Revision Date: 10th August 2026
Emergency Medicine Kenya Foundation (EMKF) supports governments and emergency healthcare providers across Kenya to save lives by strengthening the emergency healthcare system through capacity building, knowledge development, advocacy and research.
This Privacy Policy explains, in clear terms, how EMKF collects, uses, shares, stores and protects Personal Data, and how individuals can exercise their rights. It applies together with any shorter or service-specific privacy notice shown when data is collected. If a specific notice differs from this general policy, the specific notice applies to that activity.
This Privacy Policy is a notice, not a request for blanket Consent. Where EMKF needs Consent, we will ask separately, explain the particular use and provide a way to withdraw it.
This Privacy Policy applies when you use or interact with EMKF websites, mobile or web applications, including Casualty and Ambulensi, training and learning programmes, research and monitoring activities, events, communications, fundraising, recruitment, employment, volunteering, consultancy, support services, social-media channels and other EMKF services (together, the “Services”).
It applies to patients and service users, healthcare professionals, ambulance crews, dispatchers, trainees, research participants, donors, partners, website visitors, job applicants, employees, volunteers, contractors and other people whose Personal Data EMKF processes.
Some activities require additional notices—for example, a research participant information sheet, employee notice, recruitment notice, Cookies Notice or a notice provided by a county government, health facility or other partner. Those notices should be read with this policy.
Emergency Medicine Kenya Foundation is a non-governmental organisation based at 83 Parklands Road, Office Suites Block B, 3rd Floor, Nairobi, Kenya.
For privacy questions, complaints, or rights requests, contact the Data Protection Officer or designated privacy contact at emkf@emkfoundation.org. Please write “Privacy Request” in the subject line where practical.
EMKF is a Data Controller where it decides why and how Personal Data is processed. It may be a joint controller where those decisions are made with another organisation. It may also be a Data Processor where it processes Personal Data only on the documented instructions of a government, county, health facility, funder, research institution or other partner.
Where EMKF acts only as a processor, the relevant controller’s privacy notice may apply. EMKF may forward your request to that controller or tell you how to contact it, while providing the assistance required by law and contract.
“Personal Data” means information relating to an identified or identifiable person. “Sensitive Personal Data” includes information requiring additional protection under applicable law, such as health, genetic or biometric data and information about race or ethnic origin, beliefs, family details, sex or sexual orientation. “Processing” includes collecting, recording, organising, using, sharing, storing, restricting, deleting or otherwise handling Personal Data. “Data Subject” means the person to whom Personal Data relates. “Consent” means a freely given, specific, informed and unambiguous indication of agreement through a clear affirmative action.
The categories collected depend on your relationship with EMKF and the Service you use. We do not collect every category from every person.
Identity, contact and account data
Name, date of birth or age, gender where relevant, photograph, identification or verification details, postal or physical address, email address, telephone number, emergency contact, username, account credentials, preferred language and communication preferences.
Professional and organisational data
Job title, employer or facility, professional registration, qualifications, role, permissions, shift or deployment information, training needs and professional correspondence.
Health and emergency-care data
Symptoms, health status, medical history, allergies, blood group where voluntarily provided, assessment and care information, incident details, injury or illness information, referral and outcome information, next-of-kin details and other data needed for safe emergency response, clinical governance or authorised research.
Ambulensi operational and location data
Ambulance, vehicle, crew and facility identifiers; availability and status; dispatch and response records; timestamps; route, pick-up and destination information; and real-time or historical location data where needed to coordinate, audit or improve emergency response. Location permissions can normally be controlled through your device, but disabling them may prevent critical dispatch or tracking functions from working.
Training, research and programme data
Enrolment and attendance, assessment and quiz results, certification or continuing professional development records, surveys, interviews, feedback, consent records, programme participation, demographic information and research or monitoring data described in the relevant participant notice or protocol.
Employment, recruitment and relationship data
Applications, employment history, references, qualifications, contracts, performance, payroll or benefits information, tax and statutory records, safeguarding information, volunteer or contractor records, donor and partner contact details, and records needed to manage the relationship.
Technical, usage and communications data
Internet Protocol address, device and browser type, operating system, unique device identifiers, application or page activity, timestamps, diagnostic, crash, security and audit logs, cookie or similar-technology identifiers, support requests, correspondence, call or message records, and preferences.
Transaction data
Purchase, donation, invoice, payment status and transaction-reference data where relevant. A payment provider may collect payment-card or mobile-money details directly under its own privacy notice; EMKF receives only the information needed to confirm and record the transaction unless otherwise stated at collection.
We may collect Personal Data:
If we obtain Personal Data from another source, we will provide the required information within the applicable period unless an exception under law applies or the relevant controller has already provided an appropriate notice.
