Data Privacy Policy

Introduction

The Students Loan Trust Fund, hereafter referred to as ‘SLTF’ is an agency under the Ministry of Education; established in 2005 and operates under SLTF’s Act 2011, of Act 820. Our core mandate is to provide financial resources to needy students pursuing accredited progammes of study at both private and public accredited tertiary institutions as enshrined in Articles 25 and 38 of the 1992 Constitution of Ghana.

This Data Privacy Policy basically specifies some or all of the ways the organization collects, retrieves, alters, uses, stores, manages and disclosespersonal data of borrowers, guarantors, suppliers, business partners, employees and other stakeholders’.

It also spells out what SLTF would or will not do with the information of the above-mentioned persons hereafter referred to as “data subjects”, as well as the guarantee to protect the confidentiality of the personal data of same.
This is to ultimately fulfil a legal requirement to effectively safeguard the personal data rights, otherwise called privacy rights of data subjects as stipulated in the Data Protection Law 2012 (Act 843), of Ghana. In effect, it gives free will to the data subjects to either agree or disagree with SLTF’s corporate principles in relation to the above.

As a loan applicant, borrower, guarantor, supplier or any other stakeholder you consent to the collection, retrieval, use, alterations, transfer, disclosure and any other uses of your information described in this Privacy Policy. Irrespective of where you reside or supply the information from, you authorize SLTF to use your information in all other offices we operate.

By accessing our website, loan application portal, social media pages and any other medium of communication to transact business with us, you are deemed to have read and agreed fully to the terms and conditions hereafter set forth (the “Privacy Policy”). You should read these terms and conditions before using the website or transacting business with SLTF in any way.

If you do not accept in full these terms and conditions in this Privacy Policy, please do not proceed with any loan application process or any other business transactions with SLTF.
You must stop whatever process immediately with SLTF. A data subject has the choice or free will to opt out even in the middle of any transaction if they so desire.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to the Trust Fund and its staff collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Trust Funds’ authorized service providers and relevant third parties in the manner set forth in this Data Privacy Policy.

This Data Privacy Policy supplements but does not supersede nor replaces any other consents which you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

This Privacy Policy may be revised from time to time. Periodic, updates will be posted on our website and your transaction with us after such changes have been posted, will constitute your agreement to the modified Privacy Policy and all of the changes.

The purpose of this document (“Data Privacy Policy”) is to inform you of how the Trust Fund manages Personal Data (as defined below) which is subject to the Data Protection Act 2012 (Act 834).

Please take a moment to read this Data Privacy Policy so that you know and understand the purposes for which we collect, use, disclose and secure your Personal Data.

What Types of Personal Data Do We Collect?

In this Data Privacy Policy, “Personal Data” refers to any data about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, date of birth, passport photo, Social Security and National Insurance Trust (SSNIT) Number, E-zwich Number, passport or other identification number, gender, marital status, orphanage status, telephone number(s), mailing address, email address(es), residential address, disability information, salary information, bank account details, educational history information, employment history information, household details (such as dependants, assets etc) and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other means of interaction with you.

We may supplement the Personal Information you submit to us with information from third-party sources such as SSNIT, Ghana Interbank Payment and Settlement Systems (GhIPSS), Credit Reference Bureaus, Partner Banks etc to validate some of the personal data you provided as well as debt collection.

The Personal Data we collect can be either obligatory or voluntary. Obligatory Personal Data are those that we require in order to provide you with our products and services.
If you do not provide us with the requisite obligatory Personal Data such as date of birth; email address; Telephone No. etc., we would not be able to provide you with our products and services.
Voluntary (Optional) Personal Data such as middle names are not mandatory in order for us to provide you with our products and services. If you do not provide us with such voluntary Personal Data, you can still sign up for our products and services. Obligatory and Voluntary Personal Data differ for each products and services and will be indicated in the loan application forms.

Consent

When you request information or sign up for our products and services, you may be required to provide us with your Personal Data. In doing so, you agree and consent to the Trust Fund and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in accordance with this Data Privacy Policy.

You have the choice, at any time, not to provide your Personal Data or to withdraw your consent to the Trust Fund processing your Personal Data. However, do note that, failure to provide such Personal Data or a withdrawal of your consent for us to process your Personal Data may result in the Trust Fund being unable to provide you with effective and continuous products and services.

If you should withdraw your consent to the processing or handling of your Personal Data in respect of any purpose which we may reasonably consider to be essential in order for us to provide you with the products and/or services requested or applied for, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship which may be in place between us.
Furthermore, we shall be entitled to treat such withdrawal as your termination of any account or agreement which you may have with us, without prejudice to any rights and remedies which we may have at law against you.

Notwithstanding the generality of the foregoing and for avoidance of doubt, upon the termination or expiry of your contractual relationship with us (howsoever caused), we may still continue using or disclosing your personal data as may be necessary, required, authorized or permitted for compliance with applicable law or as may be requested by the relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which we may be subject, whether situated locally or overseas.

