S4D Corporate Privacy Policy

Effective Date: January 3, 2021
Last Updated: January 27, 2026

Systems for Development (S4D) Consulting LLC and its affiliated entities (“S4D”, “we”, “our”, or “us”) are committed to protecting personal data and respecting the privacy of individuals whose information we process.

This Corporate Privacy Policy describes how S4D collects, uses, discloses, and safeguards personal data across its corporate operations, websites, products, services, and engagements. It establishes the overarching data-protection principles and governance framework applicable across all S4D activities.

Product-specific privacy notices supplement this policy and provide additional detail on how personal data is processed within specific platforms or services.

1 Scope of This Policy

This Corporate Privacy Policy applies to personal data processed by S4D in connection with:

  • Our corporate website(s) and communications
  • Client, partner, and donor engagements
  • Product and platform operations
  • Professional services and advisory work
  • Vendor, consultant, and contractor relationships
  • Recruitment and human-resources processes

Where S4D processes personal data on behalf of a client, government authority, school, or other organization, S4D acts as a Data Processor and processes such data strictly in accordance with documented instructions from the Data Controller.

2 S4D Entities Covered

This policy applies to Systems for Development (S4D) Consulting LLC and its affiliated or operating entities, including but not limited to operations in:

  • United States
  • Ghana
  • Uganda
  • Zambia
  • Rwanda

Specific country-level legal considerations may be addressed through country-specific privacy annexes.

3 Data Protection Principles

S4D processes personal data in accordance with the following principles:

  • Lawfulness, fairness, and transparency
  • Purpose limitation – data is collected for specified, explicit, and legitimate purposes
  • Data minimization – data is limited to what is necessary
  • Accuracy – reasonable steps are taken to keep data accurate and up to date
  • Storage limitation – data is retained only as long as necessary
  • Integrity and confidentiality – data is protected through appropriate safeguards
  • Accountability – compliance is demonstrable and auditable

These principles guide all S4D systems, services, and engagements

4 Categories of Personal Data

Depending on the nature of the engagement, S4D may process the following categories of personal data:

  • Identification and contact information
  • Professional and organizational information
  • Account and access credentials
  • Financial and transactional metadata
  • Communications and correspondence
  • Technical and usage data (logs, device information, access records)

Sensitive or regulated data (such as health or children’s data) is processed only where required, authorized, and governed by applicable law and contractual arrangements.

5 Lawful Bases for Processing

S4D processes personal data based on one or more of the following lawful bases, as applicable:

  • Performance of a contract
  • Compliance with legal or regulatory obligations
  • Public interest or official authority (particularly in government and public-sector engagements)
  • Legitimate interests, balanced against individual rights
  • Consent, where required by law

The applicable lawful basis depends on the context and jurisdiction.

6 Purposes of Processing

Personal data processed by S4D is used for purposes including:

  • Delivery of products and professional services
  • Client and stakeholder engagement
  • Project management, reporting, and compliance
  • System security, monitoring, and audit
  • Research, analytics, and service improvement
  • Legal, regulatory, and contractual obligations

Data is not used for purposes incompatible with the original purpose of collection.

7 Data Sharing and Disclosure

S4D may share personal data with:

  • Clients and authorized stakeholders
  • Subsidiaries and affiliated entities
  • Vendors and service providers acting on our behalf
  • Donors, regulators, or authorities where required by law

All third parties are subject to appropriate contractual, confidentiality, and data-protection obligations.

S4D does not sell personal data.

8 International Data Transfers

Where personal data is transferred or accessed across borders, S4D implements appropriate safeguards consistent with applicable data-protection laws and contractual requirements, including organizational, technical, and legal measures.

9 Data Retention

Personal data is retained only for as long as necessary to:

  • Fulfill contractual and operational purposes
  • Meet legal, regulatory, and audit obligations
  • Support dispute resolution and accountability

Retention periods may vary depending on data type, purpose, and jurisdiction.

10 Data Security

S4D implements appropriate technical and organizational security measures, including:

  • Role-based access controls
  • Secure authentication mechanisms
  • Encryption and secure transmission protocols (where applicable)
  • Audit logging and monitoring
  • Incident response and escalation procedures

These measures are designed to protect personal data against unauthorized access, loss, or misuse.

11 Data Subject Rights

Subject to applicable law, individuals may have rights to:

  • Access personal data
  • Request correction or update of inaccurate data
  • Request deletion or restriction of processing
  • Object to certain processing activities

Where S4D acts as a Data Processor, such requests should be directed to the relevant Data Controller.

12 Children’s Data

S4D processes children’s data only where required for authorized services and under the authority of a Data Controller, such as a school or public institution. Additional safeguards are applied in accordance with applicable law and contractual requirements.

13 Updates to This Policy

This Corporate Privacy Policy may be updated periodically to reflect changes in legal requirements, organizational practices, or services. Updated versions will be published through appropriate channels

14 Contact Information

For questions or concerns regarding this Corporate Privacy Policy or S4D’s data-protection practices, please contact:

Systems for Development (S4D) Consulting LLC
Email: info@s4dconsulting.com
Website: www.s4dconsulting.com

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