The rules of processing and protection of personal data in the databases, the holder of which is the public organization “The Kharkow Human Rights Protection Group”

19.04.2024

ADOPED:

11 October 2022

Director Evgeniy Zakharov

The public organization “The Kharkov Human Rights Protection Group” (hereinafter – the KHPG) is non-profit organization registered in accordance with the legislation of Ukraine. The KHPG acts under the Law of Ukraine "On Public Associations" and it’s Statute.

The KHPG implements its statutory purposes and objectives on the basic of the following principles:

1) rule of law;

2) objectivity;

3) the priority of human rights and fundamental freedoms;

4) dedication to the protection of the public good

5) political and religious impartiality;

6) confidentiality of personal data;

7) prevention of conflict of interest and corruption;

8) resolving conflicts within the organization;

9) solidarity - relationships of the members of the KHPG and the staff are based on the principles of mutual confidence, mutual respect, mutual support;

10) equality;

11) benevolence, tolerance, respect for positions of minority.

CHAPTER І. GENERAL PROVISIONS AND THE SCOPE

The terminology used in these Rules, the rights of subjects of personal data, the order of making the requests of personal data, the order of processing of personal data, the order of access to personal data of third parties by their request, the procedure for processing of this request are determined by the Law of Ukraine "On Personal Data Protection."

The Scope

These Rules are mandatory for the use of the staff of the KHPG directly involved in processing and / or have access to personal data in connection with their official duties.

CHAPTER ІІ. THE LIST OF PERSONAL DATABASES, THE HOLDER OF WHICH IS THE

The KHPG is the holder of the following personal databases:

1) documentation concerning the staff of the KHPG in the form of file cabinets and in electronic form;

2) documentation concerning the counterparties of the KHPG. in file form and in electronic form: various xls-tables and databases. In particular:

the database of clients of the public reception (1999 — 2024), updated on a daily basis;

database of registration cards of Dubravlag political prisoners (1945-1976);

database of political prisoners of Permlag (1972-1989);

database of Ukrainian political prisoners (1954-1989);

database of civilian victims of armed conflict 2014-2021;

the database of victims of international crimes committed since February 24, 2022 is updated daily.

Specified personal databases are located at the address: Kharkov city, 27 Ivanova St., Apt. 4 except for the last database which is located in Germany.

CHAPTER ІІІ. PURPOSE OF THE PROCESSING OF PERSONAL DATA

The purpose of the processing of personal data in a database of the staff of the KHPG is ensuring of employment relations, administrative, legal, fiscal relations and relations in the sphere of accounting.

The purpose of the processing of personal data in a database of the counterparties is to provide administrative, legal, fiscal relations and relations in the field of accounting, as well as studying supply in the market of services which the KHPG uses to perform its projects and programs.

State registration of personal data is carried out in accordance with Article 9 of the Law of Ukraine "On Personal Data Protection."

CHAPTER ІV. PROTECTION OF PERSONAL DATA

The KHPG ensures the availability of the system, the software and hardware, and communications which prevent loss, theft, unauthorized destruction, forgery, and copying of the information and meet international and national standards.

The person responsible for the protection of personal data is the Chief bookkeeper of the KHPG.

Duties of the responsible person for the organization of work related to the protection of personal data during data processing are specified in the position description.

The responsible person is obliged:

1) to be aware of the legislation of Ukraine in the field of the protection of personal data;

2) to elaborate procedures for access to personal data of employees pursuant to their official or employment duties;

3) to ensure compliance of the employees of the KHPG with the legislation of Ukraine in the field of protection of personal data and internal documents which regulate the activities of the processing and protection of personal data in databases;

4) to elaborate a procedure of internal control over the compliance with the legislation on the protection of personal data and internal documents which regulate the activities of the processing and protection of personal data in databases of personal data, which, in particular, should contain provisions on the frequency of realization of such control;

5) to inform the Director of the KHPG or the heads of departments of the KHPG of facts of violations by the staff the legislation in the field of protection of personal data and internal documents which regulate the activities of the processing and protection of personal data in databases of personal data no later than the next business day after detection of such violations;

6) to ensure the storage of documents confirming that the subject of personal data gave consent for processing of his/her personal data and that the specified subject is aware of his rights.

For the purposes of fulfillment of his/her official duties the responsible person is entitled to:

1) receive necessary documents from the staff of the KHPG, including orders and other administrative documents issued by the Director of the KHPG related to the processing of personal data;

2) make copies of received documents, including copies of files and any records which are stored in local computer networks and autonomous computer systems;

3) unimpeded access to all office rooms of the KHPG;

4) submit to the Director of the KHPG suggestions on activities related to the processing of personal data and elimination of detected violations or deficiencies;

5) carry out interaction with other employees of the KHPG while performing their official duties and other activities related to the protection of personal data during data processing;

6) receive from of any employees of the KHPG explanations on issues of the processing of personal data;

7) sign and vise documents within his/her competence.

The employees directly involved in processing and / or have access to personal data in connection with their official (employment) duties shall comply with the legislation of Ukraine in the field of protection of personal data and internal documents regulating the activities of the KHPG for the processing and protection of personal data in databases of personal data.

Employees who have access to personal data, including exercising of their processing shall not disclose in any way personal data that they were entrusted or which became known to them in connection with their official or employment duties. This obligation is valid after termination of their activities associated with personal data; unless otherwise is provided by law.

Persons who have access to personal data, including exercising of their processing in case of violation of the Law of Ukraine "On Personal Data Protection" are responsible under the legislation of Ukraine.

Personal data should not be stored longer than it is necessary for the purpose for which those data are stored, but in any event no longer than the term of storage agreement specified by the content of the subject of personal data for processing of this data.