(As of May 2018)

Introduction

The Gulf Centre for Human Rights (GCHR) has always been committed to protecting any private information held by it. In particular, we protect subscribers’ privacy by keeping their email information secure and do not share it with anyone.  GCHR only holds subscribers’ information so they can continue to receive GCHR news updates, reports, announcements, and calls for action. GCHR has recently updated its policy on this subject, after the General Data Protection Regulation (GDPR) came into force on 25 May 2018.

Definitions

GCHR means Gulf Centre for Human Rights.

GDPR means the General Data Protection Regulation.

Responsible Person means the Executive Director.

Register of Systems means a register of all systems or contexts in which personal data is processed by the NGO.

1. Data protection principles

GCHR is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes shall not be considered incompatible with the specified, explicit and legitimate purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, updated; every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods only insofar as the personal data will be processed for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that as far as possible ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General Provisions

1. This policy applies to all personal data processed by GCHR.
2. The Responsible Person shall take responsibility for GCHR’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, GCHR shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to GCHR shall be dealt with in a timely manner.

4. Lawful purposes

1. All data processed by GCHR must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. GCHR shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in GCHR’s systems.

5. Data minimisation

1. GCHR shall ensure that personal data are adequate relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

1. GCHR shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, GCHR shall put in place an archiving policy for each area in which personal data is processed and review this policy annually.
2. The archiving policy shall take into account which data should/must be retained, for how long, and why.

8. Security

1. GCHR shall ensure as far as possible that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access, and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is as far as possible irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, GCHR shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Data Protection Commission (DPC). (See more information on the DPC website).