Privacy notice for the 2022 Data for Good Phone Survey in Ghana

1. Your personal data processed in the 2022 Data for Good Phone Survey in Ghana (the “Survey”).

The 2022 Data for Good Phone Survey in Ghana will provide valuable information to Flowminder and Ghana Statistical Service about mobile phone use and mobility.

For Flowminder, the purpose of processing your personal data from the Survey is to conduct research on phone use and mobility, support the production of respective national statistics and inform decision-making in Ghana. This overall purpose can include improving access to health and social services, health service delivery planning, disaster management planning and response, monitoring progress toward the Sustainable Development Goals, as well as scientific research.

The processing of your personal data as a part of the survey is subject to the General Data Protection Regulation (GDPR) ((EU) 2016/679) as well as UK GDPR as defined in the Data Protection Act 2018 (UK) and the Data Protection Act 2012 (Ghana).

The personal data that will be collected from you and that Flowminder will have access to if you participate is:

• Demographic data (age, gender)
• Indicators of socioeconomic status (education level, employment status, main activity, personal and household income, household subsistence)
• Indicators of SIM card use (e.g. number of SIM cards, providers, use frequency, SIM sharing)
• Mobile Phone Number
• Indicators on mobility (e.g. commuting, change of home location, number of trips taken, district of origin and destination of journey)
• Geographic location (region, district, locality)
• Interview language

Any personal data collected in the Survey is collected directly from you during the Survey, and only if you choose to participate and consent to providing that information. The link to this privacy notice was provided in the interview to you as a survey participant in the script from the person who conducted the interview.

2. Flowminder’s legal basis for processing of personal data from the Survey

Your personal data is processed on the grounds of legitimate interests pursued by Flowminder (Article 6(f), GDPR) (Article 20(1)(e), Data Protection Act of 2012, Ghana). These legitimate interests are improving access to health and social services, health service delivery planning, disaster management planning and response, marking progress towards the Sustainable Development Goals, as well as scientific research.

In addition to the categories of personal data mentioned above, special category data is collected in the following category:

• Ethnic origin may be understood from your spoken language.

These special category personal data are processed on the grounds of scientific research or statistical purposes for the public interest (Article 9(2)(j), GDPR).

3. About transfers of personal data outside of the EU/EEA

If you decided to participate in the survey and provided personal data, this data is collected from you in Ghana. It is not sent outside of the EU/EEA or Ghana during the processing unless to a country on the basis of an adequacy decision, or in the case of sending to a third country on the basis of standard contractual clauses and additional supplementary measures.

Detailed information about the relevant safeguards used with respect to such transfers can be obtained by contacting us at: privacy@flowminder.org.

5. Flowminder only shares your personal data with a limited set of parties.

Ghana Statistical Service (GSS) carries out this survey for Flowminder. GSS will also retain the final survey dataset for research purposes, statistical purposes and archiving purposes. For further information about how Ghana Statistical Service handles your personal data, you should contact GSS at the address below.

For technical purposes during data collection, the company Dobility, Inc. through its product SurveyCTO will record the personal data collected through the phone survey.

6. Your data is retained for a designated period of time by Flowminder as well as by Ghana Statistical Service.

Flowminder retains your data for a period of fifteen (15) years following the completion of the survey for further research and analysis.

For information about the retention of your data by Ghana Statistical Service (GSS), you should contact GSS directly:

Ghana Statistical Service
Head Office,
P. O. Box GP 1098,
Head Office Building,
Location: GA-144-0036, Finance Close, Accra, Ghana.
Fax: +233-302-664304
E-mail: info@statsghana.gov.gh
Website: https://www.statsghana.gov.gh 

7. You have rights as a data subject under GDPR and under the Ghana Data Protection Act 2012.

You have the right to access your personal data.

You have the right to know whether your personal data is processed, and request specific information about the processing of personal data. This right may be subject to exemption where processing for statistical purposes is carried out, especially where access to this right is likely to impair the processing itself. You can also request a copy of your data.

You have the right to have your personal data corrected.

If there are errors or if your personal data that is processed is inaccurate, you can request this be updated or supplemented.

You have the right to restriction of the processing of your personal data.

You have the right to restrict the processing of your personal data in certain situations, for example if your personal data held is not accurate.

You have the right to object to the processing of your personal data.

You have the right to object to the processing of your personal data on grounds relating to your particular situation if the processing is necessary for the performance of a task carried out in the public interest, which would mean Flowminder would need to make an evaluation based on your request to consider this objection and we must stop the processing unless we can demonstrate compelling legitimate grounds to continue, or if the processing is necessary for the establishment, exercise or defence of legal claims or possibly subject to exemption for statistical purposes.

You have the right to withdraw consent.

If the processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You have the right to have your data erased

Unless the processing is based on a legal obligation or public interest, you have the right to request your personal data be erased in certain situations.

You have the right to data portability.

In certain situations, if you provided personal data to us and we process it by automated means on the basis of your consent, or because it is necessary to enter into or fulfil a contract, you can request us to provide the personal data in a structured, commonly used and machine-readable format and to have the data transmitted to another controller.

8. No automated decision making.

Your personal data is not used in automated decision making.

9. You can exercise your rights by contacting Flowminder.

We are available by email at legal@flowminder.org and our data protection officer is available by email at DPO.Flowminder@twobirds.com.

You can also write to us at:

Stiftelsen Flowminder
Magnus Ladulåsgatan 1
118 65 Stockholm, Sweden