where permitted—marketing communications;
  • operate, maintain, troubleshoot, improve, and secure our websites, systems, and services;
  • prevent fraud, abuse, unauthorised access, and other security incidents;
  • meet legal, regulatory, reporting, safeguarding, audit, and institutional obligations; and
  • perform other purposes explained at the point of collection or authorised by applicable law.

5. Consent and other legal grounds

Depending on the context, we process personal data because you have consented, because it is needed to provide a service or take steps at your request, because we have a legal or regulatory obligation, or because it is reasonably necessary for our legitimate institutional and security interests. Where we rely on consent, you may withdraw it by contacting us, although withdrawal will not affect processing already carried out lawfully and may mean that we cannot provide a related service.

6. When we share personal data

We may share personal data, only as reasonably necessary, with:

  • staff, faculty, contractors, and service providers who need it to perform their duties;
  • technology, hosting, email, communications, security, payment, document, and support providers;
  • academic, accreditation, examination, partner, scholarship, visa, or professional bodies where required for the relevant service or authorised by you;
  • banks, payment processors, auditors, insurers, professional advisers, and debt or fraud-prevention services where appropriate;
  • courts, regulators, law-enforcement bodies, or other authorities when required or permitted by law; and
  • an acquiring or successor organisation if CInHEd or part of its operations is reorganised or transferred.

We do not sell personal data. We require service providers acting on our behalf to handle data only for authorised purposes and to apply appropriate confidentiality and security measures.

7. International processing

Some technology and service providers may process data outside Ghana. Where this happens, we will take reasonable steps to use reputable providers, limit the data shared, protect it through contractual or other safeguards, and comply with applicable Ghanaian requirements for cross-border processing.

8. Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, to provide ongoing services, to resolve disputes, to maintain institutional and academic records, to meet legal or regulatory requirements, or to protect our rights. Retention periods vary by record type. When data is no longer needed, we delete, anonymise, or securely dispose of it, subject to lawful exceptions.

9. Security

We use reasonable technical and organisational safeguards appropriate to the nature of the data and the risks involved, including access controls, protected authentication, secure transmission where available, monitoring, backups, and staff or provider confidentiality obligations. No online service can be guaranteed completely secure. You should use a unique password, protect your devices, and report suspected account or data incidents promptly to info@cinhed.com.

10. Cookies and similar technologies

We may use cookies, session tokens, and similar technologies to keep you signed in, protect forms, remember preferences, understand how services are used, and support communications or chat features. You can manage cookies through your browser settings, but disabling necessary cookies may affect sign-in or core functionality. Third-party services embedded in the website may use their own cookies or technologies under their own policies.

11. Your data-protection rights

Subject to applicable law and reasonable verification of your identity, you may ask us for information about our use of your personal data and may request access to, correction of, or appropriate deletion of inaccurate or no-longer-needed data. You may also object to certain processing, withdraw consent where consent is the basis, and object to direct marketing. Some records must be retained or processing must continue because of a legal, academic, security, or contractual requirement.

To exercise a right or ask a privacy question, contact info@cinhed.com. You may also contact Ghana's Data Protection Commission if you believe your data has been mishandled or your concern has not been resolved.

12. Children and young people

Our services are intended for prospective and current learners and other members of the education community. We do not knowingly collect personal data directly from children under 13 through the website. Where a programme or service involves a person under the age of majority, we may require a parent, guardian, or other authorised adult to provide consent or assist with the process where appropriate.

13. Changes to this policy

We may update this policy when our services, data practices, or legal obligations change. We will publish the updated version on this page and change the date above. Material changes will be communicated through a reasonable channel where appropriate.

14. Contact us

For privacy questions, requests, or complaints, contact:

Cunningham Institute of Higher Education (CInHEd)
East Legon, Accra, Ghana
info@cinhed.com
+233 (0) 542 983 877