Privacy Policy

Open Window University
Effective Date: 21/05/2026

1. Introduction

This Privacy Policy explains how Open Window University (“OWU”, “we”, “us”, or “our”) collects, uses, processes, stores, and protects Personal Data in accordance with the Zambia Data Protection Act, 2021.

This Policy applies to all individuals who interact with OWU, including:

• Prospective students
• Current students
• Alumni
• Employees and job applicants
• Website and system users

By using our Services, you acknowledge that your Personal Data will be processed in accordance with this Policy.

2. Definitions

• “Personal Data”: Any information relating to an identified or identifiable individual
• “Data Subject”: The individual to whom Personal Data relates
• “Processing”: Any operation performed on Personal Data (collection, storage, use, disclosure, etc.)
• “Special Categories of Personal Data”: Sensitive data including health, biometric, or other protected information

3. Legal Basis for Processing

OWU processes Personal Data under the following lawful bases as provided by the Zambia Data Protection Act, 2021:

• Performance of a contract
• Compliance with legal obligations
• Legitimate institutional interests
• Consent (where required)
• Protection of vital interests

4. Categories of Personal Data Collected

4.1 Identity and Contact Data

• Full name, NRC/passport number, student/staff ID
• Date of birth, gender
• Email address, phone number, residential address

Purpose: Identity verification, administration, communication

4.2 Academic Data (Students)

• Applications, qualifications, transcripts
• Course enrolment, grades, assessments
• Attendance and progression records
• Portfolios and submitted coursework

Purpose: Academic delivery, assessment, certification

4.3 Learning Management System (LMS) and Student Portal Data

(Examples include platforms such as Moodle, Canvas, or internal systems)

• Login credentials and access logs
• Course activity, submissions, discussion participation
• Usage analytics and engagement tracking
• Recorded lectures and virtual class participation

Purpose:

• Deliver contact, online and blended learning
• Monitor academic engagement and performance
• Improve teaching quality and platform functionality

Note: LMS activity may be monitored for academic integrity and system security.

4.4 Financial Data

• Tuition payments and billing records
• Sponsorship or bursary information

Purpose: Financial administration and compliance

4.5 Staff and HR Data

For employees and job applicants:

• Employment history and qualifications
• Payroll and banking details
• Performance records and evaluations
• Disciplinary records
• Tax and statutory compliance data
• Next-of-kin and emergency contacts

Purpose:

• Recruitment and onboarding
• Payroll and benefits administration
• Performance management
• Legal and regulatory compliance

4.6 Special Categories of Personal Data

Where necessary, OWU may process:

• Health and medical information (e.g., for accommodations)
• Disability status
• Biometric or identification data (where applicable)
• Data for individuals below the age of 16 with the appropriate consent i.e. from a parent/guardian/legally appointed representative

Legal Basis:

• Explicit consent
• Legal obligations
• Protection of vital interests

4.7 Technical and Usage Data

• IP address, browser type, device information
• Website usage and analytics

Purpose: System security, diagnostics, and service improvement

5. Data Retention

OWU retains Personal Data only for as long as necessary, including:

• Duration of academic enrolment or employment
• Legal and regulatory retention requirements
• Institutional record-keeping purposes

Note: Academic records may be retained indefinitely for verification and certification.

6. Data Sharing and Disclosure

OWU may share Personal Data with:

• Government and regulatory authorities
• Accreditation and examination bodies
• Payment processors and financial institutions
• IT service providers (including LMS providers such as Moodle/Canvas)
• Professional advisors (legal, audit, compliance)

All third parties are contractually obligated to:

• Maintain confidentiality
• Process data only for specified purposes
• Implement appropriate security measures

7. International Data Transfers

Where Personal Data is transferred outside Zambia, OWU ensures:

• Adequate levels of data protection
• Use of contractual safeguards
• Compliance with applicable legal requirements

8. Data Security

OWU implements appropriate technical and organisational measures to safeguard Personal Data, including:

• Access controls and authentication
• Secure data storage systems
• Network and system monitoring
• Staff confidentiality obligations

Despite these measures, no system is completely secure. OWU will respond promptly to any data breach in accordance with legal requirements.

9. Data Subject Rights

Under the Zambia Data Protection Act, 2021, you have the right to:

• Access your Personal Data
• Request correction of inaccurate data
• Request deletion (where applicable)
• Object to or restrict processing
• Withdraw consent (where processing is based on consent)
• Lodge a complaint with the relevant authority

Requests can be made by contacting OWU (see Section 12).

10. Cookies and Tracking Technologies

OWU reserves the right to use cookies to:

• Enable website functionality
• Store user preferences
• Analyse traffic and usage patterns

Users may control cookies through browser settings.

11. Children’s Data

OWU does not knowingly process Personal Data of individuals under the age of 16 without appropriate consent from a parent or guardian.

12. Contact Information

For any queries, requests, or complaints regarding this Privacy Policy or your Personal Data:

Open Window University Email: privacypolicy@owu.edu.zm

13. Policy Updates

OWU reserves the right to amend this Privacy Policy at any time to reflect:

• Legal or regulatory changes
• Updates to institutional practices

The latest version will be published on our official platforms.