POPI Act

Introduction

The purpose of the PSET CLOUD Data and Assessment Confidentiality Protocol is to provide a set of guidelines which will ensure the confidentiality of all data, assessments, interviews and information provided by clients or collected or obtained on behalf of clients for all PSET CLOUD Planning, Research, Implementation, Assessment or Monitoring and Evaluation projects. This document must be read in conjunction with PSET CLOUD’s Privacy Policy, as set out on the website www.psetcloud.org.za, and is deemed to be incorporated herein.  Insofar as there may be a conflict between this Data and Assessment Confidentiality Protocol and the Privacy Policy, the Privacy Policy will prevail.  All the terms spelt out in PSET CLOUD’s Privacy Policy are deemed to apply to this Data and Assessment Confidentiality Protocol, even if not mentioned in this Protocol.  

Survey, assessment and interview of participants

All potential participants in a survey, assessment, fieldwork or interview will be informed that their participation is voluntary and that their privacy will be preserved and their responses will be kept confidential. Potential participants must be asked if they are willing to voluntarily participate in the survey or interview or assessment.  If a person indicates that they do not wish to participate, the survey or interview must end immediately.  In the case of children under the age of 12, parental informed consent should be obtained.  

No private, confidential or identifying data or information relating to respondents/participants will be shared outside of PSET CLOUD or the sub-contractor contracted by PSET CLOUD to carry out surveys, assessments, fieldwork or interviews. 

No information collected during a survey, assessment, fieldwork or interview that could in any way identify the respondents/participants will be supplied to the client.  Codes will be used to refer to individual participants, unless written permission has been obtained for them to be named or identified.  All survey data will be anonymised before being handed over to the client.  

Use of data and information provided by clients

All data or information or documents provided by a client will be treated as confidential by PSET CLOUD and it sub-contractors, unless these are already in the public domain or the client specifically gives permission in writing for these to be shared.  The use of any data provided by a client or any of their stakeholders will be limited to undertaking the project that has been contracted.  

Use of data and information for other purposes

Data collected during a survey, assessment or interviews or in confidential documents will not be distributed or used for any other purpose without the prior consent of the client.   

Sub-contractors

Any sub-contractors contracted by PSET CLOUD to work on any project that requires them to receive or collect data/information  will be required to sign a confidentiality agreement  with PSET CLOUD to ensure that any data or information that is  provided  to them  or that they collect will be treated with the strictest confidentiality. 

Data storage, archiving and disposal

Raw data (whether in hard copy or electronic format) is not usually accessible by anyone outside PSET CLOUD’s Data or Assessment Unit, the research team, sub-contractors contracted to carry out surveys or interviews, or data capturers who capture data collected in hard copies.  

Electronic data is stored on PSET CLOUD’s network, with access granted only to members of the Data Unit or Assessment Unit (depending on the data). Members of the research or monitoring and evaluation teams outside of the Data and the Assessment Units, who will be cleaning and analysing the data, will be given access to the relevant data as and when needed. 

Hard copies of research, monitoring or evaluation data will be will be stored in accordance with PSET CLOUD’ agreement with the Document Warehouse, which assures secure storage of data. This data will be destroyed between three and five years after the completion of the project. 

Any survey data or other data or information, survey instruments and meta-data developed during the course of the project will remain on PSET CLOUD’s system and the system of sub-contractors for a period of time to be advised by the client. 

Oversight

Oversight of all processes related to assessment data resides with the Specialist Manager: Assessment.  

Oversight of all processes related to all other data resides with the Specialist Manager: Data and Statistics