Introduction

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:
o The information is no longer needed by us and there is no legal requirement
on us to retain the information;
 o 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.