Purpose

The purpose of this policy is to clarify how we protect and use any personal information we collect about you when you use or contact us about our services, and to ensure a standard process is in place to informs individuals about their rights regarding this data.

Policy

The policy applies to personal data provided to Counterpart International, Inc. (Counterpart), both by the individual themselves and by others and what their rights are regarding the data.

Collection of Personal Data

For the purposes of this policy, personal data is information in any format that relates to a living individual who can be identified by that information, either on its own or when it is combined with other information held by Counterpart.

Counterpart does not collect Personally Identifiable Information (PII) for persons under 16 years of age, unless consent is provided by someone with “parental responsibility”. Counterpart makes “reasonable efforts” to verify the person providing that consent is indeed a parental figure.

Counterpart will only collect personal data when necessary for business-related purposes. The data may be collected directly from the individual for the agreed purposes of employment, consideration for employment, assistance in making donations, informing you about goods or services we provide, providing services to you, executing contracts and or agreements, or keeping people informed about Counterpart’s work.

The types of Personal Data Counterpart may collect includes, but is not limited the following:

• Name and address
• Gender, marital status and date of birth
• Telephone and email
• Employment history, qualifications, and skills
• Forms I-9, W8BEN, W9
• Banking and transfers
• Information provided digitally through Counterpart’s websites, applications, associated sites, outreach activities, or social media accounts

You have choices when it comes to the data you share. When we ask you to provide personal data, you can decline. Many of our services and engagements some personal data to provide you with a service. If you choose not to provide data necessary to provide you with a service, we cannot engage you regarding that service. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing service or relationship with Counterpart, we may have to suspend or cancel it. We will notify you if this is the case at the time.

Personal Data is collected through our interactions with you and through our products and services. The data we collect depends on the context of your interactions with Counterpart and the choices you make, including the services you use and the way you engage Counterpart. This includes:

• Application for employment submitted by the individual
• Through government agencies or third-party reporting services as legally required
• Details provided by the individual regarding disabilities and any accommodations Counterpart may need to make in the workplace
• Information provided by the individual through direct communication between the individual and Counterpart personnel, such as email, mail, by telephone and direct meetings
• Applications by the individual to attend events such as conferences, meetings and trainings
• Photos and videos of your attendance at training events or similar sessions
• Enquiries made by individuals through our websites and comments made through our websites or social media accounts
• Your interaction with us through social media accounts, registers, subscriptions or email communications (e.g. through a subscription to Counterpart’s mailing list)

Counterpart relies primarily on consent from individuals to collect, process, and hold their data. An individual may choose to not provide consent or not provide certain personal data. If an individual chooses not to provide consent or key data, Counterpart may not be able to provide the individual with services or contract with them.

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Counterpart International to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting privacy@counterpart.org.

Use of Personal Data

The Personal Data Counterpart collects is for the following purpose:

• Assess your suitability for possible employment or a contractual engagement
• Employment
• Provide you with services
• Receive services from you
• Submission of documents to our clients/funders
• Keep you informed of our work, and the services we provide
• Compliance with relevant laws or other legal requirements

Transfer of Personal Data

We may pass your personal data on to third-party service providers contracted to Counterpart International while dealing with you only if strictly necessary for the reasons stated above.

Any third parties that we may share your data with are obliged to keep your details securely, and to use them only assist us in performing our services.

When they no longer need your data to fulfil this service, they will dispose of the details in line with Counterpart International’s procedures. If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent unless we are legally required to do otherwise.

Counterpart will only share your personal data when legally permitted or required to do so. Counterpart includes contractual language with third-parties regarding data protection, confidentiality, and secure guidelines to ensure that the transfer will be under an agreement which covers the EU GDPR requirements.

Personal information that Counterpart holds may be transferred to the following types of organizations:

• Third-party organizations that provide support services such as payroll, travel, health insurance, and others
• Professional advisors such as lawyers, auditors, and accountants
• Law enforcement, government, or other regulatory agencies as provided by law

Retention of Personal Data

It is Counterpart’s intent to not keep personal information for longer than reasonably required. The retention period depends on the nature of the personal data and the purposes for which it was received. Counterpart has a Document Retention Policy that lays out the retention period for all manners of data. The Data Retention policy has been created based on best practices for our sector.

Your Rights as an Individual

At any point while Counterpart is in possession of personal data, data subjects who are EU residents have the following rights:

• Right to Access: Subject to certain conditions, you have the right to access the information Counterpart holds on you. You can request a copy of the information.
• Right to Correction: You have the right to correct data that Counterpart holds that is inaccurate or incomplete.
• Right to be forgotten: In certain circumstances, you can request that data Counterpart holds be erased from our records.
• Right to Object to or Restrict Processing: When certain conditions apply, you have the right to object to or ask Counterpart to restrict the processing of your personal data.
• Right to Data Portability: You have the right to have the data Counterpart holds on you transferred to another organization.
• Right to Object: You have the right to object to certain types of processing such as direct marketing.
• Right to Withdraw Consent: Where Counterpart’s processing of your personal data is based on your consent, you have the right to withdraw your consent. However, it will depend on Counterpart’s legal obligations.

To process the above, Counterpart may need to request additional information from you to confirm your identity. Any request will be responded to in accordance with regulatory requirements once your request has been determined valid. See Contact and Complaints Request section for further guidance.

Breaches of Personal Data

All personal data is protected, and measures and procedures are in place to minimize the risk of unauthorized access or disclosure; Counterpart adheres to best practices to protect personal data, including encryption when the data is in transit between systems or stored at any location; providing access to data on a need-to-know basis; and performing periodical internal and external security evaluations of its controls and information security practices.

Counterpart will respond to any breach as required by the regulation. If anyone becomes aware of a data breach, they should contact privacy@counterpart.org immediately.

Cookies

Our systems may use different tracking technologies to help us understand how users use our services. These analytical tools use ‘cookies’, which are text files placed on your computer to identify your browser, and log information related to your use of Counterpart’s systems.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. If a service we provide to you (e.g. site registration) requires cookies to function, clearing or blocking cookies could disable the service.

The information gathered (including your IP address) may be transmitted to a third party for processing. This information is then used to evaluate visitors’ use of the service and to compile statistical reports on activity.

Our website may contain links to other sites with the purpose of linking directly to the source data, or to provide references to the work of other organizations (to name a few). These links are external to Counterpart, and this document is not effective once leaving the website.

By using any website related to Counterpart, you consent to the processing of data about you by Counterpart and its affiliates and service providers in the manner and for the purposes set out above.

Images Utilized by Counterpart

Counterpart utilizes images collected by our staff to demonstrate the nature and impact of our work. Counterpart seeks consent to the degree practical from the individuals depicted in these images. If your likeness is reproduced in any of the image to be deleted, please contact Counterpart and the images will be promptly removed.

Contact for Requests and Complaints

If you would like to submit a request regarding your personal information or to submit a complaint, please submit a request to privacy@counterpart.org.

The GDPR regulation provides data subjects the possibility of lodging a complaint with a supervisory authority.

Changes to this Policy

This policy is subject to change based on operational needs, to adequate it to new technologies and services, and to incorporate changes in the law.