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Privacy Policy
This policy governs all pages hosted at www.hivjustice.net, academy.hivjustice.net, and www.positivedestinations.info. Please read the following policy to understand how your personal information will be treated. This policy may change from time to time, so please check back periodically. The HIV Justice Network (HJN) is committed to ensure the confidentiality and security of personal data.
What information do we collect?
Personal information is any information that can be used to identify you. HJN collects information such as your name, email address, country and name of your organisation. We collect personal information when you register with us to receive our email newsletters, participate in an event, register for a course in the Academy, filling the ‘Contact Us’ from at Positive Destinations, or make a donation to us. These personal details are used to provide the services or information that you contacted us about.
How do we use your information?
We use your information to help us with understanding more about how our sites are used, to make the sites more useful and to be able to send you relevant communications such as our e-newsletters, or inform you of relevant events happening in your area. We also use this information to help us decide whether there are other information resources we could develop to meet the needs of people visiting the website, and occasionally we may also use your information for administrative purposes, to let you know about changes to our services. In the Academy and at Positive Destinations we use your information to provide support, to improve the services offered, and to be able to report to our Donors and other stakeholders on usage of the services.
We do not share your details with any third parties or organisations, other than to provide direct HJN services, or in the case of the Academy, services provided by our civil society partners. We may use data from the list in the form of aggregated statistics, which do not identify you, for tracking web usage only.
If you have subscribed to the HJN newsletter, we will only send you communications as specified in the registration form.
You are able to unsubscribe from the newsletter at any time via the unsubscribe link on the newsletter itself or by emailing info[at]hivjustice.net .
Accessing and updating your personal information
You can ask us what information we hold about you by contacting us at any time at info[at]hivjustice.net .
You can also ask for your personal details to be removed from our database.
Please keep your information up to date by letting us know of any changes.
(Last updated: 12 November 2024)
Cookies Policy
A cookie is a small text file passed to your computer, mobile phone or other device, through your web browser, so the website remembers who you are when you return. Cookies cannot be used by themselves to identify you..
The HIV Justice Network (HJN) uses Google Analytics to track how our websites are used. Google Analytics uses cookies to help gather statistics on how people use this website. For example, which country the user is from, and which pages you visit while on the website.
We use this information in several ways. For example, we look at how our websites are being used so we can assess how well they are working and to help us make decisions about how to improve them.
We also use this information to help us decide whether there are other information resources we could develop to meet the needs of people visiting our websites.
As a non-profit organisation in receipt of public funds we are also regularly required to account to our funders and donors on how money is being spent, for example, to report on how many people are accessing relevant pages of the website and from which countries.
Google Analytics cookies are only stored for the time of your visit to this website. If you do not wish to receive cookies you can easily modify your web browser to refuse cookies, or to notify you when you receive a new cookie, see how here.
No other user tracking methods are used on this website other than in the Academy, as described above..
(Last updated: 12 November 2024)
Data Protection Policy
1. Introduction
1.1 Purpose of Policy
The HIV Justice Network (HJN) needs to collect and use certain information about individuals in order to provide our services. These include individual users, subscribers, suppliers, employees and other people with whom the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation (GDPR).
1.2 Policy statement
HJN is committed to protecting the rights and privacy of service users, staff and others in accordance with GDPR.
HJN commits to:
- Comply with both the law and good practice;
- Respect individuals’ rights;
- Be open and honest with individuals whose data we hold;
- Provide training and support to staff who handle personal data, so that they can act confidently and consistently.
1.3 Personal data
HJN holds data for the following purposes:
- To provide information and resources to individuals, subscribers and other organisations related to HIV justice;
- To provide information on appropriate events, training, campaigns;
- For staff administration.
2. Responsibilities
The responsible person/s shall take responsibility for:
- The organisation’s ongoing compliance with this policy;
- The annual review of this policy.
3. Data recording, security and storage
3.1 Data accuracy and relevance
HJN will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any other reason unless the individual concerned has agreed to this or would reasonably expect this.
3.2 Data security
HJN will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
3.3 Storing data securely
- In cases when data is stored on printed paper, it will be kept in a secure place where only authorised people can access it.
- Printed data will be shredded when it is no longer needed.
- Data stored on a computer will be password-protected.
- Cloud services used to store personal data will be assessed for compliance with GDPR principles.