EMKF identifies a lawful basis before each processing activity and records it internally. Depending on the activity, we may process Personal Data for the following purposes and bases:
For each distinct Processing activity, EMKF identifies and records the lawful basis that actually governs it before Processing begins. Where different bases govern different circumstances, those circumstances are mapped separately; EMKF does not switch bases retrospectively merely to justify Processing. Where legitimate interests are relied upon, EMKF completes a documented Legitimate Interests Assessment proportionate to the nature and risk of the activity. Where historical, statistical or scientific research is relied upon as a basis, that basis and the safeguards protecting individuals are documented.
Where a shorter or service-specific notice is provided, it will identify the basis applicable to that activity more precisely. You may request further information about the basis used for a particular Processing activity.
We rely on Consent only where it can be freely given, specific, informed and withdrawn. Acknowledging this Privacy Policy does not itself give Consent for every use of Personal Data.
Emergency processing will not default to Consent when data is needed to protect life or physical safety, coordinate authorised emergency response, support necessary care, perform an authorised public-interest function or comply with law. Where Consent is the appropriate basis, we will seek it as soon as reasonably possible and record it.
Withdrawing Consent does not affect processing already carried out lawfully. It may prevent an optional feature or activity from continuing, but it does not stop processing based on another lawful basis.
Casualty may process account, professional, training, clinical-reference, usage, and support data to provide learning, decision-support, or emergency-care resources, maintain records, secure the platform, and improve the Service.
Ambulensi may process identity, role, professional, facility, vehicle, dispatch, incident, patient, health, communication, timing, audit and location data to coordinate emergency medical services, route or track resources, support handover, maintain operational accountability, investigate safety incidents and improve response systems.
Access is limited according to role and operational need. EMKF applies additional safeguards to health, location and emergency information. A county, facility or other partner may be the controller for a particular deployment; its notice should identify any additional purposes, recipients and retention arrangements.
Where Casualty, Ambulensi or another Service falls within Kenya’s Digital Health Act, applicable regulations or Digital Health Agency certification requirements, EMKF and the responsible deployment partner will apply the required health-information management, interoperability, security, data-quality, audit and certification controls. Regulatory certification does not expand the purposes or lawful bases for Processing described in this Policy.
EMKF uses data for research, statistics, monitoring, evaluation, learning and quality improvement only under an approved purpose and lawful basis. Where required, we use participant information sheets, Consent or ethics approvals and conduct a data-protection impact assessment.
We minimise identifiable data, separate identifiers where practical, restrict access and use aggregation, pseudonymisation or anonymisation appropriate to the risk. Published findings and donor reports should use aggregated or anonymised information unless identifiable disclosure is lawful, necessary and clearly explained in advance.
Anonymised information that can no longer identify a person is not Personal Data. We do not attempt to re-identify properly anonymised data.
We may send essential operational, account, safety, training or service messages where needed to provide a Service or manage our relationship with you. These are different from optional marketing or fundraising messages.
We send optional promotional, event or fundraising communications only where a lawful basis permits. Every electronic marketing message should provide a simple way to unsubscribe. You may also opt out by contacting emkf@emkfoundation.org. We will keep the minimum information needed to respect an opt-out.
EMKF does not sell Personal Data. We do not use Personal Data for another organisation’s commercial marketing unless you have been clearly informed and the use is lawful.
EMKF websites and digital Services may use cookies, software development kits, local storage or similar technologies. Essential technologies support functions such as security, login, session continuity and preferences. Analytics, performance, functionality or advertising technologies are used only when permitted by law and, where required, after you make a choice or give Consent.
Our Cookies Notice and cookie controls should explain the technologies in use, what they collect, their purpose, duration, whether a third party is involved and how to change or withdraw your choices. Refusing non-essential cookies should not prevent access to core content, although some optional features may work differently. Browser or device settings may provide additional controls.
We aim to collect only Personal Data that is adequate, relevant and necessary for a stated purpose, keep it accurate where needed, restrict access and avoid incompatible further use.
If we want to use identifiable data for a materially different purpose, we will assess whether that purpose is compatible with the original purpose. Where required, we will provide a new notice and identify a new lawful basis or obtain Consent before the new use.
You can help by keeping account and contact details current and telling us when information is inaccurate.
We identify mandatory fields and explain the reason at or before collection. Some data is required to create an account, verify eligibility, provide training or certification, complete a transaction, meet a legal or contractual duty, coordinate a dispatch, deliver safe emergency support or protect a person’s life or safety.
If required data is not provided, EMKF may be unable to provide the relevant Service, process an application or transaction, issue a certificate, coordinate an emergency function or meet a legal obligation. Optional fields should be labelled or described as optional, and declining them will normally affect only the related optional feature.
