Beyond Neuro-Extractivism: Building a Neural Chilimba Framework for Culturally Grounded Neuro-Education Governance in Zambia

Educational neurotechnology — portable electroencephalography (EEG) headsets, attention-tracking wearables, and cognitive-load monitors — is becoming commercially accessible in Global South markets with almost no neuro-specific regulatory infrastructure. Left ungoverned, these conditions create structural risk of neuro-extractivism: the asymmetric and largely irreversible flow of children's cognitive data from low- and middle-income country (LMIC) educational settings to technology corporations operating in regulatory vacuums. Existing neuroethics frameworks, grounded in individual consent, liberal privacy rights, and Western regulatory models, are structurally inadequate for governing neural data in such contexts — not because they are wrong, but because their individualist premise is misaligned with communities in which personhood is understood relationally. Drawing on Ubuntu's relational ontology and the Zambian Chilimba communal pooling tradition, this article proposes the Neural Chilimba framework — a three-pillar governance model that operationalises four neuro-rights (cognitive liberty, mental privacy, mental integrity, and psychological continuity) at the community level. The framework operates within Gyekye's moderate communitarianism: it does not abolish individual parental consent but embeds it within communal deliberative governance, arguing that where data is inherently relational in its epistemic content, individual consent alone is a structurally inadequate governance instrument. Legal analysis of Zambia's Data Protection Act No. 3 of 2021 identifies four structural gaps that leave neural data unprotected. Analysis of five consumer neurotechnology products, supported by a formal scoring rubric and inter-rater verification (reported in full in supplementary materials), reveals that zero products offer privacy policies in any Zambian indigenous language and none disclose compliance with Zambian law. Twelve phased and costed policy implications are provided for Zambia's Data Protection Commission, Ministry of Technology and Science, Ministry of Education, technology providers, and the African Union. The framework includes mandatory pre-deployment efficacy disclosure, a three-architecture data processing classification, longitudinal data retention limits, and youth advisory representation on governance committees. This article is an anticipatory governance intervention, not an empirical study of large-scale deployment in Zambia; it combines doctrinal legal analysis, a product audit, and normative institutional design to specify governance conditions that should be in place before educational neurotechnology becomes entrenched in Zambian school settings.