REGISTER AS STUDENT

NEW HIGH EDUCATION

DATA PROTECTION POLICY

Effective Date: 15 May 2026
Organisation: New High Education
Platform: newhigheducation.app (NHE Tutor App)
Website: newhigheducation.com
Email: admin@newhigheducation.com
WhatsApp/Telephone: (+233) 500 390 326
Registered Address: 399 Asafoatse Omanie Street, Kaneshie, Accra, Ghana
Postal Address: P. O. Box GP 3686, Accra, Ghana

1. Introduction

This Data Protection Policy explains how New High Education collects, uses, stores, protects, shares, retains, and disposes of personal data in connection with the NHE Tutor App, the website newhigheducation.com, the AI Tutor, student accounts, parent accounts, teacher accounts, admin dashboards, and related educational services.

New High Education is committed to protecting the privacy, safety, and personal data of students, parents, guardians, teachers, administrators, and other authorised users.

This Policy is designed to support compliance with Ghana’s Data Protection Act, 2012 (Act 843). The Data Protection Commission of Ghana states that Act 843 governs privacy and data security in Ghana and sets out rights, responsibilities, and compliance requirements for personal data processing. (Data Protection Commission)

2. Purpose of This Policy

The purpose of this Policy is to:

  • Protect personal data handled by New High Education

  • Explain how user data is collected and used

  • Protect student information with special care

  • Support lawful, fair, and responsible data processing

  • Guide teachers, admins, staff, and service providers on data responsibilities

  • Prevent unauthorised access, misuse, loss, or disclosure of personal data

  • Explain user rights in relation to personal data

  • Support safe use of the AI Tutor and digital learning systems

3. Scope of This Policy

This Policy applies to all personal data processed through or in connection with:

  • NHE Tutor App

  • newhigheducation.com

  • Student portal

  • Parent portal

  • Teacher portal

  • Admin dashboard

  • Super Admin dashboard

  • AI Tutor feature

  • Registration and approval systems

  • Offline payment verification records

  • Email, WhatsApp, SMS, and support communications

  • Learning records and platform usage data

  • Any related New High Education service

This Policy applies to:

  • Students

  • Parents and guardians

  • Teachers

  • Admins

  • Super Admins

  • Support staff

  • Contractors and service providers where applicable

  • Any person who processes personal data on behalf of New High Education

4. Legal Basis and Ghana Data Protection Framework

New High Education will process personal data in line with applicable Ghanaian data protection requirements.

Ghana’s Data Protection Act, 2012 (Act 843) establishes the Data Protection Commission and regulates the processing of personal information. Act 843 requires personal data to be processed lawfully, reasonably, and without infringing the privacy rights of the data subject. (nita.gov.gh)

New High Education may process personal data where:

  • The user has given consent

  • Processing is necessary to provide educational services

  • Processing is necessary to manage user accounts

  • Processing is necessary for legitimate educational, administrative, safety, or operational purposes

  • Processing is necessary to verify payments or access rights

  • Processing is necessary to protect students or other users

  • Processing is required by law, regulation, court order, or competent authority

  • Processing is necessary to investigate misuse, fraud, safeguarding concerns, or security incidents

5. Definitions

For the purpose of this Policy:

“Personal Data” means information about an individual who can be identified directly or indirectly from that information.

“Student Data” means personal data relating to a student, including registration details, student ID, learning activity, AI Tutor usage, parent links, support messages, and account records.

“Processing” means any activity involving personal data, including collecting, recording, storing, using, sharing, correcting, deleting, retrieving, reviewing, or securing data.

“Data Subject” means the person whose personal data is being processed.

“Data Controller” means the person or organisation that determines the purposes and manner of processing personal data.

“Data Processor” means a person or organisation that processes personal data on behalf of a data controller.

“Sensitive Data” means personal data that requires extra care, including data about children, health, religion, ethnicity, disability, safeguarding concerns, or other private matters.

“We”, “Us”, or “Our” means New High Education.

