Data Protection Policy
International Tropical Timber Organization (ITTO)

Last updated

13 November 2020

Definitions
Organization

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

Responsible
Person

The Director of Operations

Register
Systemsof Register of all systems or contexts in which personal data is processed bythe 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 amanner 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;c. adequate, relevant and limited to what is necessary in relation to the purposes forwhich they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken toensure 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 than isnecessary 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 andorganisational measures required by the GDPR in order to safeguard the rights andfreedoms of individuals; andf. 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
a. This policy applies to all personal data processed by the Organization.
b. The Responsible Person shall take responsibility for the Organization’s ongoingcompliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Organization shall register with the Information Commissioner’s Office (ICO) as anorganization that processes personal data.
3. Lawful, fair and transparent processinga. To ensure its processing of data is lawful, fair and transparent, the Organization shallmaintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to
the Organization shall be dealt 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, evidence of opt-in
consent shall be kept with the personal data.
d. 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 bein place to ensure such revocation is reflected accurately in the Organization’s systems.
5. Data minimisationa. The Organization shall ensure that personal data are adequate, relevant and limited towhat is necessary in relation to the purposes for which they are processed.
6. Accuracy
a. 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 shall be put inplace 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, the Organization shallput in place an archiving policy for each area in which personal data is processed andreview this process annually.

b. The archiving policy shall consider what data should/must be retained, for how long,and why.
8. Security
a. 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 and appropriate
security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data isirrecoverable.
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, the Organization shallpromptly assess the risk to people’s rights and freedoms and if appropriate report this breachto the ICO (more information on the ICO website).

END OF POLICY