Diam Rek – Data Usage Policy

For Wheelchair Provision Activities in West Africa
Including Use of WhatsApp Groups for Communication

Effective Date: 20.11.25
Approved By: Finn Burford

1. Purpose

Diam Rek is committed to protecting the personal information of wheelchair beneficiaries, volunteers, staff, donors, and partners. This policy explains how data is collected, used, stored, shared, and protected, including specific rules for communication via WhatsApp groups.

2. Scope

This policy applies to:

  • All Diam Rek staff, volunteers, contractors, and representatives

  • All communication channels used by Diam Rek (WhatsApp, email, paper forms, etc.)

  • All personal data gathered during wheelchair assessment, distribution, logistics, training, and follow-up support in West Africa

3. Data We Collect

Diam Rek collects only the information necessary to provide wheelchair services safely and effectively.

3.1 Beneficiary Data

  • Name

  • Age

  • Gender

  • Contact details

  • Location/address for delivery or assessment

  • Mobility-/disability-related information needed for wheelchair fitting

  • Photos and videos (only with consent)

3.2 Staff, Volunteer & Partner Data

  • Names

  • Contact information

  • Role within the organization or project

3.3 Operational Data

  • Wheelchair measurements, assessments, and specifications

  • Distribution records

  • Transportation and logistics details

  • Follow-up service notes

4. Use of WhatsApp Groups

WhatsApp groups are used by Diam Rek to coordinate:

  • Fieldwork and team logistics

  • Assessments and wheelchair fittings

  • Transport and distribution operations

  • Reporting and follow-up communication

  • Urgent or time-sensitive updates

4.1 WhatsApp Group Rules

To protect privacy and respect beneficiaries:

  1. Do not share sensitive personal or medical information in group chats.

  2. Share images of beneficiaries only with proper consent and only for operational needs.

  3. Limit personally identifiable information (addresses, full names, phone numbers) to what is strictly required.

  4. Do not forward messages, documents, or photos outside the group without authorization.

  5. Only designated admins may add new members to a WhatsApp group.

  6. All conversations must remain professional and relevant to Diam Rek operations.

5. How Diam Rek Uses Personal Data

Personal data is used solely to:

  • Assess beneficiaries’ needs

  • Provide wheelchairs and related support

  • Coordinate logistics and fieldwork

  • Conduct follow-ups to ensure safety and satisfaction

  • Produce internal reports

  • Share anonymised program data with donors or partners (unless explicit consent allows identifiable information)

Diam Rek does not sell, trade, or misuse personal data.

6. Data Storage and Protection

  • Digital files are stored on secure, password-protected devices and systems.

  • WhatsApp offers end-to-end encryption, but group members must still follow privacy rules.

  • Paper records are stored in locked cabinets or secure offices.

  • Access to personal data is restricted to authorised Diam Rek personnel.

7. Data Sharing

Data may only be shared with:

  • Internal team members who need it for operational reasons

  • Partner organisations assisting in wheelchair provision (minimum necessary data only)

  • Government authorities only when legally required

7.1 Sharing Photos, Stories, and Media

Photos, names, or personal stories can be shared publicly (social media, reports, website, etc.) only with explicit informed consent.

8. Data Retention

  • Beneficiary information is kept for up to 5 years for follow-up and reporting.

  • Assessment photos/videos are kept for 1 year, unless consent allows another use.

  • All data is securely deleted or destroyed once it is no longer needed.

9. Rights of Individuals

Anyone whose data Diam Rek holds has the right to:

  • Ask what data is being stored and how it is used

  • Request corrections to their information

  • Request deletion of their data when permitted by law

  • Withdraw consent for image use or data sharing

Requests can be made through: diamrekorganisation@gmail.com

10. Responsibilities of Staff and Volunteers

All staff and volunteers must:

  • Follow this policy at all times

  • Use WhatsApp responsibly

  • Limit the sharing of personal data to what is necessary

  • Obtain consent before taking or sharing photos/videos

  • Report any data breaches or concerns immediately to management

Non-compliance may result in removal from Diam Rek activities or other corrective actions.