“User” means any student, parent, guardian, teacher, admin, staff member, or approved person using New High Education services.

6. Data Protection Principles

New High Education will follow these data protection principles:

6.1 Lawful and Fair Processing

We will process personal data in a lawful, fair, and responsible manner.

6.2 Purpose Limitation

We will collect personal data only for clear educational, administrative, safety, payment-verification, communication, or service-related purposes.

6.3 Data Minimisation

We will only collect personal data that is reasonably necessary for the purpose.

6.4 Accuracy

We will take reasonable steps to keep personal data accurate, complete, and up to date.

6.5 Security

We will protect personal data against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

6.6 Retention Limitation

We will not keep personal data longer than necessary for the purpose for which it was collected, unless retention is required for legal, safeguarding, administrative, financial, or legitimate operational reasons.

6.7 Accountability

Teachers, admins, staff, and service providers must handle personal data responsibly and in accordance with this Policy.

7. Types of Personal Data We May Collect

Depending on the user’s role and use of the platform, New High Education may collect the following types of personal data.

7.1 Student Data

  • Full name

  • Student ID

  • Email address

  • Ghana mobile number

  • Date of birth, where required

  • School level, class, or programme

  • Subject interests

  • Registration status

  • Parent or guardian link

  • Learning activity

  • AI Tutor questions and responses

  • Support messages

  • Account status

  • Login and platform usage records

7.2 Parent and Guardian Data

  • Full name

  • Parent ID

  • Email address

  • Ghana mobile number

  • Relationship to student

  • Linked student information

  • Payment verification details where applicable

  • Support communication records

  • Account status

7.3 Teacher and Admin Data

  • Full name

  • Email address

  • Ghana mobile number

  • Role or position

  • Account approval status

  • Access permissions

  • Activity logs

  • Support and administrative actions

  • Communication records

7.4 Payment Verification Data

New High Education does not process payments directly on the website or in the app. Payments are made offline through approved Mobile Money or bank transfer channels.

For payment verification, we may collect:

  • Payer name

  • Student name

  • Student ID or Parent ID

  • Payment amount

  • Payment date

  • Mobile Money transaction ID

  • Bank transfer reference

  • Screenshot or receipt of payment

  • Sender phone number or bank reference details

  • Service or access period paid for

7.5 Technical and Usage Data

  • IP address

  • Device type

  • Browser type

  • Operating system

  • App usage logs

  • Login date and time

  • Pages or features used

  • Error logs

  • Security alerts

  • Referring website or page

8. Special Care for Student and Child Data

New High Education recognises that student data, especially data relating to minors, must be handled with special care.

We will take reasonable steps to:

  • Limit access to student data

  • Protect student identity and contact details

  • Restrict unnecessary collection of student information

  • Avoid using student data for unrelated purposes

  • Prevent unauthorised sharing of student records

  • Handle safeguarding concerns confidentially

  • Involve parents or guardians where appropriate

  • Protect students from online harm, exploitation, bullying, and misuse of data

Teachers, admins, and staff must treat student data as confidential and must only access it where necessary for their approved role.

9. How We Use Personal Data

New High Education may use personal data for the following purposes:

  • Creating and managing user accounts

  • Verifying student, parent, teacher, and admin identities

  • Approving or rejecting account access

  • Providing access to the NHE Tutor App

  • Delivering AI Tutor learning support

  • Supporting student learning and progress

  • Linking parent and student accounts

  • Responding to enquiries and support requests

  • Sending important service notifications

  • Verifying offline Mobile Money and bank transfer payments

  • Managing subscriptions, renewals, or access periods

  • Preventing fraud, impersonation, misuse, and unauthorised access

  • Investigating complaints or safeguarding concerns

  • Improving platform performance and user experience

  • Maintaining security and audit logs

  • Complying with legal or regulatory obligations

10. AI Tutor Data

When users interact with the AI Tutor, New High Education may collect and process information submitted through the AI Tutor.

