This statement outlines rights to flood affectees personal information and contains general principles that apply to the handling of flood affectees personal information when field surveyors collect their data.

 SPHF Data Privacy 

We believe that all flood affectees should be able to trust Sindh Peoples Housing for Flood Affectees (SPHF) with their personal and financial information which is why we apply the following key privacy principles.

• SPHF will process personal information in accordance with this privacy statement and all applicable laws of Pakistan.
• We will do our best to be transparent on how we handle flood affectees information.
• We will only process an affectees personal information for providing flood relief assistance under our flood relief program, and only for as long as it is necessary to achieve those purposes. We will dispose of the personal information safely and securely once it is no longer required.
• SPHF will enable you to exercise choice and control over our processing of your personal information, not only when we are required to do so by the applicable law, but also in other circumstances where SPHF think it is the right thing to do.
• SPHF will make sure that the personal information of all affectees is safe through appropriate security measures.
• SPHF will take steps to ensure that all collected personal information is adequately protected.
• SPHF will make best efforts to incorporate privacy and data protection measures into SPHF application and services and will prioritize the privacy of flood affectees data.

What data do SPHF collect :

The data collected is for the purpose of impact of 2022 floods on housing in affected districts, requiring information related to identification of household/ occupant, technical details of damage to the housing unit, necessary information for supporting and opening of bank account for transparent disbursement of funds/support for housing reconstruction extended by Government of Sindh along with information supporting transfer of land titleship.

There is certain personal information that is necessary for SPHF to perform aid distribution. These include:

• Affectee’s name, phone number, home address, date of birth, location, family members info, pictures of destructed houses and other information.

Typically, we collect this information:

• When we conduct survey in flood effected areas of Sindh.
• When beneficiary for aid will start reconstruction work of the house.
• When socio-technical assistance will visit to check work progress status.

We generally use this information to perform the following steps.

• Eligibility verification for housing reconstruction support/grant
• Certification as per guidelines for reconstruction at various levels of construction
• Extending support for documentation for effective project implementation
• Formulation/Identification of financial mechanisms/ modalities for transparency related to financial transactions.

During the course of SPHF Project life, we may collect information for;

• Geo-location data
• To monitor project implementation progress both physical & financial
• Information about occupation of beneficiaries
• Capacity building & training activities/initiative for housing reconstruction

Typically, we use the information above and any other information necessary;

• For troubleshooting, network management and network optimization purposes.
• Use the recorded information for training quality assurance, feedback or for records purposes;
• find ways in which we can better improve our service, such as using personal and/or aggregated statistics or de-identified information about beneficiaries, aid applicant, network traffic and location patterns to conduct research to help improve our understanding of beneficiaries needs.
• conduct research that create value for the community.
• Analyses use of our network and services to identify general trends and survey results to improve services for beneficiaries.
• Send Informative SMS communications about aid and services based on beneficiaries needs. And/or share information within government departments, for processing, service development, community betterment, analytics and research purposes.

Information needed for us to protect your security 

We use the information to keep our services and communities safe and secure:

• we may investigate or take action regarding suspicious and illegal activities that violate our Terms of Services, or the applicable law; and/or
• share information, in accordance with applicable law/regulations and/or court orders, with the relevant authorities, for example, to protect beneficiaries or someone else from harm or damage.

Information you consented to provide to us 

The information provided is as per consent of the occupant / affectee whose house/is assessed during the survey

How we protect your personal information

We ensure that beneficiary’s personal information is safe and secure through the following measures:

• When beneficiaries shares information all of the data is encrypted using cryptographic protocols such as Transport Layer Security (TLS) and Secure Socket Layer (SSL) encryption. We employ such cryptographic protocols on all pages on our websites from where SPHF control all personal information.
• When SPHF use service providers or other data processors to process beneficiary’s personal information on our behalf, we ensure that the relevant providers and processors will implement appropriate technical and organizational measures to protect the information. Such controls include access control to the information and the infrastructure that stores the information, contractual arrangement that requires the third parties to comply with all relevant laws. We apply privacy and data protection by design and by default, and build privacy and data protection into the foundation of our aid distribution services.

How long we keep your personal information for 

We will only process affectees / beneficiary’s personal information for providing assistance under the flood relief program, and only for as long as it is necessary to achieve those purposes. We will dispose of affectee’s / beneficiary’s personal information safely and securely once it is no longer required subject to applicable laws for retention of data. For example, the government of Sindh requires that we maintain flood affectees records for 5 years.

Your rights

It is important to us that each affectee understands its privacy rights. Therefore, please note the following:

• Right to withdraw consent: Where an affectee has consented for us to use, process, or share its personal information, it can withdraw that consent any time, unless the information is required for us to perform our services.
• Right to access information: An affectee can access and request a copy of the personal information that we retain by contacting SPHF.
• Right to erasure: An affectee can request that we erase some of the personal information we retain, provided that certain circumstances apply:
  • The information is no longer needed by us and there is no legal requirement on us to retain the information;
  • We will do our best in accommodating the request, but please bear in mind that this may result in the affectee being ineligible to receive some or all of the benefits under SPHF’s flood relief program.

Revision of this privacy statement

We commit to reviewing this statement periodically, and on an ongoing as needed basis. If there are material changes to the statement, we may inform the affectee / beneficiary through ways in which we think fit, which may include a prominent announcement on our homepage, emails, SMS or message to affectees / beneficiaries registered phone numbers.

We will consider factors such as materiality of the change, the services affected by the change, and the reach when SPHF chooses a method of notification. SPHF is responsible for the handling of your personal information as per this policy and the applicable laws of Pakistan, which shall prevail in the event of any conflict.