Data Protection Policy

For most organisations a data breach is an administrative failure. For an organisation working with survivors of gender-based violence, disclosure of the wrong information to the wrong person can put someone in physical danger. This policy is written with that consequence in view.

It operates alongside Cameroonian law, including Law No. 2010/012 of 21 December 2010 on cybersecurity and cybercriminality, and the confidentiality requirements of the IASC Guidelines on Gender-Based Violence.

1. Collect only what is needed for a stated purpose, and never collect information because it might be useful later.
2. Obtain informed consent, explained in a language the person understands, before recording personal information.
3. Store securely, with access limited to personnel who need it to do their work.
4. Never share identifiable information without the informed consent of the person concerned, except where there is a legal obligation or a risk of serious harm to a child or another person.
5. Retain only as long as necessary, then destroy securely.
6. Report and publish only in aggregated, de-identified form.

• Case records are stored separately from general programme records, with access restricted to designated case management personnel.
• Identifying information is kept to the minimum needed to provide support, and case codes are used in place of names wherever possible.
• Records are never transported in a form that identifies an individual, whether on paper or on a personal device.
• Case information is never discussed outside a supervision or referral context, including with colleagues who are not involved.
• A survivor's consent is required before information is shared with any referral partner, and consent may be limited to specific parties.

Informed consent is obtained before any photograph or recording is taken for publication, and the person is told where it may appear. Consent may be withdrawn. Survivors of violence are never photographed identifiably in connection with GBV programming, regardless of consent, because circumstances can change and a published image cannot be recalled.

• Programme data is not stored on personal devices or personal cloud accounts.
• Devices holding personal data are password protected and locked when unattended.
• Paper records are kept in locked storage and never left in vehicles or public spaces.
• Data is not shared through personal messaging accounts.

Participation in research is voluntary, informed and revocable. Published findings are aggregated so that no individual can be identified, including by combining details such as location, age and circumstance. Communities see findings about themselves before external audiences do.

Any suspected breach is reported immediately to the President. The response prioritises the safety of anyone affected — which may include warning them, supporting relocation, or alerting a referral partner — before any consideration of organisational reputation. Breaches are recorded, reviewed by the Bureau, and disclosed to affected individuals where they may be at risk.