EMKF may share Personal Data, on a need-to-know and lawful basis, with:
We share only what is necessary for the stated purpose. Processors must act under written terms, confidentiality and security obligations. Routine data sharing between controllers or joint controllers is governed by an appropriate agreement and clearly allocated responsibilities. We require service providers and partners to protect Personal Data and do not allow them to use it for unrelated purposes.
Where an EMKF application uses third-party software development kits or similar code—for example for hosting, authentication, analytics, crash diagnostics, maps or location, push messaging, payments or support—the relevant provider may process only the data necessary for the disclosed function. EMKF requires such providers to give Personal Data the same or an equivalent level of protection as this Privacy Policy and applicable app-store requirements, and remains responsible for appropriate due diligence, configuration and monitoring.
EMKF does not sell Personal or Sensitive Personal Data. We do not permit a provider or software development kit to use health, emergency, precise-location, account or authentication data for its own advertising, marketing profiling or unrelated data-mining purposes.
Some technology providers, research collaborators or partners may process or support Personal Data from another country. Before a cross-border transfer, EMKF assesses necessity, the recipient, destination, risks and the legal transfer mechanism, and uses appropriate contractual, organisational and technical safeguards.
For Sensitive Personal Data, EMKF meets the additional legal requirements that apply, including obtaining express Consent where the law requires it, in addition to the necessary safeguards. We can provide further information about applicable transfer safeguards, subject to legitimate confidentiality and security restrictions.
We keep Personal Data only for as long as reasonably necessary for the stated purpose and in line with EMKF’s approved retention and disposal schedule. The period depends on the type and sensitivity of the data; legal, contractual, clinical, ethical, donor and regulatory requirements; safety and audit needs; limitation periods; and whether a dispute, investigation or legal hold applies.
When Personal Data is no longer required, we securely delete, destroy, anonymise or, where appropriate, pseudonymise it. Deleting an account does not automatically erase records that must lawfully be retained, but access and further use will be limited to the continuing purpose. Backup copies are removed or made inaccessible through the normal backup cycle where practicable.
EMKF uses risk-based technical, organisational and physical safeguards. These may include role-based access, authentication, encryption where appropriate, secure configuration and patching, logging and monitoring, backups and recovery, confidentiality commitments, staff training, supplier controls, secure transfer and disposal, and regular testing or review.
No system is completely secure. If a Personal Data breach occurs, EMKF will contain and investigate it, assess the risk, document the response and notify the relevant controller, the Data Commissioner and affected individuals within the periods and in the circumstances required by law. Where individuals are notified, we will explain practical steps they can take to reduce harm.
Subject to applicable conditions and exceptions, you may have the right to:
These rights are not absolute. For example, EMKF may need to retain or continue processing data to comply with law, protect life or safety, perform an authorised function, preserve research integrity with appropriate safeguards, or establish, exercise or defend legal claims. We will explain any lawful limitation that applies.
Send a clear request to emkf@emkfoundation.org or to the physical address in section 2. State the right you wish to exercise and the Service or relationship involved. We may ask for information reasonably needed to verify your identity, authority or the scope of the request, and we will not disclose Personal Data until appropriate verification is complete.
EMKF will acknowledge and respond within the timelines required by applicable law. Requests are normally free, although a lawful fee or other measure may apply to a manifestly unfounded, excessive or repetitive request. If EMKF is only the processor, we may refer the request to the responsible controller.
If you are dissatisfied, first contact EMKF so we can investigate. You may also lodge a complaint with the Office of the Data Protection Commissioner of Kenya through its published contact and complaints channels. Using EMKF’s process does not remove your right to complain to the regulator or seek another remedy available by law.
If a mobile application or Service allows you to create an account, it will provide a readily discoverable Delete Account option within the app, normally under Account or Settings. You may also request deletion without reinstalling the app through the public account-and-data-deletion resource linked from the relevant app-store listing. The published HTML version of this Privacy Policy may serve as that external resource when it provides a direct route to this section.
To use the external route, email emkf@emkfoundation.org with the subject “Delete my app account”, identify the relevant Service and provide the account identifier reasonably needed to locate the account. Do not include a password or unnecessary health information. We may verify your identity or authority before acting.
On a valid request, EMKF will delete or irreversibly de-identify the account and associated Personal Data from active systems and instruct applicable Processors or service providers to do the same. Temporary deactivation, disabling or freezing does not count as deletion. We will act without undue delay and within applicable legal timelines.
Some records may be retained where necessary for legal, clinical, patient-safety, security, fraud-prevention, audit, certification, research-integrity, dispute or regulatory purposes. Retained data will be restricted to that purpose, protected and deleted or anonymised when the retention requirement ends. We will explain the categories retained, the reason and the expected period where applicable. Residual backup copies will expire through the normal protected backup cycle.