How do We Collect Your Personal Data?

1. Generally, we collect your Personal Data in the following ways:
   1. when you submit any form, including but not limited to application forms or other forms relating to any of our products or services;
   2. when you use some of our services provided through online and other technology platforms including but not limited to websites, social media platforms, Apps and any online accounts established with us;
   3. when you sign up for or use any of the many services we provide or when you register an account at any of the Trust Fund applications such as website, mobile application, students loan application system etc.;
   4. when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, business partners, ex-employer, public agencies or relevant authorities;
   5. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
   6. when you interact with our staff, including board of trustees, consultants, contractors and temporary personnel (National Service Persons etc.), example via telephone calls (which may be recorded for quality assurance and security purposes), letters, fax, face-to-face meetings, WhatsApp and Emails;
   7. when you participate in customer surveys;
   8. when you submit a job application;
   9. when your images are captured by us via closed-circuit television cameras (“CCTVs”) while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
   10. through physical access, internet and information technology monitoring processes;
   11. when you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
   12. when you are contacted by, and respond to, our agents and other service providers;
   13. connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or
   14. when you submit your Personal Data to us for any other reason.
2. When you browse our website, you generally do so anonymously but please pay attention to the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials. The following entails the use of cookie information collected on our website and/or students’ loan portal:
   1. When you interact with us on our websites or students’ loan portal, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser you are on, what operating system you are using, your IP address, and your click stream information and time stamp (for example, which pages you have viewed, the time the pages were accessed and the time spent per web page).
   2. Cookies are small text files placed or stored on your computing or other electronic devices that can be recalled by a web server in the domain that placed the cookie. Cookies allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on you.
   3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. Please refer to your browser documentation to check if cookies have been enabled on your computer or to request not to receive cookies. However, you may not be able to enter certain part(s) of our website, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our website or any of our web applications.
3. If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, guarantor or a “Connected Person” by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.“Connected Person” may include but is not limited to any authorized signatory; senior public servants; Metropolitan, Municipal & District Chief Executives; senior medical officers; coordinating directors; members of recognized professional bodies (lawyers, accountants, engineers etc.); ministers of recognized religious bodies; senior police officers; senior officers of the Ghana armed forces.
4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You agree to inform the Trust Fund immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as the Trust Fund may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

What is the Purpose of Collecting and Processing Your Personal Data?

1. Generally, we collect, use and disclose your Personal Data for the following purposes:
   1. process your application for student loan;
   2. verifying your identity and student/customer due diligence;
   3. determine whether you are eligible for student loan;
   4. make payment (disbursement) of student loan;
   5. maintain accurate and up-to-date records;
   6. answer queries you (or your parent(s) or partner) might have in relation to your student loan application;
   7. process any complaint or appeal you submit;
   8. administer and/or pursue the repayment of any loan and/or overpayment of student loan you receive;
   9. develop new products;
   10. for research and statistical purposes;
   11. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
   12. managing the administrative and business operations of the Trust Fund and complying with internal policies and procedures (including but not limited to facilitating business continuity planning) ;
   13. audit purposes;
   14. matching any Personal Data held which relates to you for any of the purposes listed herein;
   15. resolving complaints and handling requests and enquiries;
   16. preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of the Trust Funds’ proprietary and sensitive information) ;
   17. providing media announcements and responses, for example in relation to complaints or law suits;
   18. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand student behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
   19. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances) ;
   20. managing and preparing reports on incidents and accidents;
   21. organising events, seminars or trainings;
   22. complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to the Trust Fund or that it is expected to comply, according to:
   23. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies;
   24. to assist in law enforcement and investigations by relevant authorities;
   25. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
   26. archival management (including but not limited to national archives and retrievals) ; and/or
   27. any other purpose relating to any of the above.
2. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by the Trust Fund, we collect, use and disclose your Personal data for the following purposes:
   1. managing project tenders or the supply of goods and services;
   2. processing and payment of vendor invoices;
   3. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks) ; and/or
   4. any other purpose relating to any of the above.
3. If you submit an application to us as a candidate for an employment, we collect, use and disclose your Personal Data for the following purposes:
   1. conducting interviews;
   2. processing your application (including pre­recruitment checks involving your qualifications) ;
   3. providing or obtaining employee references and for background screening;
   4. evaluating and assessing your suitability for the position applied for; and
   5. any other purposes reasonably related to any of the above.
4. If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, the Trust Fund may contact you using such telephone number(s) (including voice calls, text, fax or other means) with information about our products and services.
5. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
6. You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, we will require some time to process your withdrawal request. During this period of time you may still receive marketing or promotional materials/communication.
7. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products or services that you have subscribed to with the Trust Fund.

