This policy is pending final adoption by the TDOU Board of Directors. It is published here for transparency while that process completes, and will be dated and finalised once approved.
This policy sets out how the Tigray Disability Organizations Union (TDOU) collects, uses, shares, and disposes of personal data across its programmes, advocacy, fundraising, and operations — not only on this website. For what happens specifically when you visit tdou.org.et, see our Privacy Policy.
1. Purpose and Scope
TDOU is committed to handling personal data with respect, transparency, and care — especially given the sensitive nature of disability-related information and the vulnerability of the communities we serve. This policy applies to all personal data TDOU holds (paper or digital), to all staff, volunteers, consultants, and board members, and to any third party that processes data on TDOU’s behalf. It does not apply to fully anonymised aggregate statistics that cannot be linked back to an individual.
No organisation can guarantee absolute data security. TDOU implements reasonable and proportionate controls given its size and resources, but cannot promise data will never be lost, stolen, or accessed without authorisation. We commit to notifying affected individuals and relevant authorities promptly in the event of any known breach.
2. Legal Framework
TDOU operates in Ethiopia and engages with international partners. This policy is guided by Ethiopia’s Personal Data Protection Proclamation No. 1321/2024 (in force since 24 July 2024, enforced by the Ethiopian Communications Authority), the Ethiopian Constitution’s Article 26 right to privacy, the Ethiopian Computer Crime Proclamation No. 958/2016, the Ethiopian Commercial Code’s financial record-keeping requirements, Article 22 of the UN Convention on the Rights of Persons with Disabilities, and — as international best practice where it sets a higher standard — the EU’s GDPR. Specific grant or funder agreements may impose additional obligations, which take precedence where stricter.
3. Definitions
- Personal data: any information that identifies or could identify a living person — e.g. name, ID number, contact details, disability type, photograph.
- Special category data: data requiring stronger protection — health information, disability status, ethnicity, religion.
- Data subject: the individual whose data is processed (member, beneficiary, donor, staff member, etc.).
- Data controller: TDOU — the organisation that determines how and why personal data is processed.
- Data processor: a third party that processes data on TDOU’s behalf (e.g. an IT provider, survey platform).
- Disaggregated data: aggregate data broken down by characteristics (disability type, gender, age group, region) with all individual identifiers removed.
- Anonymisation: irreversibly removing all identifiers so re-identification is not reasonably possible.
- Data breach: accidental or unlawful loss, disclosure, alteration, or access to personal data.
4. What Data We Collect and Why
TDOU collects personal data only for specific, legitimate purposes, and only to the extent necessary for those purposes. Depending on your relationship with TDOU, this may include: identity and contact details (members, beneficiaries); disability or health information for needs assessment and programme design; assessment and survey data for programme planning; financial and donation details for donors and grant recipients; employment and payroll records for staff and volunteers; event and training attendance for programme monitoring; and contact-form submissions from this website. We do not collect data simply because it might be useful later — using data for a purpose other than the one it was collected for is not permitted without fresh consent or a clear legal basis.
5. Special Category Data — Disability and Health Information
Disability data is central to TDOU’s mission; without it we cannot design effective programmes, produce credible advocacy evidence, or meet donor reporting requirements. Collection is necessary, but must be proportionate and based on explicit consent. In practice this means: disability information is never used to disadvantage the person it concerns; it is stored separately from general identity data wherever feasible; it is shared only where strictly necessary; staff who handle it are trained in sensitive data handling; and all public-facing reports use aggregated, anonymised figures rather than naming individuals. Images or video that show disability-related equipment, or that visually identify a person’s disability, require explicit consent before being captured or used externally.
6. Informed Consent
TDOU relies on informed consent as the primary basis for collecting and using personal data, particularly special category data, with extra care given the vulnerability of the communities we serve. Valid consent is freely given (refusing it carries no penalty), specific to each purpose, informed in plain language, and expressed through a clear affirmative action. Consent forms are available in Tigrinya and Amharic as well as English; where literacy is a barrier, consent is explained verbally and a witness countersigns. Consent to programme participation does not automatically cover photography or media use — that is sought separately, and can be withdrawn at any time without affecting the lawfulness of prior processing. In limited cases TDOU processes data on another legal basis — contractual necessity, legal obligation, or legitimate interest — and will document that basis.
7. How We Use Data
Data is used solely for the purposes described at the time of collection: delivering disability-inclusive programmes and services; monitoring and evaluating outcomes; producing donor and grant reports (using aggregated, anonymised data unless personal data is contractually required); meeting legal and financial compliance obligations; communicating with members, donors, partners and the public; advocacy and policy work using disaggregated statistics only; and publishing programme reports and communications (with consent for any personal stories or images). TDOU does not use personal data for commercial purposes and does not sell or rent it to any party.
8. Data Sharing
TDOU shares personal data only with the data subject’s specific consent, or where there is a legitimate legal or contractual basis, and only to the extent necessary and proportionate. Before sharing, TDOU assesses whether sharing is necessary, whether a less privacy-invasive alternative exists, and whether the receiving organisation has adequate protections. Any third party receiving data from TDOU must sign a written data sharing or data processing agreement specifying the scope of use, security obligations, and a requirement to delete the data once its purpose is fulfilled.
TDOU does not share individual-level disability or health data in external reports (always aggregated); does not share member or beneficiary personal data with donors unless the individual has specifically consented and the grant contract requires it; does not share personal data with commercial third parties for marketing or resale; and will not share data with government authorities unless legally compelled, informing the data subject where legally permissible.
