Policies

This Responsible Data Policy borrows heavily from the Responsible Program Data Policy, 2015, developed by Oxfam, one of the first organisations in the social sector to develop such a policy. While the core of the said policy has been retained, relevant changes have been carried out to conform to applicable law in India and address other factual considerations in relation to Help Your Foundation. Responsible Data Policy v1.6, Help Your Foundation, 2020

As a rights-based organisation, Help Your Foundation (“We” / “Us” / “Our”) is committed to using data responsibly to uphold the rights of individuals, groups, and organisations with whom we work. Using data responsibly is not just an issue of technical security and encryption but also of safeguarding the rights of people—to be counted and heard; ensure their dignity, respect, and privacy; enable them to make informed decisions; and not be put at risk when providing data. We recognise that people have rights with regard to the information related to them, and that We have a responsibility to protect and uphold those rights. Accordingly, this document contains Help Your Foundation's ‘Responsible Data Policy’ (“Policy”), which is fundamentally rooted in the following rights:

• A. Right to be counted and heard
• B. Right to dignity and respect
• C. Right to make an informed decision
• D. Right to privacy
• E. Right to not be put at risk

This Policy guides Help Your Foundation’s treatment of data throughout the project/programme lifecycle i.e., from planning to collection of data through to the conclusion of the project/programme and disposal of data. This Policy sets out to facilitate the invaluable contribution that data makes to the quality of Our work, uphold accountability, and allow Us to raise the voices of those We work with.

This Policy is designed to be forward-looking and prepare Help Your Foundation for the future. It establishes a framework that enables Us to take full advantage of the current opportunities and future potential of the data revolution

For the purposes of this Policy, “Data” refers to the physical representation of information in a manner suitable for communication, interpretation, or processing by human beings or by automatic means. Data may be numerical, descriptive, audio, or visual, and may be collected formally, such as by means including Computer Assisted Personal Interviewing (CAPI) or the traditional Paper and Pencil Interviewing (PAPI). As an organisation, Help Your Foundation has almost fully digitised its data collection and uses CAPI for most of its data collection needs, using tools that are either owned by Help Your Foundation or that we are officially licensed to use. However, there may be instances (such as when a survey might be very simple, with a flexible timeline OR when we might want to use a very specific template, like training effectiveness feedback at the end of a session).

Informally, data might be collected when unplanned, unstructured conversations happen between Help Your Foundation staff and members of the community, or when informal data collection is more appropriate compared to formal data collection (as in the case of reporting abuse, for instance).

Data may pose varying degrees of risk to different stakeholders, including but not limited to the people who provide data, those that collect it, and Help Your Foundation itself. Therefore, this Policy provides an indicative and inclusive classification of data into high-, medium-, and low-risk to guide Help Your Foundation’s reasonable and responsible treatment of data.

Examples of high-, medium-, and low-risk data may include, without limitation:

• (i) High-risk data: Sensitive personal information, such as racial or ethnic origin, physical or mental health status, sexual orientation, political opinions or affiliations, religious or philosophical beliefs, criminal record, biometric data (e.g., photos, fingerprints), genetic information, medical records, refugee displacement status, etc.
• (ii) Medium-risk data: Other Personally Identifiable Information (“PII”) such as name, address, identity number, gender, age or date of birth, financial account numbers, contact details; anonymised and aggregated financial and medical records, etc.
• (iii) Low-risk data: Any other anonymised and aggregated records; any non-personal information.

The formal term for individuals from whom data is collected is “Data Subjects.” In this Policy, however, We use the term “participants” and expand the definition to include any individual, group, cooperative, Self-Help Group (“SHG”), partner, vendor, funding organisation, corporate entity, or any other entity with which Help Your Foundation works and that provides data, including Help Your Foundation’s own employees and consultants.

“Responsible data” is defined to mean: “The duty to ensure people’s rights to consent, privacy, security, and ownership around the information processes of collection, analysis, storage, presentation, and reuse of data, while respecting the values of transparency and openness.” Responsible data is a set of practices and considerations that aim to address challenges of understanding norms such as participation, consent, right to information, and the freedoms of expression, association, and privacy.

This Policy governs all project/programme data in the organisation, including data from funded programme components and those receiving unrestricted funds, financial data, operational data, data generated from and used in social media posts, and communication material. It applies to all aspects of the project and programme cycle, as well as research projects.

Help Your Foundation will conduct rigorous workshops on operationalising this Policy internally among its employees. Help Your Foundation will also ensure that external stakeholders (individuals, partner organisations, consultants, contractors, vendors, etc.) read and understand this Policy and accordingly consent to comply with the same.

An operational checklist will subsequently accompany this Policy. The checklist will provide details on how (i) to make a succinct communication of the prescriptions of this Policy to participants, and (ii) to seek participants’ informed consent for collection and use of data in accordance with this Policy. This checklist will be updated periodically.

Policy Elements

• A. Right to be counted and heard
• B. Right to dignity and respect
• C. Right to make an informed decision
• D. Right to privacy
• E. Right to not be put at risk