UNCC PROJECT PRIVACY POLICY

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United Nationals Countryless Children (UNCC)

Area: Governance, Leadership & Management
Version: 1.0
Approved by: UNCC Board
Review Cycle: Every 2 Years

1. Purpose

The purpose of this Privacy Policy is to ensure that UNCC:

• Meets its obligations under Australian Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)

• Complies with ACNC Governance Standards and DFAT safeguarding requirements

• Aligns with Uganda, Kenya, and East African data protection laws

• Upholds international humanitarian standards on confidentiality and protection

This policy ensures that all individuals engaging with UNCC have their privacy, dignity, and confidentiality protected at all times.

2. Scope

This policy applies to:

• People UNCC supports (children, young mothers, seniors, families)

• Staff, volunteers, consultants, contractors

• Donors and collaborators

• Website users and community members

• Partner organisations and referral agencies

3. Policy Statement

UNCC is committed to:

• Protecting personal information from misuse, loss, or unauthorized access

• Ensuring confidentiality, particularly for children and vulnerable persons

• Maintaining transparency and accountability

• Upholding safeguarding and protection principles

4. Information We Collect

UNCC may collect personal and sensitive information including:

4.1 People We Support

• Name, contact details, date of birth

• Family and caregiver details

• Education and service history

• Health and vulnerability information

• Protection case information

4.2 Workforce & Representatives

• Identity and contact details

• Employment history and qualifications

• Criminal background checks

• Banking and payment details

4.3 Donors & Partners

• Contact information

• Donation and engagement records

4.4 Website Users

• IP address and technical data

• Usage patterns and interaction data

5. Why We Collect Information

We collect information to:

• Deliver humanitarian services and protection programs

• Provide child safeguarding and case management

• Support education, health, and welfare programs

• Manage employment, volunteers, and partnerships

• Meet legal, regulatory, and donor obligations

• Respond to enquiries, feedback, and complaints

6. Collection of Information

Information is collected through:

• Direct interaction (interviews, forms, assessments)

• Referrals from partners (UNHCR, NGOs, authorities)

• Community outreach

• Website and communication platforms

• Third parties (with consent or legal basis)

UNCC ensures informed consent and culturally appropriate communication methods.

7. Use and Disclosure of Information

UNCC may disclose personal information to:

• Staff, volunteers, and implementing partners

• Government and regulatory authorities

• Protection agencies and humanitarian actors

• Donors (aggregated/anonymised data)

• Legal, financial, and professional advisers

Disclosure occurs only when:

• Consent is provided

• Required by law

• Necessary for protection or safeguarding

• Required for humanitarian coordination

8. Safeguarding & Sensitive Information

UNCC applies strict safeguards for:

• Children and young mothers

• Survivors of abuse or exploitation

• Vulnerable seniors

Sensitive data is:

• Collected only when necessary

• Stored securely

• Shared strictly on a need-to-know basis

9. International Standards Compliance

UNCC complies with:

• United Nations Convention on the Rights of the Child (UNCRC)

• Universal Declaration of Human Rights (UDHR)

• IASC Safeguarding & Protection Guidelines

• PSEA (Prevention of Sexual Exploitation and Abuse)

10. Overseas Disclosure

Due to international operations, information may be shared with partners outside the country of origin.

UNCC ensures:

• Secure data transfer

• Confidential handling

• Compliance with donor and legal requirements

11. Data Storage & Security

UNCC protects personal information through:

• Secure cloud systems and restricted access

• Password-protected databases

• Staff confidentiality agreements

• Regular data protection training

• Physical and digital security controls

12. Access and Correction

Individuals have the right to:

• Access their personal information

• Request correction of inaccurate data

Requests will be handled promptly and respectfully.

13. Complaints

Individuals may lodge complaints regarding privacy breaches.

UNCC will:

• Investigate fairly and promptly

• Provide a transparent response

• Take corrective action

If unresolved, complaints may be escalated to relevant authorities.

14. Website & Digital Privacy

UNCC collects limited website data for:

• Improving services

• Monitoring engagement

For full details:
👉 www.unccs.org/privacy

15. Provision of Information

Providing personal information is voluntary.

However, failure to provide required information may limit UNCC’s ability to deliver services.

16. Policy Review

UNCC will review this policy regularly to ensure:

• Compliance with laws

• Alignment with donor requirements

• Continuous improvement

17. Relevant Legislation

• Privacy Act 1988 (Australia)

• Australian Privacy Principles (APPs)

• Information Privacy Act (East Africa jurisdictions where applicable)

• Human rights and humanitarian protection laws

18. Supporting Standards

• ACNC Governance Standards

• DFAT Safeguarding & Transparency Requirements

• UNHCR Protection Frameworks

• ACFID Code of Conduct

• ISO 9001 (Quality Management)

19. Related Procedures

• Consent Procedures

• Safeguarding & Child Protection Procedures

• Complaints & Appeals Procedures

• Data Protection & Record Management Procedures

20. Approval & Sign-Off

Approved by:
Peter Lino Lomoro – Co-Founder & Director

Reviewed by:
UNCC Board Members (Uganda & Kenya)

Effective Date: 03/01/2026

Signature: 03/01/2026