Last updated 8th April 2022

Definitions

GDI

Means: 

• Disinformation Index Ltd, a company limited by guarantee and registered in England & Wales with company number 11297397; and/or
• Disinformation Index Inc, a nonprofit nonstock corporation with public charity status incorporated in Delaware and operated exclusively for charitable and educational purposes within the meaning of section 501(c)(3) of the Internal Revenue Code of 1986; and/or
• GDI Global Disinformation Index gUG, a nonprofit limited liability company (tax number 27/613/05773) with registered office in Berlin, which exclusively and directly pursues charitable purposes within the meaning of the section "tax-privileged purposes" of the German Fiscal Code.

GDPR

Means the General Data Protection Regulation (EU) 2016/679. 

Responsible Person

Means Jo Jenks, person responsible for data protection within GDI, contactable at the following mailing address: Disinformation Index Ltd, 4 Emmanuel Court, Reddicroft, Sutton Coldfield, West Midlands B73 6AX, UK or via email at: [privacy@disinformationindex.org](<>)

Register of Systems

Means a register of all systems or contexts in which personal data is processed by GDI.

1. Data protection principles

GDI is committed to processing data in accordance with its responsibilities under legislation in the countries in which it operates, which includes (but is not limited to) the GDPR. Article 5 of the GDPR requires that personal data shall be:

• processed lawfully, fairly and in a transparent manner in relation to individuals;
• 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, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes);
• processed in a way that is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
• 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 insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or 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
• processed in a manner that 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

This policy applies to all personal data processed by GDI.

The Responsible Person has lead responsibility for GDI’s ongoing compliance with this policy.

This policy shall be reviewed at least annually.

Disinformation Index Ltd is not required to pay a fee to the Information Commissioner’s Office as an organisation that processes personal data since it is a company limited by guarantee set up for not-for-profit purposes.

3. Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, GDI maintains a Register of Systems, which is reviewed at least annually.

Individuals have rights in relation to the processing of their date, including the right to access their personal data in accordance with legal requirements, and any such requests made to GDI shall be dealt with in a timely manner, and in accordance with statutory deadlines.

4. Lawful purposes

All data processed by GDI shall fall within one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). GDI will note the appropriate lawful basis in the Register of Systems and - where consent is relied upon as a lawful basis for processing data - evidence of opt-in consent will be kept with the personal data.

Data is retained for three (3) years following your last contact with GDI or until you object to one and/or more of these uses by clicking on the corresponding link appearing in GDI’s newsletters, or by sending a simple written request to the Responsible Person at the above-mentioned address.

7. Archiving / removal

To ensure that personal data is kept for no longer than necessary, GDI has in place an archiving policy for each area in which personal data is processed and reviews this process annually. The archiving policy considers what data should/must be retained, for how long, and why.

8. Security

GDI ensures that personal data is stored securely using modern software that is kept-up to date.

Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.

When personal data is deleted, the data is rendered irrecoverable.

Appropriate back-up and disaster recovery solutions are 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, GDI shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the applicable regulator.