DASSA Research Platform

What Are Cookies?

Cookies are small text files stored on your device (computer, smartphone, tablet) when you visit a website. They are designed to store basic information and help improve your browsing experience. Cookies are not viruses or computer programs and do not take up much space.

Types of Cookies We Use

How to Manage Cookies

Some services on this website require us to collect personal information from you. To comply with data protection legislation, we must tell you how we collect, process,store distribute and delete the information we collect and how it is used. Any information you submit will be stored securely and will never be passed on or sold to any third party.

User anonymity and personal information

Log files are maintained and analysed to monitor website usage. Log files do not capture personal information but do capture your IP address, which is automatically recognised by our web servers.

Aggregated analyses of these log files may be made available to DASSA staff and partner agencies to allow us to measure (for example) what works within the platform, user traffic, overall utility of the different parts of the platform of and the typical user paths through the site. This plus other technical data allows us to improve your user experience and maintain the website.

DASSA will not attempt to identify individual users except to ratify that they are human. You should be aware, however, that access to platform will generally create log entries in the systems of your ISP or network service provider. These entities may be in a position to identify the user computer equipment used to access a page. Such monitoring would be done by the provider of network services and is beyond the responsibility or control of DASSA.

DASSA will make no attempt to track or identify individual users, except where there is a reasonable suspicion that unauthorised access to systems is being attempted or where inquiry with respect to processing of data is necessary. DASSA will also not process any personal data within the datasets any user. That responsibility lies solely on the user. In the case of all users, DASSA reserves the right to attempt to identify and track any individual who is reasonably suspected of trying to gain unauthorised access to computer systems or resources operating as part of DASSA services.

As a condition of use of this site, all users must give permission for DASSA to use its access logs to attempt to track users who are reasonably suspected of gaining, or attempting to gain, unauthorised access.

All log file information collected by DASSA is kept secure, and no access to raw log files is given to any third party.

Use of cookies

This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used solely on a ‘per session’ basis or to maintain user preferences. Cookies are not shared with any third parties.

Website Traffic

In order to improve our website structure and functionality, we count the number of visitors and how visitors move around the website. More specifically, we are tracking the following fully anonymised information:

• Masked 2 byte(s) IPs - e.g., 192.168.xxx.xxx
• Date and time of a page request
• Title of the page being viewed (Page Title)
• URL of the page being viewed (Page URL)
• URL of the page that was viewed prior to the current page (Referrer URL)
• Screen resolution being used
• Time in local user’s timezone
• Files that were clicked and downloaded (Download)
• Links to an outside domain that were clicked (Outlink)
• Pages generation time/Page speed (the time it takes for webpages to be generated by the webserver and then downloaded by the user)
• Main Language of the browser being used (Accept-Language header)
• User Agent of the browser being used (User-Agent header)

We are not collecting personal data or geolocation information.

This information is hosted within the territory of Kenya.

DATA PRIVACY STATEMENT

DASSA[The Platform] is the premier data sharing platform for all scientific data generated within the African continent. DASSA as a trusted research environment (TRE) which hosts various capabilities for users to access, upload, review, share discuss and therefore generate new knowledge from existing silos across Africa

Regulation

All personal data collected will be processed in accordance with the provisions and principles encapsulated within the Data Protection Act, 2019, the relevant regulations under it as well as the General Data Protection Regulation-2016/679[GDPRR] and its accompanying regulations. Should there be any conflict of Laws, then DASSA will apply a strict test to ensure compliance with these rules.

The Datasets shared onto the DASSA platform especially those relating to health data must therefore comply with global benchmarks on data sharing. It is now globally accepted that historical, statistical, journalistic, literature, and art or scientific research may be conducted by the processing of consented data.

• Scientific Research: The processing of personal data for scientific research is necessary for public interest in advancing knowledge and understanding of health and diseases.
• Historical Research: This is necessary for preserving and studying historical events and their impact in the society.
• Statistical Research: Health care providers can carry out statistical research using health data for purposes of monitoring trends in disease incidences and the prevelance to predit and control any disease.

Privacy by Design

DASSA employs several approaches in an effort to embed privacy principles within its system. Without exception, all users by acceding to this privacy policy are aligning themselves to a strict standard of compliance to the territorial jurisdictions where their data sets were collected and to the greatest degree indemnify DASSA from any suits that would arise from such non-compliance deliberate or otherwise.