- Appropriate back-up and disaster recovery solutions shall be in place.
- Appropriate technical measures will be put into place to keep data secure.
3.4 Data retention
HJN will retain personal data for no longer than is appropriate. Routine audits will review the time that personal data is held.
Any individual or organisation can ask about their information and this can be deleted on request, and we will remove any personally identifiable data. It may not be possible to remove data immediately from archives or backups, however, such data will be put ‘beyond use’ and will not be used for any other purposes.
4. Accountability and transparency
HJN will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all data processing activities that we do and ensure that they comply with each of the GDPR principles.
We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, transparency, and continuously improving security and enhanced privacy procedures.
5. Consent
HJN will ensure that consents are specific, informed and in straightforward language. This is to make sure that individuals understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of data.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to withdraw their consent will be clearly available. We will have systems to ensure such requests are reflected accurately in our systems.
6. Subject access requests
Individuals have the right to access their personal data. HJN will provide an individual with a copy of the information requested free of charge.
This will occur within one month of receipt.
(Last updated: 12 November 2024)
Safeguarding Policy
Purpose
The purpose of this policy is to:
- State the commitment of the HIV Justice Network (HJN) to the safeguarding of young people and vulnerable adults and the prevention of abuse, exploitation, and neglect.
- Set out common values and principles and provide guidance on safeguarding and protection issues and good practice.
- Set out the process for the users of HJN services to report a safeguarding issue.
- Ensure that all HJN representatives know their responsibilities in safeguarding young people and vulnerable adults from harm.
Definitions
In this policy:
- Safeguarding is the process by which we protect all HJN service users and representatives’ health, wellbeing, and human rights, enabling them to live free from harm, paying special attention to young people and vulnerable adults.
- Young people refers to any person under the age of 18.
- Adult means a person aged 18 years or over.
- Vulnerable adult refers to a person aged 18 or over whose agency is limited by one or a combination of factors which include individual aspects, such as: physical or mental disability; health status, such as HIV-positive status; age; emotional fragility or distress; and social positions, including gender, sexual orientation, gender identity, race/ethnicity, origin and religious belief.
A vulnerable adult is subject to unequal power relations, including unequal economic and social disparities, which inhibits their ability to avoid, prevent or expose violence, abuse, neglect or exploitation. Options available to vulnerable adults are often limited by the factors above, and they may be subject to duress or influence. Vulnerability can be context specific and can be temporary or indefinite and should be seen as a continuum which reflects the shifting nature of vulnerability in the context of our work.
- Harm is ill-treatment, including sexual abuse and non-physical forms of ill-treatment (such as bullying or harassment); or the impairment of health (physical or mental) or development (physical, intellectual, emotional, social or behavioural). Neglect or inaction, particularly in the context of a relationship of responsibility or trust, can be forms of harm.
- HIV Justice Network (HJN) is registered as a foundation in the Netherlands under the name Stichting HIV Justice).
- HJN service users – includes all users of HJN services such as the websites, Global HIV Criminalisation Database, newsletter (HIV Justice News), and the HIV Justice Academy.
- HJN representatives:
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- People working for HJN – includes paid employees, consultants, contractors, freelancers, suppliers, and unpaid volunteers.
- People working with HJN – includes anyone working with HJN in a formal capacity (paid or unpaid) such as our HIV Justice Global Consortium Partners and members of the HIV JUSTICE WORLDWIDE Steering Committee.
Safeguarding Policy
Protecting people is a priority for the HIV Justice Network (HJN).
We aim to provide a safe, trusted environment and to respond promptly and appropriately to reports of potential or actual risk of harm.
We do this by:
- Ensuring all HJN representatives are aware of this Safeguarding Policy and how important it is.
- Publishing this policy so that all HJN service users have access to it.
- Publishing a set of Community Guidelines which define the kind of behaviour we deem to be acceptable for users and which apply to all HJN service users who are using the HIV Justice Academy.
- Having documented procedures in place to ensure that concerns of harm are dealt with appropriately and that action is taken promptly.
Advocacy and communications
In our advocacy and communications activities, HJN may at times use text and/or images, video and/or audio recordings of or about individuals.
