Privacy & Consent Policy

This policy is reviewed at least annually, and sooner if: Nigerian data protection law or NDPC guidance materially changes; the Academy launches a feature that changes what personal data is collected or how it is shared (most notably, the donor portal and public marketing site currently in design); a data breach or near-miss reveals a gap; or the Academy's scale crosses one of the trigger thresholds referenced in this policy (e.g., the DPO threshold in Section 6.2). Material changes are communicated to staff, and where they affect previously given consent, to the affected beneficiaries, guardians, donors, or partner organizations.