Data Protection and Confidentiality Policy
A professional framework for protecting the data of workers, reporting persons, witnesses, complainants and users of PLRO services.
Core principle
Data collection, use, access and sharing must be limited to what is necessary for monitoring, documentation, referral, follow-up, analysis and the Observatory’s services.
Data classification
Public data
Published reports, aggregated indicators and statistics, policy briefs, awareness materials and information intended for the public.
Internal data
Internal analyses, draft reports, unpublished files, operational notes and information not intended for public release.
Sensitive data
Names of workers, reporting persons and witnesses; contact details; workplaces; legal, medical and occupational documents; and individual case details.
1. Data minimisation
PLRO collects only the data directly necessary to handle, document, refer, follow up or analyse a case.
2. Purpose limitation
Information is used for the purpose for which it was collected. It is not used for an incompatible purpose without a clear justification and an approved institutional procedure.
3. Access permissions
PLRO follows the principle of need to know. Access is restricted to authorised staff to the extent required by their duties.
4. Storing sensitive information
- Sensitive information is stored in approved systems and channels.
- Sensitive files are not stored on unapproved personal devices or accounts.
- System access rights are assigned according to roles and responsibilities.
- Appropriate backup and protection procedures are applied.
5. Sharing data
Personal or sensitive data are shared only when sharing is:
- For a clear, specific purpose.
- Necessary to handle the case.
- Limited to the minimum required.
- In accordance with approved permissions and procedures.
- Through a secure channel.
- Subject to consent and risk assessment where required.
6. Anonymisation
The Observatory uses aggregated or anonymised data in reports, studies, indicators and public outputs, and separates personal data from analytical data wherever possible.
7. Backups and data security
Data are stored in approved systems with appropriate organisational and technical safeguards against loss, breaches and unauthorised access. Regular backups follow established procedures.
8. Retention and deletion
Retention periods depend on operational or legal needs and the nature of each case. When no longer needed, data are securely deleted, destroyed or archived under approved procedures.
9. Data security incidents
If data are lost or unauthorised access is suspected, steps are taken to contain the incident, assess risks, notify the relevant internal authorities and implement corrective measures.