This may include:

  • Questions asked by students

  • AI-generated answers

  • Follow-up prompts

  • Learning history

  • Feedback on responses

  • Safety flags or misuse alerts

  • Time and date of AI Tutor use

AI Tutor data may be used to:

  • Generate educational responses

  • Improve learning support

  • Maintain continuity of learning

  • Detect harmful or inappropriate use

  • Investigate complaints

  • Improve safety and answer quality

  • Protect students and other users

Users should not submit unnecessary sensitive personal information into the AI Tutor.

11. Offline Payment Data

Because payments are made offline, New High Education may need to collect payment evidence manually.

Users may be asked to send payment proof through approved communication channels such as email or WhatsApp.

Payment verification data will be used only for purposes such as:

  • Confirming payment

  • Activating access

  • Handling renewals

  • Resolving payment disputes

  • Processing refund requests

  • Maintaining financial and administrative records

  • Preventing payment fraud

New High Education will not ask users to enter Mobile Money PINs, debit card numbers, credit card numbers, or online banking passwords into the NHE Tutor App or website.

12. Sharing Personal Data

New High Education will not sell personal data.

We may share personal data only where necessary and lawful, including with:

  • Approved New High Education staff

  • Teachers, admins, or Super Admins with authorised access

  • Parents or guardians where appropriate

  • Cloud hosting and database providers

  • AI service providers

  • Email, SMS, or communication service providers

  • Payment verification or banking-related providers, where necessary

  • Technical support providers

  • Legal, regulatory, or governmental authorities where required

  • Professional advisers such as lawyers, accountants, or auditors where necessary

  • Child protection or law enforcement authorities where a child may be at risk or where unlawful conduct is suspected

Where service providers process personal data on behalf of New High Education, we will take reasonable steps to ensure they handle the data securely and only for authorised purposes.

13. International Data Transfers

Some systems or service providers used by New High Education may store or process data outside Ghana.

Where personal data is transferred or processed outside Ghana, New High Education will take reasonable steps to ensure that the data is protected in a secure and lawful manner.

This may include using trusted cloud service providers, limiting access, applying security controls, and ensuring that data is processed only for approved purposes.

14. Data Security Measures

New High Education will take reasonable technical and organisational steps to protect personal data.

Security measures may include:

  • Secure login systems

  • Role-based access control

  • Restricted teacher and admin permissions

  • Secure cloud hosting

  • Password protection

  • Account verification

  • Audit logs

  • Data access monitoring

  • Secure communication practices

  • Staff and admin confidentiality obligations

  • Data breach reporting procedures

  • Regular review of access rights

  • Suspension of suspicious accounts

No digital system is completely risk-free, but New High Education will take reasonable steps to protect user data.

15. Role-Based Access Control

New High Education will use role-based access to limit what different users can see and do.

User roles may include:

  • Student

  • Parent or Guardian

  • Teacher

  • Admin

  • Super Admin

  • Support or technical personnel

Each role should only have access to the information necessary for that role.

For example:

  • Students should access their own learning account

  • Parents should access only approved linked student information

  • Teachers should access only the information needed for teaching or support

  • Admins should access only the data needed for account management or authorised duties

  • Super Admins should manage role assignment and approvals responsibly

Unauthorised, excessive, or curiosity-based access is prohibited.

16. Confidentiality Duties

All teachers, admins, staff, contractors, and authorised persons must keep personal data confidential.

They must not:

  • Share student or parent data without authorisation

  • Download or copy records unnecessarily

  • Send personal data to private emails without approval

  • Discuss student records publicly

  • Use student data for personal gain

  • Share screenshots of private records

  • Access records outside their duties

  • Disclose safeguarding reports without permission

  • Use personal data for political, commercial, or unrelated purposes

Confidentiality duties continue even after a person’s role with New High Education ends.

17. Data Accuracy and Correction

New High Education will take reasonable steps to keep personal data accurate and up to date.

