{"id":3,"date":"2022-07-13T08:53:21","date_gmt":"2022-07-13T08:53:21","guid":{"rendered":"https:\/\/mustardbridge.org\/?page_id=3"},"modified":"2024-04-15T20:11:09","modified_gmt":"2024-04-15T20:11:09","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/mustardbridge.org\/?page_id=3","title":{"rendered":"Privacy Policy"},"content":{"rendered":"\t\t
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Data Protection policy for Mustard Bridge Foundation<\/strong><\/span><\/p>\n

\u00a0<\/p>\n

\"\"<\/p>\n

MUSTARD BRIDGE FOUNDATION<\/em><\/strong>
P.O.BOX 191, Bushenyi.<\/em><\/strong>
info@mustardbridge.org<\/em><\/strong><\/p>\n

Introduction<\/strong><\/span>
Mustard Bridge Foundation needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled, stored and erased, to meet the company\u2019s data protection standards thus complying with the legislation.<\/p>\n

Purpose<\/strong><\/span>
This data protection policy ensures Mustard Bridge Foundation :
complies with Data Protection legislation and follows good practice;
protects the rights of employees, customers and partners;
is transparent in terms of how it stores and processes individuals\u2019 data;
protects itself from the risks associated with a data breach.<\/p>\n

Scope<\/strong><\/span>
This policy includes in its scope all data which we process either in hardcopy or digital copy, this includes special categories of data. This policy applies to all staff, members, suppliers
Its purpose is to protect the \u201crights and freedoms\u201d of natural persons (i.e., living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.<\/p>\n

Policy Statement<\/strong><\/span>
Mustard Bridge Foundation is committed to compliance with all relevant Uganda law in respect of personal data, and the protection of the \u201crights and freedoms\u201d of individuals whose information we collect and process. We are committed to protecting and respecting personal data. We wish to be transparent on how we process personal data and demonstrate that we are accountable with the policy in relation to our processing of the data.<\/p>\n

The policy describes how organisations must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.<\/p>\n

Privacy Policy – Data Protection Principles<\/strong><\/span>
This policy underpinned by six important principles requiring that personal data be:
\u2022Processed lawfully, fairly and in a transparent manner;
\u2022Collected for specified, explicit and legitimate purpose;
\u2022Adequate, relevant and limited to what is necessary;
\u2022Accurate and where necessary, kept up to date;
\u2022Retained only for as long as necessary;
\u2022Processed in an appropriate manner to maintain security.<\/p>\n

This policy are applicable to all personal data processing functions, including those performed on customers\u2019, clients\u2019, employees\u2019, suppliers\u2019 and partners\u2019 personal data, and any other personal data the organisation processes from any source.<\/p>\n

The Data Protection Officer is responsible for reviewing the register of data processing annually, in light of any changes to Mustard Bridge Foundation activities.<\/p>\n

Partners and any third parties working with or for Mustard Bridge Foundation, and who have or may have access to personal data, will be expected to have read, understood and to comply with this policy.<\/p>\n

No third party may access personal data held by Mustard Bridge Foundation without having first entered into a data confidentiality agreement which imposes obligations on the third party no less onerous than those to which we are committed, and which gives us the right to audit compliance with the agreement.<\/p>\n

1. Personal Date must be processed lawfully, fairly and in a transparent manner<\/strong>
Mustard Bridge Foundation will not process any personal data unless there is a legal basis to do so such as consent or it is necessary for the performance of a contract.
Mustard Bridge Foundation does not knowingly collect any personal identifiable information from children under age of 18.
Therefore, processing will be lawful if:
\u00a0\u2022 The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; or
\u2022 The data subject has given consent to the processing of his or her personal data for one or more specific purposes.<\/p>\n


\u00a02. Personal data can only be collected for specific, explicit and legitimate purposes<\/strong>
Data obtained for specified purposes must not be used for a purpose that differs<\/p>\n

\u00a03. Personal Data must be adequate, relevant and limited to what is necessary<\/strong>
The Data Protection Officer is responsible for ensuring that Mustard Bridge Foundation do not collect information that is not strictly necessary for the purpose for which it is obtained.<\/p>\n

