Controller:
Stiftelsen Flowminder
Magnus Ladulåsgatan 1
118 65 Stockholm, Suède
privacy@flowminder.org
Data protection officer:
1. Your personal data processed in the 2022 Annual Household Income and Expenditure Survey in Ghana (the “Survey”).
The 2022 Annual Household Income and Expenditure Survey in Ghana provides information to Ghana Statistical Service about household income and expenditure under its mandate under Ghanaian law.
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, marking 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:
- Age
- Education level
- Gender
- Relationship to head of household
- Citizenship/nationality
- Indicators of socioeconomic status (employment status, main activity, personal and household income, household subsistence)
- Indicators of SIM card use (number of SIM cards, providers, use frequency, SIM sharing)
- Indicators on mobility (commuting, change of home location, number of trips taken, district of origin and destination of journey)
- Geographic location (region, district, locality, GPS coordinates of household)
- 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 toward 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.
- Sexual orientation might be inferred from the combination of household demographics like gender, relationship to head of household and age.
These special category personal data are processed on the grounds of scientific or historical 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 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.
4. The controller of the personal data is Stiftelsen Flowminder (“Flowminder”, “we”, “us”).
Our contact information is:
Stiftelsen Flowminder
Magnus Ladulåsgatan 1
118 65 Stockholm, Sweden
privacy@flowminder.org
Our data protection officer’s contact information is:
Bird & Bird DPO Services SRL
Avenue Louise 235 b 1, 1050 Brussels, Belgium
DPO.Flowminder@twobirds.com
5. Flowminder only shares your personal data with a limited set of parties explained during the Survey.
Ghana Statistical Service (GSS) independently carries out this household expenditure survey as a part of its mandate as the national agency responsible for collection of national statistics in Ghana and for its own purposes shared with you at the time of the collection. For information about how Ghana Statistical Service handles your personal data, you should contact GSS at the address below.
Once GSS shares your personal data collected during the Survey with Flowminder, your data is only shared with authorized staff members of Flowminder.
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: Finance Close, Accra, Ghana.
Fax: +233-302-664304
E-mail: info@statsghana.gov.gh
Website: www.statsghana.gov.gh
7. You have rights as a data subject under GDPR.
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. You can also request a copy of this.
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.
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 privacy@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
10. You can also file a complaint with the Swedish Public Authority for Privacy Protection, which is called Integritetsskyddsmyndigheten in Swedish or the Information Commissioner’s Office in the United Kingdom.
The contact information for Integritetsskyddsmyndigheten in Sweden is:
They are available by email at: imy@imy.se
You can also write to them at:
Integritetsskyddsmyndigheten
Box 8114
104 20 Stockholm, Sweden
Their website is: https://www.imy.se/
The contact information of the Information Commissioner’s Office in the United Kingdom is:
You can write to them at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
You can call or fax them at:
Phone: +44 0303 123 1113
Fax: 01625 524510
Their website is: https://ico.org.uk/make-a-complaint/