9. Disaggregated Data and Anonymisation
Disaggregated statistics — broken down by disability type, sex, age group, and geographic zone — let TDOU show who is being reached and whether programmes are equitable, without exposing individual identity. Before data is treated as anonymised, TDOU asks whether re-identification is reasonably possible, including in combination with other available datasets; if so, it is not truly anonymised and remains personal data. In small communities where a disability characteristic combined with a location could identify someone, TDOU uses broader geographic groupings or suppresses any group of fewer than five individuals (the “Rule of Five”).
10. Data Retention
TDOU retains personal data only as long as necessary for its purpose, or as required by law; where a specific grant or legal requirement sets a longer period, that takes precedence. As a general guide: member and beneficiary registration records are kept for the active relationship plus 7 years; individual assessment data for the active period plus 5 years (then anonymised); donor records for the active relationship plus 7 years (institutional/grant donor records, 10 years from grant close); financial records for 10 years per the Ethiopian Commercial Code; staff and volunteer personnel files for employment plus 7 years; signed consent forms for the duration of data use plus 3 years; and website contact/enquiry data for 2 years from last contact. Disaggregated programme statistics with no personal data may be retained indefinitely for advocacy and reporting. All disposal is documented — paper records are shredded, and digital files are permanently deleted with confirmation from any external storage provider.
11. Data Security
TDOU implements security measures proportionate to the sensitivity of the data it holds and the organisation’s resources. Access to personal data is limited to staff and volunteers with a specific need to know; staff receive data protection induction and annual refresher training; devices used for TDOU work must be password-protected with screen lock enabled; and paper files containing personal data are kept in a locked cabinet and cross-cut shredded before disposal. Shared drives containing personal data are access-controlled; sensitive files such as assessment and financial data are kept in encrypted or access-restricted folders; passwords must be at least 12 characters and not shared between staff; and external platforms are evaluated before use, with free public-tier services never used to store personal data.
12. Rights of Data Subjects
Consistent with Ethiopia’s Personal Data Protection Proclamation No. 1321/2024 and internationally recognised principles, TDOU recognises and commits to honouring the following rights, exercised by written request to our contact below:
- Access — request a copy of all personal data TDOU holds about you.
- Correction — request that inaccurate or incomplete data be corrected; TDOU responds within 30 days.
- Erasure — request deletion of data once there is no longer a legitimate reason to hold it (this right is not absolute and may be overridden by legal retention obligations).
- Withdraw consent — at any time, without giving a reason; this does not affect the lawfulness of prior processing.
- Object to processing — where processing is based on legitimate interests and your situation warrants it.
- Complain — raise a concern about how TDOU handles your data (see Section 15).
13. Children and Vulnerable Adults
TDOU works with individuals who may include minors and adults with reduced capacity to give informed consent independently. For children under 18, parental or guardian consent is required before collecting personal data, and a child able to understand should also be asked for their own assent; photographs of children require specific written parental consent and may not be used in any media without it. For adults with reduced decision-making capacity, TDOU assumes capacity unless there is clear evidence otherwise; where support is needed to understand consent, a trusted support person is involved, but does not give consent on the individual’s behalf without legal authority to do so, and consent processes are adapted to accessible formats as needed.
14. Digital Channels and Website
What happens specifically when you visit or contact us through tdou.org.et is covered in full in our Privacy Policy. Email correspondence with TDOU may be retained as part of programme, donor, or operational records, and staff are not permitted to share personal data about data subjects over unencrypted email without explicit consent. TDOU’s social media channels are public; please do not send sensitive personal information via social media messaging, and TDOU will not tag individuals in photographs without their consent.
15. Breaches and Incident Response
A data breach occurs when personal data is accidentally or unlawfully lost, destroyed, altered, disclosed, or accessed without authorisation — for example, a lost device containing beneficiary data, a misdirected email, or unauthorised access to TDOU’s systems. Any suspected breach is reported internally within 24 hours of discovery, contained immediately, and assessed for scope and likely harm. Where a breach is likely to pose a risk to the rights or welfare of data subjects, affected individuals are notified without undue delay, and every breach — whether or not notification is required — is recorded and followed by a review of controls. TDOU cannot guarantee a breach will never occur, but commits to responding promptly and transparently, telling affected individuals what happened, what data was involved, and what steps TDOU is taking.
Any data subject who believes TDOU has handled their personal data improperly may contact TDOU in writing at info@tdou.org.et. TDOU will acknowledge complaints within five working days and provide a substantive response within 30 calendar days. If a complaint is not resolved to the data subject’s satisfaction, they may raise the matter with relevant civil society oversight bodies or an applicable regulatory authority.
16. Governance and Accountability
The TDOU Board approves and oversees this policy and is accountable for organisational compliance. The Executive Director ensures day-to-day compliance, escalates significant data matters to the Board, and appoints a Data Protection Lead, who is responsible for operationalising this policy and is the first point of contact for data subject requests and incidents. All staff and volunteers are expected to understand and comply with this policy and to report suspected breaches or concerns immediately. Third-party processors are bound by data processing agreements and must notify TDOU of any breach involving TDOU data without undue delay.
17. Policy Review and Updates
This policy is reviewed at least annually, and also after any significant data breach, a change in TDOU’s operations that affects data collection or sharing, new or amended legislation, or a new funding relationship that introduces additional data handling obligations. Material changes will be communicated to staff and relevant data subjects.
Questions about this policy can be sent to info@tdou.org.et.