11. Data Breaches

If a data breach occurs, Diam Rek will:

  • Investigate immediately

  • Notify affected individuals when appropriate

  • Take corrective actions to prevent recurrence

12. Policy Review

This policy will be reviewed annually or whenever operational, legal, or technological changes require updates.

13. Email Subscribers and Newsletter Data

Diam Rek collects and manages email subscriber information to share updates about programs, impact stories, fundraising activities, and opportunities for involvement.

13.1 What Data We Collect

For email subscribers, Diam Rek may collect:

  • Name (optional)

  • Email address

  • Country/region (optional)

  • Language preference (optional)

  • Subscription preferences (e.g., newsletters, volunteer news, donation updates)

13.2 How We Use Email Subscriber Data

Email addresses are used for:

  • Sending newsletters and organisational updates

  • Sharing impact stories and beneficiary highlights (with consent)

  • Announcing events, volunteer opportunities, and distribution activities

  • Fundraising appeals or donor-related communication

  • Internal analytics to improve communication

Diam Rek does not sell or trade email addresses to third parties.

13.3 Consent and Opt-In Requirements

  • Subscribers must provide explicit opt-in consent to join the email list.

  • Consent may be collected via website forms, paper sign-up sheets, WhatsApp links, or partner events.

  • Email subscription is never automatic—individuals must choose to join.

13.4 Unsubscribing

Subscribers may unsubscribe at any time by:

  • Clicking the “unsubscribe” link in any email

  • Contacting Diam Rek at diamrekorganisation@gmail.com

  • Requesting removal through a staff member or volunteer

Unsubscribe requests must be honoured within 10 business days.

13.5 Storage and Protection of Email Data

  • Email lists are stored in secure, password-protected email or CRM platforms.

  • Access is limited to authorised Diam Rek communications personnel.

  • Data is encrypted where supported by the chosen email service.

13.6 Use of Third-Party Email Services

Diam Rek may use reputable email marketing platforms (e.g., Mailchimp, Sendinblue, Constant Contact). These services may store data outside the country of operation but must comply with international data protection standards.

Diam Rek ensures that any third-party provider:

  • Maintains strong privacy and security protections

  • Does not use subscriber data for its own purposes

  • Allows subscribers to control their own preferences and opt-out settings

13.7 Retention of Email Subscriber Data

  • Email subscriber data is retained until the individual unsubscribes or their email becomes inactive.

  • Inactive emails are periodically reviewed and may be removed after 24 months of no engagement, depending on platform capabilities.

14. Donor Information and Gift Aid

14.1 Donor Information

When you make a donation to us, including via third-party payment processors such as Stripe, we collect personal information necessary to process your donation. This may include your name, email address, billing address, and transaction details.

We use this information to:

• Process and administer your donation

• Maintain accurate financial records

• Contact you in relation to your donation

• Request and process Gift Aid declarations where applicable

• Comply with our legal and regulatory obligations

14.2 Gift Aid

If you are a UK taxpayer, we may contact you to ask whether you would like to complete a Gift Aid declaration. This allows us to claim an additional 25% on your eligible donation from HMRC at no extra cost to you.

We will only claim Gift Aid where we have received a valid Gift Aid declaration from you.

14.3 Lawful Basis for Processing

We process donor personal data under the following lawful bases:

• Legitimate Interests – to administer donations and communicate with donors about their contributions, including Gift Aid.

• Legal Obligation – to comply with charity law, tax regulations, and financial reporting requirements.

We will not use your personal data for marketing purposes unless you have explicitly opted in to receive such communications.

14.4 Data Retention

We retain donation and Gift Aid records for as long as required by HMRC and charity accounting regulations (currently a minimum of 6 years).

Your Rights

You have the right to:

• Request access to the personal data we hold about you

• Request correction of inaccurate data

• Request erasure where appropriate

• Object to certain types of processing

• Withdraw consent where processing is based on consent

To exercise any of these rights, please contact us at diamrekorganisation@gmail.com.