Purposes as to Why We Collect Several Types of Data

DASSA mandates all datasets to have employed the following principles in Data Management in Health Research within DASSA

• Personal Data. This is any information that relates to an identified or identifiable natural person. It includes things such as names, age, identification card numbers, passport numbers, telephone numbers, postal addresses, email addresses, credit card details, debit card details, country of origin, and or residential addresses. Such information is collected for purposes of ensuring that you are properly identified, effective communication between yourself and the platform is seamless and there is provision of quality services to the data subjects
• Sensitive Personal Data. This is information that reveals the natural person’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details, including names of a person’s children, parents, spouse or spouses, sex or sexual orientation. The Platform appreciates that data subjects come from diverse backgrounds that vary.

DASSA shall only NOT process personal data, unless the processing is necessary: -

• For the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject before entering into a contract
• For compliance with any legal obligation to which the The Platform is subject
• In order to protect the vital interests of the data subject or another natural person.
• For the performance of a task carried out in the public interest or in the exercise of official authority vested in The Platform
• For the performance of any task carried out by a public authority with a claim on the specific data.
• For the legitimate interests pursued by the platform or to a third party to whom the data is disclosed, except if the processing is unwarranted in any particular case having regard to the harm and prejudice to the rights and freedoms or legitimate interests of the data subject; or
• For the purpose of historical, statistical, journalistic. literature and art or scientific research
• Further processing of personal data shall be in accordance with the purpose of collection.

Note:

Where the Platform may need to use a data subject’s personal data for unrelated purpose, the Platform will notify the data subject and explain the grounds thereof and seek consent for such process such data for that unrelated purpose. Personal data shall not be used for unrelated purpose without consent.

The Platform may ONLY process personal data without the knowledge and or consent of the data subject to the extent that is permissible by the Data Protection Act, 2019.

Determination of what specific personal data and or sensitive data is collected is dependent on the product(s) or services(s) that one may need from the Platform. Such determining factors may include but not limited to: -

• Provision of health services
• Provision of academic services
• Management of and improvement of the Platform’s relationships with users and service provider engagements and development analysis
• Need to engage in business related contractual engagements such as those relate to supply chain management and financial management
• Legal compliance and public purposes such as the need to meet our legal obligations by cooperating with public authorities whenever they make lawful requests, compliance with court orders and government regulations
• Engagement of consultants
• Need to ensure that there are proper working communication channels between the Platform and the data subjects
• Enhancement of both the safety of the Platform and the data subject in the internet space
• Purposes of enabling third party service providers to effectively provide product(s) and service(s) to the Platform
• To ensure business contingency planning and response to active incidents
• For proper investigation and responding to complaints relating between the Platform relationship with data subjects so as to maintain and or improve quality in service delivery
• For research and other statistical and artistic trend analysis conducted by way of de-identifying and aggregating or anonymizing source data with that of other data subjects and institutions to ensure that it cannot be re-worked so as identify the data subjects.

DASSA has commenced the process of registration with the different offices of the data protection commissioner(ODPC). For instance, DASSA is already registered with the office of the ODPC(Kenya)as a Data Controller and a Data Processor pursuant Section 18 of the Data Protection Act(K). DASSA has a duly appointed Data Protection Officer who may be reached via email sent to…………………… who will respond to any privacy related queries within 24 hours.

At DASSA we are committed to ensure that all personal data collected by us such as a natural person’s race, health status, social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of a person’s children, parents, spouse, sex or the sexual orientation of patients and residents is processed in a fair and transparent manner, with appropriate data protection measures in place to safeguard personal data against unauthorized access, disclosure, or loss.

DASSA has put procedures in place to protect against breaches in data security and will notify data subjects and any applicable regulator of any suspected breach, where legally necessitated to do so.

While processing personal data in our possession DASSA shall uphold the key principles of lawfulness, transparency, purpose limitation, integrity, confidentiality, and availability, data minimization, accuracy, storage limitation and fairness.

To be precise, DASSA commits to ensure that all personal data shall be: -

• Processed in accordance with the right to privacy of the data subject.
• Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
• Collected for explicit, specified, and legitimate purposes and not further processed in a manner incompatible with those purposes.
• Adequate, relevant, limited to what is necessary in relation to the purposes for which it is processed.
• Collected only where a valid explanation is provided whenever information relating to family or private affairs is required.
• Accurate and, where necessary, kept up to date, with every reasonable step being taken to ensure that any inaccurate personal data is erased or rectified without delay.
• Kept in a form which identifies the data subjects for no longer than is necessary for the purposes for which it was collected.