All data collection forms, e.g., proposal forms\/application forms (electronic or paper-based), must include a fair processing statement or link to a privacy statement a. Callers should be advised that the privacy statement is available on the website https:\/\/www.mustardbridge.org.<\/p>\n


\u00a04. Personal data must be accurate and kept up to date with every effort to erase or rectify without delay<\/strong>
\u00a0\u2022Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate.<\/p>\n


It is also the responsibility of the data subject to ensure that data held by Mustard Bridge Foundation is accurate and up to date. Completion of a registration or application form by a data subject will include a statement that the data contained therein is accurate at the date of submission.<\/p>\n

5. Personal data must be kept in a form such that the data subject can only be identified for as long as is necessary for processing.<\/strong>
Where personal data is retained beyond the processing date, it will be minimised, encrypted\/pseudonymised, in order to protect the identity of the data subject, in the event of a data breach.<\/p>\n

Personal data will be retained in line with the Retention of Records Procedure\/Schedule and, once its retention date has passed, it must be securely destroyed, as set out in this procedure.
Consent<\/strong><\/span>
Mustard Bridge Foundation understands \u2018consent\u2019 to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject\u2019s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time.<\/p>\n

Mustard Bridge Foundation also understands \u2018consent\u2019 to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the grounds of misleading information will not be a valid basis for processing.<\/p>\n

There must be some active communication between the parties to demonstrate \u201cactive consent\u201d. Consent cannot be inferred from non-responsive communications. We must be able to demonstrate that consent was obtained for the processing operation.<\/p>\n

For sensitive data, explicit consent from data subjects must be obtained unless an alternative legitimate basis for processing exists.<\/p>\n

Data Subjects\u2019 Rights<\/strong><\/span>
Data subjects have the following rights regarding data processing, and the data that is recorded about them:
\u00a0 \u2022 To make subject access requests regarding the nature of information held and to whom it has been disclosed;
\u2022 To prevent processing likely to cause damage or distress;
\u2022 To prevent processing for purposes of direct marketing;
\u2022 To be informed about the mechanics of automated decision-making process that will significantly affect them;
\u2022 To not have significant decisions, that will affect them, taken solely by automated process;
\u2022 To sue for compensation if they suffer damage by any contravention of the policy;
\u2022 To act to rectify, block, erase, including the right to be forgotten, or destroy inaccurate data;
\u2022 To request the Data Protection Commissioner to assess whether any provision of the policy has been contravened;
\u2022 To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller;
\u2022 To object to any automated profiling that is occurring without consent.<\/p>\n

Data Subject Access Requests<\/strong><\/span>
All individuals who are the subject of personal data held by Mustard Bridge Foundation are entitled to:<\/p>\n

\u2022 Ask what information the company holds about them and why;
\u2022 Ask how to gain access to it;
\u2022 Be informed about how to keep it up to date;
\u2022 Be informed about how the company is meeting its data protection obligations.<\/p>\n

Should an Individual contact the company requesting this information, this is called a Subject Access Request.<\/p>\n

Subject Access Requests from individuals should be made by email
We will aim to provide the relevant data as soon as possible. Where we are unable to provide the requested data to the data subject, we will advise the data subject and provide the reason why.<\/p>\n

We will always verify the identity of anyone making a subject access request before handing over any information.
Security of Data<\/strong><\/span>
All Employees\/Staff are responsible for ensuring that any personal data that Mustard Bridge Foundation holds and for which we are responsible, is kept securely and is not, under any conditions, disclosed to any third party unless that third party has been specifically authorised by Mustard Bridge Foundation to receive that information and has entered into a confidentiality agreement.<\/p>\n

All personal data should be treated with the highest security and must be kept:
\u2022 in a lockable room with controlled access; and\/or
\u2022 in a locked drawer or filing cabinet; and\/or
\u2022 if computerised, password protected and\/or stored on (removable) computer media which are encrypted. Care must be taken to ensure that PC screens and terminals are not visible except to authorised employees\/staff of Mustard Bridge Foundation.<\/p>\n

Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed from secure archiving, provided that this removal does not infringe our other legal responsibilities and obligations.<\/p>\n

