Privacy Notice

Statement on Processing of Personal Data

This statement explains how and why the Palestinian Center for Human Rights (“PCHR”) and the Danish Institute against Torture (“DIGNITY”) use the personal data you provide in the course of your interview. The reason we need to explain this before the interview is to ensure you are fully informed of your right to data protection and privacy that you are entitled to in accordance with the EU General Data Protection Regulation (“GDPR”) once the information has been further processed by DIGNITY (headquartered in Copenhagen, Denmark).

Information we collect

In the course of this interview, the PCHR will collect personal data about you that will be further processed by the PCHR and its partner organisation DIGNITY. The types of personal data which we may collect from you include your name, address, and contact details; your date and place of birth; your educational background; information about incidents and events involving you as a victim or witness (for example, details of torture or other alleged crimes you have been subjected to or witnessed). We may also collect and use special categories of personal data about you including your racial or ethnic origin, political opinions, physical and mental health, religious or philosophical beliefs, trade union membership, sexual orientation, and gender identity. 

How we use this information

    We collect, store, review, and further process this personal data to:

    • Assist investigations regarding alleged crimes under international law committed against Palestinians;
    • Assist in ensuring perpetrators of alleged crimes under international law committed against Palestinians can be held accountable;
    • Publish information regarding alleged crimes under international law committed against Palestinians;
    • Provide you with information and support, where needed and possible; and
    • Allow us to contact you in the future if we need to.

    We will only collect the amount of personal data required to fulfil these functions effectively. 

    We can legally process your personal data on the basis of:

    • The General Data Protection Regulation, art. 6(1)(e) (public interests)
    • The General Data Protection Regulation, art. 6(1)(f) (our legitimate interests)
    • The General Data Protection Regulation, art. 9(2)(e) (personal data which are manifestly made public by the data subject)
    • The General Data Protection Regulation, art. 9(2)(f) (to establish, exercise and defend legal claims)
    • The Danish Data Protection Act, § 8 (our legitimate interests)

    We have assessed that our processing is legitimate and in the interest of both you, PCHR, and DIGNITY. Our processing of your personal data will be a valuable asset in building lawsuits and establishing, exercising and defending legal claims. Our processing is also in the interest of the public, as it is necessary to build lawsuits and establish, exercise and defend legal claims related to international crimes and human rights violations.

    Sharing personal data

    The PCHR and DIGNITY may share your personal data with the following third parties:

    • National or international criminal justice authorities conducting independent and impartial proceedings in accordance with human rights, which may include national investigators and prosecutors, the International Criminal Court and Europol;
    •  UN human rights bodies or other UN bodies with an accountability mandate (e.g. Special Rapporteur or OHCHR, etc.);
    • Other institutions seeking to facilitate access to remedies and reparations for victims of crimes under international law committed in Palestine that currently exist or may be established in the future.

    When we have given you enough information to enable you to make an informed decision, we will be asking you if you consent to the sharing of your personal data with these third parties. We may also share your personal data where the person or entity who is receiving it has a legitimate interest for which processing is necessary and proportionate. 

    In very exceptional cases, we may be required to share your personal data with other bodies if we are under a legal duty to do so, where doing so would not violate international human rights law. This may be where we are required to do so by a court order or for the purposes of prevention of fraud or other crime. 

    Storing personal data

    We will store and transfer your personal data using methods that are secure in order to prevent your personal data from being accessed in an unauthorised way, altered, or lost. We monitor for any suspected data breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

    International Data Transfer

    When your personal data is being transferred from the Occupied Palestinian Territories (OPT) to the European Union, a third country or an international organization, such as the United Nations, this may only be done if the third country or the international organization in question meets the legal requirements of providing an adequate level of protection for individuals’ rights to privacy and data protection.

    Protecting personal data

    We put in place technical, administrative, and organisational security measures to protect your data against loss, misuse, and unauthorised access, disclosure, alteration, and destruction.

    Your data is stored securely on an encrypted platform managed by PCHR and DIGNITY. We monitor for any suspected data breach and will notify you and the relevant data protection authority of a suspected breach where we are legally required to do so.

    The staff involved in processing and sharing your data are subject to confidentiality.

    When sharing your personal data, we also take the highest precautions, by, for example, using secure and encrypted channels. If we transfer your information outside of the European Union, and the country in question has not been deemed by the EU Commission to have adequate data protection laws, we will make certain appropriate safeguards are in place for ensuring that your privacy rights continue to be protected.

    Data retention

    We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it.

    We have internal guidelines for the retention period of all categories of personal data. These are set in relation to the obligations we are subject to under applicable law, including documentation and audit requirements.

    When determining the retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    Your rights

    You have a set of rights as explained below:

    1. Your right of access: You have the right to request copies of your personal data.
    2. Your right to rectification: You can ask us to correct personal data you believe is inaccurate, and you also have the right to request completion of personal data you find incomplete.
    3. Your right to erasure: You can request the erasure of your personal data under certain circumstances.
    4. Your right to restriction of processing: You can request the restriction of processing of your personal data in certain situations.
    5. Your right to object to processing: You have the right to object to our processing of your personal data.
    6. Your right to lodge a complaint to the Danish Data Protection Agency: If you are not satisfied with how we handle your personal data, you have the right to file a complaint with the Danish Data Protection Agency.

    Contact

    If you want to exercise any of your rights, wish to withdraw consent, complain, or have any queries about the processing of your personal data or the safeguards we put in place to protect it, please contact:

    • Email: PCHR at [email protected] and DIGNITY at [email protected]
    • Mail: PCHR, Deir Albalah, Baghdad St known as Abu Asad St, Tawfiq Abu Asad Building, 2nd Floor, DIGNITY, Bryggervangen 55, 2100 København, Denmark

    Complaints

    You also have the right to make a complaint at any time to the data protection regulator in the country in which your data is being processed. 

    Complaints regarding processing of personal data could be filed respectively with 

    In Denmark, where DIGNITY is located, the Danish Data Protection Agency – datatilsynet.dk

    The Danish Data Protection Agency
    Carl Jacobsens Vej 35
    2500 Valby
    Denmark
    Web: https://www.datatilsynet.dk/english
    Email: [email protected]   Phone: +45 3319 3200