Deleting an app account does not automatically cancel an Apple App Store or Google Play subscription or other platform-managed purchase. Any such subscription must be managed through the relevant store account, but cancellation is not a condition for submitting an account-deletion request.
EMKF applies additional safeguards when processing Personal Data about children or people who may need support because of disability, illness, age, literacy, emergency circumstances or another vulnerability. Notices and choices should be accessible and appropriate to the person and context.
Where required, we verify and record authorisation from a parent, guardian or lawful representative, while respecting the individual’s rights and evolving capacity. In a genuine emergency, we may process necessary data to protect life or safety under another lawful basis. High-risk activities are assessed before they begin, including through a data-protection impact assessment where required.
EMKF does not intend to make a decision that produces legal or similarly significant adverse effects based solely on automated processing unless the decision is lawful and appropriate safeguards are in place.
Before using artificial intelligence, profiling or other automated tools with Personal Data, EMKF assesses necessity, accuracy, fairness, security, transparency and the risk to individuals. Where required, we provide meaningful information about the logic and likely effect, maintain human oversight and provide a way to request human intervention or challenge a decision. Sensitive or emergency data receives heightened protection.
EMKF will not disclose Personal Data to a third-party artificial-intelligence provider unless the disclosure is necessary for a clearly explained feature or approved purpose, appropriate contractual and technical safeguards are in place, and any required permission has been obtained. Health, emergency and precise-location data will not be used to train a general-purpose model or for unrelated data mining unless a separate lawful, approved and transparent arrangement expressly permits it.
Our Services may link to or interoperate with websites, app stores, social-media platforms, payment providers or other services that have their own privacy practices. EMKF is not responsible for independent processing by those third parties. Review their privacy notices before providing Personal Data. Where a third party processes data for EMKF, the safeguards in section 15 apply.
EMKF will publish the approved version of this Privacy Policy on an active, publicly accessible, non-geofenced and non-editable HTML webpage. A readily accessible link will appear in each relevant mobile application and in its Google Play or Apple App Store listing. This Policy applies together with any shorter in-app disclosure presented for a particular permission or feature.
Before an application accesses or collects Personal Data in a way that may not be reasonably expected—such as precise or background location, microphone, camera, photos or files, contacts, or other protected device data—the application will provide a clear and prominent in-app disclosure and request the relevant system permission. The disclosure will identify the data, the feature and purpose, any material sharing, and whether collection continues in the background. Consent will require an affirmative action; leaving or dismissing the screen will not be treated as agreement. Where reasonably practicable, a user who declines a permission will be offered a manual or less data-intensive alternative.
Applications will request only permissions necessary for their current functions, and EMKF will remove unused permissions. EMKF does not sell Personal or Sensitive Personal Data and does not use health, emergency, HealthKit, Health Connect or precise-location data for advertising, marketing profiling or unrelated data mining. EMKF applications will not intentionally store identifiable health information in iCloud.
For each application and platform, EMKF will maintain accurate Google Play Data Safety and Apple App Privacy declarations that reflect the application’s actual data practices, permissions and third-party code. EMKF will update this Privacy Policy, in-app disclosures and store declarations before or when a release materially changes those practices.
For a health or medical application, EMKF will complete any required Google Play health-app declaration and Apple regulated-medical-device status declaration. Unless the application is expressly identified as a regulated medical device, its store description will state that it is not a medical device and does not diagnose, treat, cure or prevent any medical condition, and will direct users to consult a qualified healthcare professional for medical advice, diagnosis or treatment. Where an application is regulated as a medical device, EMKF will provide the required proof of regulatory approval, instructions for use, intended-use statement and safety information.
Where an app-specific notice or store disclosure provides more detail for a particular application or feature, it applies together with this Policy. If EMKF identifies a material discrepancy between an application’s behaviour and its disclosures, it will correct the disclosure or stop or limit the affected processing until it is lawful and transparent.
We review this Privacy Policy regularly and when our Services, processing practices, risks, law or regulatory guidance change. The current version and effective date will be shown on the approved document or published page.
For material changes, we will provide reasonable notice through the relevant Service, website, email, application notification or another appropriate channel. We will not use previously collected Personal Data for an incompatible new purpose without providing the required information and establishing a lawful basis.
Data Protection Officer
Emergency Medicine Kenya Foundation
83 Parklands Road
Office Suites, Block B, 3rd Floor
Nairobi, Kenya
Email: emkf@emkfoundation.org
Please contact us if you need this Privacy Policy in a more accessible format or need help exercising a privacy right.