Records that have reached their retention date are to be shredded and disposed of as \u2018confidential waste\u2019. Hard drives of redundant PCs are to be removed and immediately destroyed, as required before disposal.<\/p>\n

Processing of personal data \u2018off-site\u2019 presents a potentially greater risk of loss, theft or damage to personal data.<\/p>\n

Disclosure of Data to Third Parties<\/strong><\/span>
Mustard Bridge Foundation will ensure that personal data is not disclosed to unauthorised third parties. All employees\/staff will exercise caution when asked to disclose personal data held on a data subject to a third party. We will consider whether disclosure of the information is relevant to, and necessary for, the conduct of our business. Nonetheless disclosure will only be to third parties that are authorised to receive it, and with whom we have in place a data protection \/ confidentiality agreement.<\/p>\n

All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures.
Disclosing Data for Other Reasons
In certain circumstances, Mustard Bridge Foundation will disclose personal data to law enforcement agencies without the consent of the data subject.<\/p>\n


Retention and Disposal of Data<\/strong><\/span>
Mustard Bridge Foundation shall not retain personal data for a longer period than is necessary, in relation to the purpose(s) for which the data was originally collected, except where it is required to be retained to meet other legislative or regulatory obligations.<\/p>\n

Mustard Bridge Foundation may also store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.<\/p>\n


Data Protection Risks<\/strong><\/span>
This policy helps to protect Mustard Bridge Foundation from potentially, serious data security risks, including:
Breaches of confidentiality:<\/strong> for instance, information processed inappropriately;
Reputational damage:<\/strong> for instance, the Company could suffer material or non-material damage if hackers successfully gained access to sensitive data.<\/p>\n

1. Data Storage<\/strong>
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Controller. When data is stored in paper format, it should be kept in a secure place where unauthorised people cannot see it.<\/p>\n

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer or filing cabinet;
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer;
Data printouts should be shredded and disposed of securely when no longer required;
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts;
Data should be protected by strong passwords that are changed regularly and never shared between employees;
If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used;
Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed-up frequently. Those back-ups should be tested regularly, in line with the company\u2019s standard backup procedures.
All servers and computers containing data should be protected by approved security software and a firewall.<\/p>\n

Data Usage<\/strong><\/span>
Personal data is of no value to Mustard Bridge Foundation unless the business can make use of it. However, it is when personal data is accessed and used, that it can be at the greatest risk of loss, corruption or theft. For example:
When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Data must be encrypted before being transferred electronically.
Personal data should never be transferred outside of Uganda without the knowledge and consent of the top management and then only where there is an appropriate \u201clevel of protection for the fundamental rights of the data subjects\u201d<\/p>\n

Data Accuracy
The law requires Mustard Bridge Foundation to take reasonable steps to ensure data is kept accurately and up to date. The higher the importance, that the personal data is accurate, the greater the effort Mustard Bridge Foundation should put into ensuring its accuracy.<\/p>\n

It is the responsibility of all employees who work with data to take reasonable steps, to ensure it is kept as accurate and up to date as possible:
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets;
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer\u2019s details when they call;
Mustard Bridge Foundation will make it easy for data subjects to update the information we hold about them. For instance, via the company website;
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database: and
It is the marketing manager\u2019s responsibility to ensure marketing databases are checked against industry suppression files every six months.<\/p>\n

Providing Information
Mustard Bridge Foundation aims to ensure that individuals are aware that their data is being processed, and that they understand:
How their data is being used;
How to exercise their rights.<\/p>\n

To this end, the company has a Privacy Notice setting out how data relating to individuals is used by the company. (This is available upon request. A version of this statement is also available on the Company\u2019s website).<\/p>\n

General Staff Guidelines<\/strong><\/span>
The only people able to access data covered by this policy should be those who need it for their work;
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers;
Mustard Bridge Foundation will provide training to all employees to help them understand their responsibilities when handling data;
Employees should keep all data secure, by taking sensible precautions and following the guidelines below;
Strong passwords are mandatory, and they should never be shared;
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated. If it is found to be out of date and\/or no longer required, it should be deleted and disposed of appropriately.
Employees should request help from their line manager or the Data Protection Officer if they are unsure about any aspect of data protection.<\/p>\n


