Children and Young Persons Data Policy

1. Introduction

MindBrood Initiative ("we," "us," "our") operates the Societrics Advisory platform, which includes age-appropriate assessment tiers for secondary school students including those in Junior Secondary School (JSS 1–3) and Senior Secondary School (SSS 1–3). Given that this age range includes users who may be under 18 years of age — and in some cases under 13 — we apply heightened data protection standards to all data relating to young users.

This policy is issued in compliance with the Nigeria Data Protection Act 2023 (NDPA), the Child Rights Act 2003 (as applicable), and relevant international standards for the protection of children's data online. It applies to all Societrics platforms accessed by users under 18.

2. Age Categories and Access Rules

2.1 Under 13 — Foundation Tier

The Societrics Advisory Foundation Tier is designed for younger secondary school students. Access by users under 13 is permitted only through an institutional deployment where:

• The school or educational institution has signed a Data Processing Agreement (DPA) with MindBrood Initiative
• The institution has obtained documented written parental or guardian consent for each student prior to their first assessment
• Student accounts are created and managed by the school — not by the student individually
• A designated school counsellor or administrator is responsible for overseeing student use

Self-registration by users under 13 without institutional oversight is not permitted. If we become aware that a user under 13 has self-registered without institutional oversight, we will delete the account and associated data within 14 days and notify the institution or parent if identifiable.

2.2 Ages 13–17 — Intermediate Tier

Students aged 13–17 may access the Intermediate Tier with documented parental or guardian consent. Schools deploying the platform to this age group must:

• Collect, record, and retain parental consent before students complete their first assessment
• Make the consent form available to parents in plain language, including a clear explanation of what data is collected and how it is used
• Provide parents with a mechanism to withdraw consent at any time

2.3 Ages 18 and Above

Standard Terms of Service apply. No parental consent required.

3. What Data We Collect from Young Users

We apply data minimisation principles to young users — collecting only the minimum data necessary for the educational guidance service. For users under 18, we collect:

• Assessment responses: answers to age-appropriate VCTR Framework questionnaire items at the Foundation or Intermediate tier
• School-assigned identifier: a reference used by the school to link results to the student within the school's system — this may be a student ID number, not necessarily the student's full name
• Limited demographics: age range (not exact date of birth), gender (optional), class level (JSS/SSS year), and school state or LGA
• Assessment results: VCTR archetype profile, trait distribution, and guided career/learning recommendations

We do NOT collect from users under 18:

• Home address, phone number, or personal contact details
• Biometric data
• Financial information
• Detailed social media profiles or external account data beyond what Google Sign-In provides (name, email)
• Precise geolocation (we collect state/LGA level only)

4. How Young Users' Data Is Used

4.1 Permitted Uses

• Delivering assessment results to the student for self-reflection and educational guidance
• Providing aggregate class-level and school-level personality distribution insights to authorised school counsellors and administrators
• Contributing the student's anonymised, non-identifiable assessment data to the National Personality Index (NPI) for educational research (see Section 5)
• Improving the age-appropriateness and accuracy of the Foundation and Intermediate assessment tiers

4.2 Prohibited Uses of Young Users' Data

• Individual student results will never be shared with prospective employers, higher institutions, government agencies, or any commercial party
• Assessment results will never be used to label, track, or stream students into educational pathways without their knowledge and the involvement of a qualified counsellor
• We will never use young users' data for commercial advertising, profiling, or any purpose unrelated to the educational guidance service
• We will never sell young users' data under any circumstances

5. Research Use of Young Users' Anonymised Data

Anonymised, non-identifiable assessment data from young users contributes to the National Personality Index (NPI) — the aggregate population-level index that maps archetype distributions across Nigeria's student population. This is one of the primary research purposes of the platform and is disclosed to schools and parents in the consent process.

The following safeguards apply to research use of young users' data:

• Data is anonymised before any research use — no individual student can be identified from any published NPI output
• Research outputs present population-level patterns (e.g., "40% of JSS 3 students in Lagos show Thinker as primary archetype") — not individual data
• Research partners (including NERDC and academic institutions) receive only aggregate data tables — never individual student records
• Parents may opt their child out of research use by contacting privacy@societrics.org. The opt-out does not affect the student's ability to use the platform or receive personalised guidance.

6. School Administrator Responsibilities

Schools and educational institutions that deploy Societrics Advisory to students accept the following responsibilities as data controllers for their students:

• Obtain, record, and retain parental or guardian consent for every student before their first assessment
• Designate a named Data Protection Contact within the school responsible for all student data matters on the platform
• Provide students and parents with the platform Privacy Policy, this Children's Data Policy, and the consent form in plain, accessible language before any assessments begin
• Limit access to individual student assessment results to the student, their designated counsellor, and named administrative staff — not to all teachers or staff
• Not share individual student results with parents without the student's knowledge (for students 13 and above) unless there is a safeguarding concern
• Delete or request deletion of student accounts upon the student leaving the school or upon withdrawal of parental consent
• Report any suspected data breach or unauthorised access to student data to MindBrood Initiative within 24 hours at privacy@societrics.org

7. Parental and Guardian Rights

Parents and guardians of students under 18 have the following rights in respect of their child's data on the platform:

• Right of access: request a copy of the data held about their child
• Right to rectification: request correction of inaccurate demographic information
• Right to erasure: request deletion of their child's individual data (note: anonymised aggregate contributions to NPI cannot be removed as individual data is not retained after anonymisation)
• Right to withdraw consent: withdraw consent for continued data processing at any time — this will result in account deactivation
• Right to opt out of research: exclude their child's data from research use (NPI contribution) without affecting service access
• Right to object: object to any specific use of their child's data

To exercise any parental right, contact us at privacy@societrics.org with your child's school name and student identifier. We will respond within 14 days. We may require verification of your identity and parental relationship before actioning requests.

8. Student Rights

Students who are 13 or older also have independent rights to their data, including:

• Understanding what data is collected about them and why — in age-appropriate language
• Accessing their own assessment results and profile at any time through the platform
• Requesting deletion of their account (for students 16 and above, independently; for students 13–15, with parental involvement)
• Knowing whether their anonymised data contributes to research, and opting out if they wish

9. Security Measures for Young Users' Data

In addition to the general platform security measures described in the Privacy Policy, we apply the following protections specifically to young users' data:

• Individual student assessment records are accessible only to the student and authorised school administrators — not to other students or the general public
• Student data is stored with the same encryption and access control standards as all Platform data
• No marketing, advertising, or third-party tracking code is applied to Platform pages accessed by users identified as under 18
• We conduct periodic audits of access logs for institutional accounts to verify that student data is being accessed only by authorised school personnel

10. Reporting Concerns about Young Users

If you are a parent, student, or school administrator with concerns about how a young person's data has been handled on the Societrics platform, please contact us immediately:

Email: privacy@societrics.org
Subject line: "Child Data Concern — [School Name]"

We treat all concerns relating to young users' data as priority matters and will respond within 72 hours. Where a safeguarding concern is identified, we will cooperate with relevant Nigerian authorities as required by law.

11. Compliance and Review

This policy is reviewed annually and whenever relevant Nigerian law relating to children's data protection is updated. Schools deploying the platform are encouraged to review this policy each academic year and update their consent processes accordingly.

This policy must be read alongside our Privacy Policy, Terms of Service, and the Acceptable Use Policy. In matters relating to young users, this Children and Young Persons Data Policy takes precedence.