6.1 Data Controller
Eifen & Eighth Academy is the data controller for all personal data described in this policy: it alone decides why and how that data is processed. [Insert registered office address], [Insert CAC/RC number]. General privacy enquiries: hello@eifeneighth.org.
6.2 Data Protection Officer / focal point
The NDPA requires data controllers "of major importance" — a designation the NDPC applies based on the volume and risk profile of personal data processed, or on revenue thresholds it sets — to appoint a qualified Data Protection Officer. At its current scale (a handful of active cohorts and roughly ten beneficiaries, per the Academy's own program records), Eifen & Eighth Academy does not process personal data at a volume that meets that threshold. Consistent with the same "build for now, revisit at a trigger point" approach the Academy already uses for its systems, we designate a Data Protection Focal Person now and commit to appointing a formally qualified DPO and registering with the NDPC once either of the following is met, in line with the NDPC's General Application and Implementation Directive (GAID) 2025 compliance-audit thresholds: personal data of more than 1,000 data subjects processed within any 6-month period, or more than 2,000 within any 12-month period.
Data Protection Focal Person: [Insert name and role — e.g., the Founder, until a dedicated appointment is made]. Contact: hello@eifeneighth.org.
6.3 Internal roles
Access to personal data inside the Foundation Operations Platform is role-based, not all-or-nothing. The table below reflects the platform's access model as designed:
Role
Beneficiary data
Donor & financial data
Notes
Founder / Super Admin
Full access
Full access
Sole role with user/role administration rights; sets consent flags and any future public-facing settings.
Program Staff
Full access (intake, cohort assignment, outcome logging)
Read-only
No delete rights on financial records.
Finance Staff
Read-only, limited to name + cohort (no contact details or notes)
Full access (records donations/expenses, manages funds)
Restricted from beneficiary contact information and case notes — finance does not need it to do its job.
Mentor / Volunteer
Create/read outcomes only for beneficiaries they are assigned to; no other beneficiary data
None
Row-level scoping, not just role scoping — a mentor cannot see beneficiaries outside their own assignment.
Donor (future donor portal)
None (individually identifying data)
Read-only, limited to their own donations and the fund(s) they contributed to
Sees aggregate, anonymized impact of their own giving — never another beneficiary's identifying data.
Public website visitor (future)
None (individually identifying data)
None
Aggregate counts only, below any threshold that could identify an individual.
Object-level restrictions (for example, a mentor being limited to their assigned beneficiaries, or a donor to their own donations) are enforced in the system itself, not left to staff discretion or hidden only in the interface.
6.4 Data processors
Third parties that process personal data on the Academy's behalf and under its instructions — for example, its hosting provider — are data processors, not independent controllers. The Academy is responsible for choosing processors that can meet the security and confidentiality standards in this policy (Section 20) and for having a written agreement with each one covering how they may use the data.