Disclosure of your Personal Data

The Trust Fund will take reasonable steps to keep your Personal Data confidential as well as protect it against unauthorised disclosure. However, in order to provide you with effective and continuous products and services, and for the purposes listed above (where applicable), your Personal Data may be disclosed to the following entities or parties:

1. Banks and other Financial Institutions;
2. Universities, Colleges, and Training Institutions;
3. Employers;
4. Credit Bureaus and Credit Reporting Agencies;
5. Debt Collection Agencies;
6. Contractors, vendors, installers, or third party service providers who provide administrative or operational services to the Trust Fund, such as courier services, telecommunications, information technology, payment (disbursement of loans), validation of ID numbers, loan processing, repayment collection, training, market research, storage, archival or other services to the Trust Fund such as SSNIT, GhIPSS, Controller and Accountant General’s Department (CAGD), National Health Insurance Authority (NHIA), National Identification Authority (NIA), Driver and Vehicle Licensing Authority (DVLA), Passport Office etc.;
7. Third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your loan account held with us;
8. Any person (1) who provides security or acts as surety for your liabilities and obligations to the Trust Fund or (2) for whom you act as surety or third party security provider;
9. Contractors, vendors or other third party service providers in connection with promotions, online campaigns, products and services offered by us;
10. Our professional advisers such as our auditors and lawyers;
11. Corporate service providers or lawyers, who are appointed by you;
12. Collection agencies in relation to the enforcement of repayment obligations for loans;
13. Third parties who organise promotional or marketing events, seminars or trainings;
14. Relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which the Trust Fund may be subject; and
15. Any other party to whom you authorise us to disclose your Personal Data to.

Data Security (Protection of Your Data)

1. The security of your Personal Data is our priority. The Trust Fund takes all physical, technical and organisational measures necessary to ensure the security and confidentiality of Personal Data. We have put in place reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks and ensure that your Personal Data remain safe, secure and private. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website or web applications (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using web applications and take any necessary precautions.
2. Employee access is only limited to authorised employees who are fully trained in handling your information. These authorised personnel are required to ensure the confidentiality of your information and to respect your privacy at all times. Employees who have access to your information will be subjected to disciplinary action should they fail to observe this Data Privacy Policy and other guidelines, codes or policies which we may issue to them from time to time.
3. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
4. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
5. We have put in place procedures to deal with any suspected data security breach and will notify you any applicable regulator of a suspected breach where we are legally required to do.
6. If we disclose any of your Personal Data to our authorised service providers, we will require them to appropriately safeguard the Personal Data provided to them.

Third-Party Sites

Our website and/or students’ loan portal may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website.
We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

Data Retention

We will only retain your Personal Data and that of your spouse and your relatives and guarantors for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, as well as any relevant legal requirements. In some circumstances we will retain personal data indefinitely, generally for the purposes described above.

Access and Correction of your Personal Data

1. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested / applied for.
2. We are committed to ensure that the Personal Data we hold about you is accurate, complete, and up-to-date. If there are any changes to your Personal Data or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your Personal Data.
3. You have the right to access your Personal Data. If you would like to request access to your Personal Data, please contact us. We may also take steps to verify your identity before fulfilling your request for access to your Personal Data.
4. If your Personal Data has been provided to us by a third party, you should contact that such party directly to make any queries, feedback and access and correction requests to the Trust Fund on your behalf.
5. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, the Trust Fund may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with the Trust Fund and your being in breach of your contractual obligations or undertakings, and the Trust Fund’s legal rights and remedies in such event are expressly reserved.
6. You have a right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. Your right to make such a request will arise in specific circumstances, for example, where data is no longer necessary for the purpose for which it was collected or where you withdraw your consent for processing your data (and this is the sole basis on which your data is processed).We will consider this request in accordance with our obligations under data protection law, only where there is no outstanding balance on the account. Please contact us if you want to delete your personal data.
7. You have a right to block or suppress the processing of your personal data in certain circumstances. If for example you contest the accuracy of the personal data, processing may be restricted until the accuracy of the personal information has been verified. This may also apply where you contest that the processing is unlawful. Please contact us if you want to restrict the processing of your personal data.
8. You have the right to object to the processing of your personal data if it is based on the performance of a task carried out in the public interest. You also have a right to object where we process your information for research purposes. We will consider any request in accordance with our obligations under the data protection law. Please contact us if you want to object to us processing your personal data.

Review of this Policy

This policy may be updated from time to time to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. If there are material changes to this Policy, we will notify you by posting a notice of such changes on our website or by sending you a notification directly.
Do periodically review this Data Privacy Policy to stay informed on how we are protecting and managing your information.

Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Privacy Policy.

How to Contact Us

All feedback, withdrawal of consent, access and correction of your Personal data, questions, comments or other communications relating to your Personal Data or this Privacy Policy should please, be directed by email to dps@sltf.gov.gh or:

to SLTF via post The CEO/Data Protection Supervisor Students Loan Trust Fund P.O. Box CT 223, Cantonments Asylum Down, Accra

Access via Telephone: +233 (0302) 231 886/7 Fax: +233 (0302) 231 873 Access via the Web: www.sltf.gov.gh