SASF Data Protection Policy

Purpose

This Data Protection Policy outlines how Swayambam Avam Swabhimaan Foundation (SAS Foundation) collects, uses, stores, and protects personal data in compliance with applicable data protection laws and best practices. The policy ensures the privacy, security, and transparency of personal data handled by the Foundation in the course of its operations.

Scope

This policy applies to:

• All trustees, employees, interns, volunteers, and partners of SAS Foundation.
• All data subjects whose personal data is collected, stored, or processed by SAS Foundation.
• All systems, services, and processes that involve personal data—digital or physical.

Definitions

• Personal Data: Any information relating to an identified or identifiable individual.
• Data Subject: Any individual whose personal data is being collected or processed.
• Processing: Any operation performed on personal data, including collection, storage, use, sharing, or deletion.
• Data Controller: SAS Foundation, which determines the purpose and means of processing personal data.

Legal Basis for Data Processing

SAS Foundation processes personal data based on:

• Consent of the data subject.
• Legitimate interest in delivering programs and services.
• Compliance with legal obligations under Indian law (e.g., Income Tax Act, NGO Darpan).
• Public interest or philanthropic objectives under Section 12A & 80G of the Income Tax Act.

Data Collection

SAS Foundation may collect the following categories of data:

• Personal identification: Name, date of birth, gender, photo ID.
• Contact information: Phone number, address, email.
• Sensitive personal data (only where necessary): Health details, disability status, financial information.
• Usage data: Website or social media interactions, forms submitted, donations, volunteering activity.

Data is collected via:

• Physical or online registration forms.
• Surveys, workshops, webinars, events.
• Website and social media platforms.
• Third-party partnership (with appropriate safeguards).

Data Usage

Data is used for:

• Program registration, impact reporting, and outreach.
• Communication, feedback, and engagement.
• Regulatory compliance, audits, and donor reporting.
• Research, case studies, and awareness campaigns (with anonymity wherever possible).

Data Sharing and Disclosure

SAS Foundation does not sell personal data. Limited data may be shared with:

• Government authorities (when legally required).
• Funding agencies or CSR partners (with non-disclosure clauses).
• Verified third-party service providers (e.g., email platforms, cloud storage), under data protection agreements.

Data Retention

Personal data is retained:

• As long as necessary for program delivery and legal obligations.
• For up to 7 years for financial or regulatory records.
• Data no longer required is securely deleted or anonymized.

Data Security

SAS Foundation ensures:

• Secure storage of physical records in locked cabinets.
• Password-protected access to digital files.
• Regular data backups and access controls.
• Staff awareness and training on data protection.

Rights of Data Subjects

Data subjects have the right to:

• Access their data.
• Request correction or deletion.
• Withdraw consent at any time (where applicable).
• Lodge a complaint with the relevant data protection authority.

Policy Review and Compliance

• This policy will be reviewed annually or as required by law.
• Non-compliance by staff or volunteers may lead to disciplinary action.

Contact Information

For questions or concerns about this policy, contact:

Data Protection Officer (DPO)

RZ-54/5A, Rajnagar Part 2, Palam Colony, New Delhi 110077

contact@sas-foundation.in

+91 9654709935