HJN has a responsibility towards individuals that might be portrayed as vulnerable and should ensure that they are treated with dignity. Any HJN representative must understand the potential for misuse of text, images, video or audio recordings and the possible emotional impact and personal risk of recounting first-person stories. Engaging individuals in such activities must only be done with full and informed consent.
Roles and responsibilities
HJN takes a zero-tolerance approach towards safeguarding breaches, and we take all reports seriously. All HJN representatives have a responsibility to report concerns relating to harm that they are made aware of or that arises in the course of their work.
If an HJN service user has a safeguarding concern, they should report it to complaints[at]hivjustice.net. All concerns will be treated in confidence. An escalation process is defined to ensure fairness, and this includes ensuring that the person reporting an issue is kept informed of progress and the outcome.
The designated lead within HJN is the executive director. However, if the concern is regarding the executive director, then it will be dealt with by the chair of the Supervisory Board.
The executive director, who is employed by the Supervisory Board, holds ultimate accountability for the governance of all safeguarding matters.
(Last updated: 21 September 2022)
Integrity Policy – Corruption, Fraud and Mismanagement
Policy Statement
HJN has zero tolerance for corruption, fraud or mismanagement (CFM) and is committed to preventing CFM from occurring and to developing an anti-fraud and anti-corruption culture. The principles of openness and transparency; confidentiality; capacity building; and accountability are adopted. HJN will identify and promptly investigate any suspected activities of CFM and will take appropriate disciplinary and legal actions.
Definitions
“Corruption” means the offering, giving, soliciting, or acceptance of an inducement or reward that may improperly influence the action of a person or entity. Some examples of corruption include: bribery; conspiracy; extortion.
“Fraud and Mismanagement” means any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. Dishonest or fraudulent activities include, but are not limited to, the following:
- Forgery or alteration of documents
- Misrepresentation of information on documents.
- Misappropriation of funds or assets.
- Improprieties in the handling or reporting of money or financial transactions.
- Authorising or receiving payments for goods not received or services not performed.
- Authorising or receiving payment for hours not worked.
- Inappropriate use of the organisation’s records and disclosing confidential and proprietary information to outside parties.
“HJN representatives” means:
- People working for HJN – includes paid employees, consultants, contractors, freelancers, suppliers, and unpaid volunteers.
- People working with HJN – includes anyone working with HJN in a formal capacity (paid or unpaid) such as our Supervisory Board members, HIV Justice Global Consortium Partners and members of the HIV JUSTICE WORLDWIDE Coalition Steering Committee.
Policy
This policy applies to all HJN representatives.
- We believe in conducting our work ethically, honestly, and in full compliance with all laws and regulations applicable to the respective contexts in which we work.
- HJN representatives are committed to staying accountable and transparent and to upholding HJN’s values and integrity.
- It is the obligation of everyone subject to this Integrity Policy to bring forward any related issues, questions, doubts or concerns to HJN management.
- HJN is committed to ensuring that everyone subject to this Integrity Policy understands: a) the consequences of violating the policy as it applies to them; b) their duty to report all suspicions of corruption thought to be in breach of this policy to HJN as detailed in the Whistleblowing Policy.
HJN aspires towards an atmosphere in which suspicions of CFM can be shared and reported, making sure that such reports are always followed up by careful investigation.
To achieve this, HJN will:
- Develop, maintain and consistently apply effective controls to prevent CFM at all levels;
- Ensure that if CFM occurs, vigorous and prompt investigations takes place;
- Take appropriate disciplinary and legal action in all cases, where justified;
- Take all appropriate and reasonable steps to recover any financial losses;
- Review systems and procedures to prevent similar frauds; and
- Report incidents to donors as required.
Sub-Grantees
It is a requirement that all sub-grantees be aware of and are familiar with CFM policies and procedures that are attached to any funding received. HJN undertakes to make sub-grantees aware of any such conditions that apply.
Sub-grant agreements are subject to grantee acceptance of conditions relating to CFM.
Sub-grantees are supported to be compliant with and adopt, where necessary, policy, procedures (and institute mechanisms) that will create better alignment with donor requirements as to the proper mitigation of the risks and consequences of CFM.
Sub-grantees are expected to:
- Immediately inform HJN when financial or other irregularities occur in their network or organisation or when a suspicion of CFM arises. This should be communicated to the Executive Director (ED).