Users should inform New High Education if their information changes, including:

  • Name

  • Email address

  • Mobile number

  • Student class or level

  • Parent or guardian details

  • Linked student information

  • Payment-related information

  • Role or access status

Users may request correction of inaccurate or incomplete personal data by contacting:

admin@newhigheducation.com

Act 843 allows a data subject who provides proof of identity to request confirmation of whether a data controller holds personal data about them, receive a description of that data, and request correction; it also provides for correction or deletion of inaccurate, irrelevant, excessive, outdated, incomplete, or misleading personal data. (nita.gov.gh)

18. User Rights

Subject to identity verification and applicable legal requirements, users may have the right to:

  • Ask whether New High Education holds personal data about them

  • Request access to personal data held about them

  • Request correction of inaccurate data

  • Request deletion of data where appropriate

  • Object to certain processing where permitted

  • Withdraw consent where processing is based on consent

  • Object to direct marketing

  • Raise a complaint about the misuse of personal data

Requests should be sent to:

admin@newhigheducation.com

New High Education may require proof of identity before responding to any data request.

For student data, New High Education may require parent, guardian, school, or administrative verification before releasing or changing information.

19. Direct Marketing

New High Education may send educational updates, service announcements, or marketing messages where permitted by law or where the user has opted in.

Users may opt out of direct marketing at any time by contacting:

admin@newhigheducation.com

New High Education will not sell student data or use student data for unrelated third-party advertising.

20. Data Retention

New High Education will retain personal data only for as long as reasonably necessary.

Retention periods may depend on:

  • Account status

  • Service access period

  • Educational record needs

  • Payment verification needs

  • Refund or dispute handling

  • Safeguarding requirements

  • Legal or regulatory obligations

  • Security and fraud prevention needs

  • Audit and administrative records

Examples:

  • Active account data may be kept while the account remains active

  • Payment verification data may be kept for accounting, audit, dispute, and refund purposes

  • Safeguarding records may be kept where needed to protect children or comply with legal obligations

  • Technical logs may be kept for security, troubleshooting, and fraud prevention

When personal data is no longer needed, New High Education will take reasonable steps to delete, anonymise, archive, or securely dispose of it.

Act 843 provides that a data controller should delete, destroy, or de-identify records of personal data at the expiry of the retention period, subject to lawful exceptions. (nita.gov.gh)

21. Data Deletion and Account Closure

Users may request account closure or deletion of personal data by contacting New High Education.

Deletion may be subject to:

  • Identity verification

  • Outstanding payment or refund issues

  • Legal retention requirements

  • Safeguarding obligations

  • Fraud investigation

  • Administrative record requirements

  • School or group access arrangements

  • Technical limitations

Where full deletion is not possible, New High Education may restrict, archive, or anonymise the data where appropriate.

22. Data Breach Management

A data breach may include:

  • Unauthorised access to personal data

  • Accidental sharing of student records

  • Loss of a device containing personal data

  • Hacking or account compromise

  • Sending personal data to the wrong person

  • Unauthorised download or copying of records

  • Exposure of payment verification records

  • Misuse of teacher or admin access

Where a breach is suspected, New High Education may:

  • Investigate the incident

  • Secure affected accounts or systems

  • Restrict access where necessary

  • Preserve relevant evidence

  • Assess risk to affected users

  • Notify affected users where appropriate

  • Notify relevant authorities where required

  • Take steps to prevent recurrence

Teachers, admins, staff, and users must report suspected data breaches immediately.

23. Reporting a Data Protection Concern

Users may report privacy or data protection concerns, including:

  • Incorrect personal data

  • Unauthorised access

  • Suspicious account activity

  • Data shared without permission

  • Misuse of student information

  • Payment data concerns

  • AI Tutor data concerns

  • Request for correction or deletion

  • Concern about teacher or admin access

Reports should be sent to:

Email: admin@newhigheducation.com
WhatsApp/Telephone: (+233) 500 390 326

Where possible, include:

  • Full name

  • Account email

  • Student ID or Parent ID, where applicable

  • Description of the concern

  • Date and time of the issue

  • Screenshots or supporting evidence, where safe to provide

24. Staff, Teacher, and Admin Responsibilities

Teachers, admins, Super Admins, staff, and contractors must:

  • Read and follow this Policy

  • Protect all personal data they access

  • Use data only for approved duties

  • Keep login details secure

  • Avoid unnecessary access to records

  • Report data breaches immediately

  • Respect student and parent privacy

  • Follow role-based access rules

  • Avoid copying or downloading data unnecessarily

  • Keep safeguarding information confidential

  • Cooperate with data protection investigations

Failure to follow this Policy may result in restriction of access, disciplinary action, termination of role, or further action where appropriate.

