DATA PROTECTION POLICYFirst Edition

November 2022

INTERNATIONAL TROPICAL TIMBER ORGANIZATION

Adopted by the International Tropical Timber Council at its 58th Session

DATA PROTECTION POLICYInternational Tropical Timber Organization (ITTO)

Definitions
Organization

The International Tropical Timber Organization (ITTO)GDPRThe General Data Protection Regulation 2018 (GDPR)

Responsible
Person

The Director of Operations

Register ofSystems

Register of all systems or contexts in which personal data is processedby the Organization

1. Data protection principles

The Organization is committed to processing data in accordance with its
responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:a.

processed lawfully, fairly and in a transparent manner in relation to individuals;b.

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 historicalresearch purposes or statistical purposes shall not be considered to beincompatible with the initial purposes;c.

adequate, relevant and limited to what is necessary in relation to thepurposes for which they are processed;d.

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;e.

kept in a form which permits identification of data subjects for no longer thanis 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 toimplementation of the appropriate technical and organisational measuresrequired by the GDPR in order to safeguard the rights and freedoms ofindividuals; and-1-f.

processed in a manner that ensures appropriate security of the personaldata, including protection against unauthorised or unlawful processing andagainst accidental loss, destruction or damage, using appropriate technicalor organisational measures.”2. General provisionsa.

This policy applies to all personal data processed by the Organization.

b.

The Responsible Person shall take responsibility for the Organization’s
ongoing compliance with this policy.

c.

This policy shall be reviewed at least annually and updated as
appropriate and/or necessary.

d.

The Organization shall register with the Information Commissioner’s Office(ICO) as an organization that processes personal data.

3. Lawful, fair and transparent processinga.

To ensure its processing of data is lawful, fair and transparent, theOrganization shall maintain a Register of Systems.

b.

The Register of Systems shall be reviewed at least annually.

c.

Individuals have the right to access and rectify or erase their personal data,
the right to data portability and the right to confidentiality of electronic
communications, and any such requests made to the Organization shall bedealt with in a timely manner.

4. Lawful purposesa.

All data processed by the Organization must be done on one of the following
lawful bases: consent, contract, legal obligation, vital interests, public task
or legitimate interests (see ICO guidance for more information).

b.

The Organization shall note the appropriate lawful basis in the Register of Systems.

c.

Where consent is relied upon as a lawful basis for processing data, evidenceof opt-in consent shall be kept with the personal data.

d.

Where communications are sent to individuals based on their consent, theoption 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 the Organization’s systems.

-2-5. Data minimisationa.

The Organization shall ensure that personal data are adequate, relevant and limitedtowhat is necessary in relation to the purposes for which they areprocessed.

6. Accuracya.

The Organization shall take reasonable steps to ensure personal data is accurate.

b.

Where necessary for the lawful basis on which data is processed, steps shallbe put in place to ensure that personal data is kept up to date.

7. Archiving / removala.

To ensure that personal data is kept for no longer than necessary, theOrganization shall put in place an archiving policy for each area in which
personal data is processed and review this process annually.

b.

The archiving policy shall consider what data should/must be retained, for
how long, and why.

8. Securitya.

The Organization shall ensure that personal data is stored securely using
modern software that is kept-up-to-date.

b.

Access to personal data shall be limited to personnel who need access andappropriate security should be in place to avoid unauthorised sharing ofinformation.

c.

When personal data is deleted this should be done safely such that thedata is irrecoverable.

d.

Appropriate back-up and disaster recovery solutions shall be in place.

9. BreachIn the event of a breach of security leading to the accidental or unlawful destruction,
loss, alteration, unauthorised disclosure of, or access to, personal data, theOrganization shall promptly assess the risk to people’s rights and freedoms and if
appropriate report this breach to the ICO (more information on the ICO website).

END OF POLICY-3-