Privacy Policy & Data Protection

Trinswa Medical Training College ("Trinswa", "we", "us", "our") respects your privacy and is dedicated to safeguarding the personal information you entrust to us. This Privacy Policy explains what information we gather, why we gather it, how we handle it, and the choices you have regarding your data.

This policy is guided by the Kenya Data Protection Act, 2019, the Data Protection (General) Regulations, 2021, and other applicable Kenyan laws governing the handling of personal information.

By using our website, submitting an enquiry, or enrolling in any of our programs, you acknowledge that you have read and understood this policy.

1. About Us — The Data Controller

Trinswa Medical Training College is the entity responsible for deciding how and why your personal information is processed.

2. Information We Gather

We collect different types of information depending on how you interact with us.

a) When you send us an enquiry or apply through our website

• Your first and last name
• Email address and phone number
• The course you are interested in (MBBS, Nursing, Paramedical, or Other)
• The subject and content of your message
• A record of when you gave us consent

b) When you enroll as a student

• Full name, email address, and phone number
• National ID or passport number
• KCSE results and academic certificates
• Home county
• Programme selected and how you learned about Trinswa
• Account password (encrypted — we can never see it)
• Next of kin and emergency contact details
• Records relating to clinical attachment and placement

c) When you browse our website

• Pages you visit, how long you stay, and which site referred you (anonymised)
• IP address (converted into a daily hash — it cannot be traced back to you)
• Your cookie preferences

3. Why We Process Your Information

We use your personal data for the following purposes:

• Responding to your enquiries and processing your application
• Sending you fee structures, brochures, course details, and intake announcements you have asked for
• Sharing newsletters and event invitations (only when you have opted in)
• Maintaining student records, tracking academic progress, and coordinating clinical attachments
• Enhancing our website and gaining insight into visitor behavior
• Fulfilling our obligations under Kenyan law

4. Our Lawful Grounds for Processing

We rely on the following legal bases to process your data:

• Your consent — for newsletters, photography, and any optional information. You are free to withdraw consent whenever you wish.
• Performance of a contract — to handle your application and provide the training services you have requested.
• Our legitimate interests — for website analytics and maintaining security.
• Compliance with the law — where Kenyan legislation requires us to process or retain certain data.

5. Photography & Media Consent

During events, graduation ceremonies, clinical activities, and everyday campus life, Trinswa may take photographs or record video of students, staff, and visitors. Such media may appear on our website, social media channels, and printed promotional materials.

• When you register on our website, we will ask for your explicit consent regarding media use
• At events, clear signage will inform attendees that photography is taking place
• You can withdraw your media consent at any time by adjusting your account settings or sending us an email
• Withdrawing consent will not undo any use that has already happened, but we will stop using your images going forward and will remove them from future publications upon request

6. How Long We Keep Your Data

We retain personal information only for as long as necessary for the purposes described in this policy:

• Enquiry records: kept for 2 years from the date you submitted your enquiry
• Account information: kept while your account remains active, plus 3 years after your last login
• Application records: kept for 5 years, in line with educational record-keeping requirements
• Clinical attachment records: kept for 7 years in accordance with medical training regulations
• Website analytics: kept for 24 months in aggregated, non-identifiable form
• Consent records: kept for 7 years as required by law

7. Your Rights as a Data Subject

Under the Kenya Data Protection Act, 2019, you are entitled to:

• Be informed — know how your data is being used
• Access — obtain a copy of the personal information we hold about you
• Correction — have inaccurate or incomplete information corrected
• Deletion — request that your data be erased ("the right to be forgotten")
• Restriction — ask us to limit how we process your data in certain situations
• Portability — receive your data in a structured, machine-readable format
• Object — object to processing carried out on the basis of legitimate interest
• Withdraw consent — at any time, without affecting processing that already took place

To exercise any of these rights, please email info@trinswamtc.ac.ke with the subject line "Data Rights Request". We will acknowledge your request and respond within 21 days.

8. Cookies and Similar Technologies

Our website uses the following types of cookies:

• Strictly necessary cookies — these keep the site functioning (e.g., session management, security tokens). They cannot be switched off.
• Analytics cookies — Google Analytics (GA4) helps us understand how visitors navigate our site. These cookies are only placed with your explicit consent.
• Preference cookies — these remember your display preferences, such as dark/light mode and font size.

You can change your cookie choices at any time by clicking the cookie banner or by contacting us directly.

9. External Services We Rely On

• Amazon SES — used for sending transactional emails such as fee schedules and application confirmations. Data is handled under Amazon's privacy policy.
• Google Analytics — used for website analytics. Only active when you give consent. All data is anonymised.
• OpenStreetMap / Leaflet.js — provides map tiles for campus location maps. No personal data is shared.
• WhatsApp — if you click a WhatsApp button on our site, you will be redirected to WhatsApp's platform, which operates under its own privacy policy.

10. How We Protect Your Data

We take the security of your personal information seriously:

• Passwords are encrypted using bcrypt — we never store them in plain text
• Our website is served over HTTPS (TLS encryption)
• Only authorized staff can access our databases
• We apply security updates to all systems on a regular basis
• Physical student records are kept in locked cabinets with restricted access

11. Minors and Our Services

Our website and training programs are designed for individuals aged 18 and above. We do not intentionally collect personal information from anyone under 18 without verified parental or guardian consent. If you suspect that a minor has provided us with their data without consent, please contact us immediately so we can take appropriate action.

12. Raising a Concern

If you are unhappy with how we have handled your personal information, please reach out to us first at info@trinswamtc.ac.ke. We will do our best to resolve your concern.

You also have the right to file a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya at www.odpc.go.ke.

13. Updates to This Policy

We may revise this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Effective Date" at the top of this page indicates when the policy was last updated. Your continued use of our website after any changes means you accept the revised policy.

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