- Comply with any requests for information, documentation of processes or decisions etc if there is an alert to any suspicion of CFM occurring within a sub-grantee network or organisation.
- HJN, as the lead organisation of the HIV Justice Global Consortium, funded through RCF, is held responsible by RCF for all funds and activities and as such will investigate in a timely manner before taking any decision (through the HJN Supervisory Board) of instituting the process of contacting / alerting the RCF Secretariat if it deems that financial or other irregularities are occurring, or a suspicion of CFM has arisen which deems such action necessary.
- Contact the donor if there is a suspicion of CFM within HJN which cannot be resolved to the satisfaction of the sub-grantee after conversation/representation to the ED and/or Supervisory Board of HJN, as appropriate.
It is acknowledged that a sub-grantee may feel that a representation should go directly to the donor without first contacting HJN’s ED and/or Supervisory Board.
A suspicion or allegation of CFM concerning RCF Funds should be sent to the RCF Secretariat at: Whistleblower(at)robertcarrfund.org
HJN commits itself to investigating or responding to any complaint in a way which respects the confidentiality of any individual whistle-blower (in accordance with the HJN whistle blowing policy), is solution-focused, and obeys and follows the principles of natural justice.
As part of its own due diligence, learning, and capacity-building process, HJN will maintain a ‘register’ (anonymised) of any allegations received, investigations conducted, and resultant actions, that occur as a result of this policy.
HJN Whistleblowing Policy
HJN encourages the raising of concerns about possible corrupt, fraudulent, or unethical behaviour. Such concerns will be treated confidentially and will be properly investigated.
The purpose of the Policy:
This is to allow all organisations, individuals, and other interested parties to bring forward in an appropriate way:
- Concerns, allegations, or information that highlight potential or actual harm being caused by the activities of HJN or its sub-grantees to the communities, organisations, and individuals that we serve; and
- Concerns or evidence that HJN or sub-grantees of HJN-administered funds, are using funds inappropriately.
The areas covered by the ‘Whistleblowing’ Policy, include, but are not limited to:
- Misconduct by HJN representatives, consultants, contractors and/or sub-grantees;
- Theft or diversion of funds or other assets (including embezzlement, theft of assets procured with grant funds);
- Fraud against HJN or its grant recipients (e.g. bribery, kickbacks, inappropriate gratuities, forged signatures, false travel claims, travel with no legitimate purpose)
- HJN or its sub-grantees knowingly communicating false information (including false financial or programmatic reporting and other misrepresentation of information) and inappropriate disclosure of information;
- Unethical conduct (conduct that undermines universal, core ethical values, such as integrity, respect, honesty, appreciation of diversity, sexuality, autonomy of gender choice, responsibility toward those that HJN works with as partners, accountability, and fairness), including issues related to violations of human rights in relation to the activities of HJN or HJN-supported activities.
To lodge a complaint under this Policy the steps to take are:
● Identify that this is the Policy to use:
The complaint is about an issue, activity, or person funded by or representing HJN; we cannot be held responsible for other activities of organisations or individuals when not ‘representing’ HJN and/or not using HJN-administered funds.
● If you feel this is the correct Policy to use:
In the case of the matter concerning a sub-grantee organisation carrying out an activity funded by HJN, or purporting to represent HJN, we would suggest you first look for local resolution with that organisation. Our partner organisations have autonomy regarding how they operate, and we consider that local resolution is always preferable before escalation.
● If you are not able, unwilling, or have exhausted any local resolution:
Your complaint should in first instance be addressed to HJN’s Executive Director, who can be written to at edwin(at)hivjustice.net.
In the case of the matter involving HJN itself, then the complaint should be addressed to complaints(at)hivjustice.net.
In all cases, insofar as it is legally and practically possible, HJN undertakes to keep any information provided confidential – including the name of the complainant.
Upon receipt of your email, HJN undertakes to acknowledge your concerns within 14 days and to suggest a specific way that your complaint will be handled and processed.
Additionally, any whistle-blower is also reminded of the right that they have to go directly to the funding agency supporting the HJN activity or HJN-supported programme about which they are raising the concerns .
As part of its own due diligence, learning, and capacity building process, HJN will maintain a ‘register’ (anonymised) of any allegations received, investigations conducted, and resultant actions, that occur as a result of this policy.
(Last updated: June 2024)