25. Third-Party Service Providers

New High Education may use trusted third-party service providers to support platform operations.

These may include:

  • Cloud hosting services

  • Database providers

  • AI model providers

  • Authentication services

  • Email and SMS providers

  • Analytics and monitoring tools

  • Technical support providers

  • Banking or payment verification support, where necessary

New High Education will take reasonable steps to ensure third-party providers process personal data securely and only for authorised purposes.

Users should also review the privacy terms of relevant third-party services where applicable.

26. Data Protection in Communication Channels

New High Education may communicate with users through email, WhatsApp, telephone, SMS, in-app notifications, or other approved channels.

Users should avoid sending unnecessary sensitive personal information through insecure channels.

When sending support requests, users should include only the information needed to resolve the issue.

New High Education will not ask users to send:

  • Mobile Money PINs

  • Bank passwords

  • Full card details

  • Private security codes

  • Unnecessary identity documents

  • Sensitive information unrelated to the service request

27. Data Protection and Safeguarding

Where data protection and child safeguarding overlap, New High Education will prioritise the child's safety and welfare.

This means personal data may be shared with appropriate persons or authorities where necessary to:

  • Protect a child from harm

  • Investigate abuse or exploitation

  • Prevent bullying, grooming, or harassment

  • Respond to a serious safeguarding concern

  • Comply with legal obligations

Such sharing will be limited to what is necessary and appropriate.

28. Complaints

If a user is unhappy with how New High Education handles their personal data, they may contact us first so we can investigate and respond.

Complaints should be sent to:

admin@newhigheducation.com

Users may also contact the Data Protection Commission, Ghana, which is responsible for data protection matters in Ghana.

29. Relationship With Other Policies

This Data Protection Policy should be read together with:

  • Privacy Policy

  • Terms and Conditions

  • Student Code of Conduct

  • AI Tutor Use Policy

  • Child Protection and Safeguarding Policy

  • Acceptable Use Policy

  • Payment and Refund Policy

  • Parent and Guardian Policy

  • Teacher and Admin Code of Conduct

Where there is a conflict between policies, New High Education will interpret them in a way that best protects student safety, privacy, lawful processing, educational integrity, and platform security.

30. Changes to This Policy

New High Education may update this Data Protection Policy from time to time.

Updates may reflect changes in:

  • Ghanaian law

  • Platform features

  • AI Tutor functionality

  • Payment verification processes

  • Data security practices

  • User roles and permissions

  • Operational procedures

  • Third-party service providers

Updated versions may be posted on the website, app, dashboard, or official communication channels.

Continued use of the NHE Tutor App or related services after updates are posted means that the user accepts the updated Policy.

31. Contact Information

For data protection questions, requests, reports, or complaints, contact:

New High Education
Registered Address: 399 Asafoatse Omanie Street, Kaneshie, Accra, Ghana
Postal Address: P. O. Box GP 3686, Accra, Ghana
Website: newhigheducation.com
Email: admin@newhigheducation.com
WhatsApp/Telephone: (+233) 500 390 326

32. Acceptance of This Policy

By using the NHE Tutor App, website, AI Tutor, student portal, parent portal, teacher portal, admin dashboard, or any related New High Education service, users confirm that they have read, understood, and agreed to this Data Protection Policy.

Teachers, admins, Super Admins, support staff, and authorised personnel must follow this Policy as a condition of their access to New High Education systems and personal data.