Data protection
v0.1-draft · last reviewed 15 September 2026
Working draft. This page says how Clarvyn intends to operate. It has not been reviewed by a Ghana-qualified lawyer, and the wording will change when it is. We publish it now because a school deciding whether to trust us with children’s records should be able to read what we claim to do. Tell us where it is wrong: support@clarvyn.ai.
Who is responsible for what
The school is the data controller. It decides which children are enrolled, what is recorded about them, which staff see what, and how long a record is kept. Clarvyn is the processor: we store and move that data on the school’s instructions and for no other purpose.
This split matters when you want something done. A request to correct a child’s date of birth or a guardian’s phone number is the school’s to action, and the school can do it immediately in the console. A request about how Clarvyn itself holds the data comes to us.
The law we work under
Ghana’s Data Protection Act, 2012 (Act 843). It gives you the right to ask for a copy of your personal data, to have it corrected, and to have it deleted. How to exercise those rights is on deleting your account and who to write to.
What is not in place yet
Two things a careful reader will look for, stated plainly rather than implied:
- We are not yet registered with Ghana’s Data Protection Commission. Registration is in progress. When it completes we will publish the certificate number on this page.
- There is no signed processor annex yet. A school signing today gets these published pages and a contract that references them. The formal annex, naming a data protection supervisor, follows counsel review.
What we can already promise, because the software enforces it
- Each school’s records live in their own database schema, separate from every other school’s. See security.
- When Roam Labs staff use platform-level powers, the action is written to an audit table that survives the school being removed.
- We do not sell data, we do not use it for advertising, and we do not use children’s records to train anything. See children’s data.
Where data is stored
On infrastructure operated by the companies named on sub-processors. Clarvyn has not yet pinned a storage region, so data may be processed outside Ghana. We will state the region on this page once it is fixed.
Asking us something
Write to support@clarvyn.ai.