Roles and Responsibilitie<\/strong><\/span>s<\/p>\n

Mustard Bridge Foundation is a Data Controller and\/or Data Processor.<\/p>\n

Data Protection Officer<\/strong>
Where a DPO is appointed:
The role holder will be a member of the senior management team, be accountable to Mustard Bridge Foundation for the management of personal data within Mustard Bridge Foundation and for ensuring that compliance with data protection legislation and good practice can be demonstrated.<\/p>\n

This accountability includes:
development and implementation of this policy; and
security and risk management in relation to compliance with the policy.<\/p>\n

All Employees\/Staff
Top Management and all those in managerial or supervisory roles throughout Mustard Bridge Foundation are responsible for developing and encouraging good information handling practices within Mustard Bridge Foundation; responsibilities are set out in individual job descriptions. Compliance with data protection legislation is the responsibility of all employees\/staff of Mustard Bridge Foundation who process personal data.<\/p>\n

Employees\/staff of Mustard Bridge Foundation are responsible for ensuring that any personal data about them and supplied by them to Mustard Bridge Foundation is accurate and up to date.<\/p>\n

Everyone who works for or with Mustard Bridge Foundation has some responsibility for ensuring data is collected, stored and handled appropriately.<\/p>\n

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.<\/p>\n

However, the following have key areas of responsibility:
The board of directors\/Partners\/Owner(s) is ultimately responsible for ensuring that Mustard Bridge Foundation meets its legal obligations.
The Data Protection Officer, is responsible for:
Keeping the board\/Partners\/Owner(s) updated about data protection responsibilities, risks and issues;
Reviewing all data protection procedures and related policies, in line with an agreed schedule;
Arranging data protection training and advice for the people covered by this policy;
Handling data protection questions from staff and anyone else covered by this policy;
Dealing with requests from individuals to see the data Mustard Bridge Foundation, holds about them (also called \u2018Data Subject Access Requests\u2019).
Checking and approving any contracts or agreements with third parties that may handle the company\u2019s sensitive data.<\/p>\n


Staff awareness training is mandatory for anyone who handles personal data or who is responsible for overseeing data protection practices.
Mustard Bridge Foundation will also ensure that training is relevant to the work that employees do. For example, those responsible for processing personal data should be taught about their responsibilities and the threats that come with that.
Definitions<\/strong><\/span>
Definitions used by the company drawn from the General Data Protection Regulation (policy)<\/p>\n

Personal Data<\/strong>
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.<\/p>\n

Data Subject<\/strong>
Any living individual who is the subject of personal data held\/processed by our organisation.<\/p>\n

Processing<\/strong>
Any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.<\/p>\n

Personal Data Breach<\/strong>
A breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.<\/p>\n

Data Subject Consent<\/strong>
Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.<\/p>\n\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/section>\n\t\t\t\t

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Data Protection policy for Mustard Bridge Foundation \u00a0 MUSTARD BRIDGE FOUNDATIONP.O.BOX 191, Bushenyi.info@mustardbridge.org IntroductionMustard Bridge Foundation needs to gather and use certain information about individuals. These can include customers, suppliers, …<\/p>\n

Privacy Policy<\/span> Read More »<\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"open","template":"","meta":{"site-sidebar-layout":"default","site-content-layout":"default","ast-main-header-display":"","ast-hfb-above-header-display":"","ast-hfb-below-header-display":"","ast-hfb-mobile-header-display":"","site-post-title":"","ast-breadcrumbs-content":"","ast-featured-img":"","footer-sml-layout":"","theme-transparent-header-meta":"","adv-header-id-meta":"","stick-header-meta":"","header-above-stick-meta":"","header-main-stick-meta":"","header-below-stick-meta":"","footnotes":""},"class_list":["post-3","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/pages\/3","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/mustardbridge.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=3"}],"version-history":[{"count":11,"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/pages\/3\/revisions"}],"predecessor-version":[{"id":1274,"href":"https:\/\/mustardbridge.org\/index.php?rest_route=\/wp\/v2\/pages\/3\/revisions\/1274"}],"wp:attachment":[{"href":"https:\/\/mustardbridge.org\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=3"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}