The GI is comprised of the following entities:

• The Global Initiative Against Transnational Organized Crime, an association established in Geneva, Switzerland under Articles 60-79 of the Swiss Civil Code, [CHE-296 622. 305] with its registered office in Geneva, Avenue de France 23, CH-1202, Switzerland (the “Global Initiative HQ”)
• The Global Initiative – Verein gegen transnationale organisiert Kriminalität, with its place of residence in Vienna, Austria and its main place of activities in Austria and Southeastern Europe, whose registered office is at Schwarzenbergplatz 1/3rd floor, AT-1010 Vienna/ZVR: 102 464 2959 (the “Global Initiative Vienna”); and
• The Global Initiative Against Transnational Organised Crime Cape Town NPC, a non-profit company incorporated under section 13(1) of the South Africa Companies Act, 2008 with its registered office at Community House, 41 Salt River Road, Cape Town 7925, South Africa (the “Global Initiative Capetown”.

In order to make it easy for you to find out more about how we handle information about you, we have divided privacy notice into two sections. The first section sets out the general information that applies to all individuals whose personal data we use, the second section is divided into specific categories of individuals whose personal information we use so that you can find the most relevant information to you.

The GI entity that is the data controller of your personal data depends on the entity with whom you have a relationship, unless you are a visitor to the website in which case no personal information is collected about you. The specific data controller that handles your personal information is listed in the specific sections below. The data controller determines the purpose and means of how your personal information is used. Personal information means information from which an individual could be identified, either directly or indirectly.

1. Your rights under data protection law

In certain circumstances you have the right to:

• Request access to your personal information (often referred to as a ‘data subject access request’), enabling you to receive a copy of the information we hold about you.
• Request correction of any incorrect or incomplete personal information we hold about you.
• Request that we erase your personal information where there is no good reason for us to continue to process it.
• Object to our processing of your personal information where we are using it for our legitimate interests.
• Request that we restrict our processing of your personal information, for example if you wish to determine its accuracy or why we are processing it.
• Ask us to transfer certain personal information we hold about you to another third party service provider, or directly to you.
• If we are relying on your consent to use your personal information, you have the right to withdraw it at any time (we will always provide you with details as to how you can withdraw your consent at the point at which you grant it, and below).
• Complain to your local data protection supervisory authority (The Federal Data Protection and Information Commissioner in Switzerland, and the Datenschutzbehörde in Austria).

 

2. Who do we share your information with?

Your personal information will be shared, if appropriate or necessary, with GI group companies, which are limited to the entities listed at the beginning of this privacy notice.

In addition, the GI may share your personal information with third parties of the following types:

• third party technological services providers such as providers of emails services, cloud storage or survey structuring;
• third party service providers of services including insurance, travel logistics, and payroll functions;
• regulators where required to do so by law.

The GI will only share your information with third parties where it is required by law, necessary to administer the working relationship with you, or we have a legitimate interest to do so. Under no circumstances will we sell or rent this information to any third party.

3. Do we transfer your personal information to other countries when we share it?

Sometimes when we share your personal information with the third parties described above, it may be transferred to countries outside the European Economic Area. We will do our best to make sure that your personal information is stored and transferred in a way which is secure. When transferring personal information out of the EEA we take appropriate steps to protect that information, which include:

• entering into agreements with third parties which include these standard clauses; and
• transferring to third parties that have agreed to comply with schemes approved by the European Commission to protect your information, or in jurisdictions which the European Commission has decided provide adequate protection for your information (Switzerland, where one of the GI entities is based, is a jurisdiction that has been deemed to provide adequate protection in this way).

4. How do we keep your information safe

The security of your Personal Information is extremely important to us, and so we take appropriate technological and organisational steps to keep your personal information safe. The GI also carefully selects all the technology service providers it uses, giving due consideration to the technological security measures which are applied to the information used by them.

Please remember that no method of transmission over the internet or method of electronic storage, is 100% secure. Should you suspect or be concerned about a breach relating to your data, please contact us immediately.

5. Policy Changes

This Privacy Policy was last amended in August 2019, and it may change from time to time where required. Please ensure you check back regularly to keep updated.

6. Contact us

If you have any concerns about how we use your personal information, or would like to exercise any of the rights to which you are entitled, as listed above, please contact our Secretariat at (secretariat@globalinitiative.net).

If your query relates to a specific event, or to the newsletter, please contact Claudio Landi (Claudio.landi@globalinitiative.net).

If your query relates to the GI network, please contact Livia Wagner (livia.wagner@globalinitiative.net).

Part 2

A. If you are a visitor to this website

The GI does not collect any personal information about you other than the information you provide to us if you subscribe to receive the GI newsletter. Please note that you may opt out of receiving the newsletter at any time by contacting Claudio Landi (Claudio.landi@globalinitiative.net).

Although we track website usage in order to measure traffic flows, the information we collect is aggregate and does not make any individual identifiable.

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, in this case to send you the GI newsletter, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. As soon as we do not need your personal information, we will delete it from our systems.

B. If you are in a business relationship with the Global Initiative

If you are a supplier, a contractor, or otherwise in a business relationship with the GI, the data controller of your personal information is the Global Initiative entity with whom you have a business relationship.

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, typically for the duration of your business relationship with us, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. As soon as we do not need your personal information, we will delete it from our systems.

C. If you are attending an event or training organised by the Global Initiative

If you are attending an event or training organised by the GI, the data controller of your personal information is the Global Initiative entity with whom you have been communicating in relation to the event, and that has directly invited you to participate.

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, which will include the period of time through which you are attending events or trainings organised by the Global Initiative, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. As soon as we do not need your personal information, we will delete it from our systems.

D. If you are listed as the emergency contact or next of kin of one of our employees

The data controller of your personal information is the Global Initiative entity with whom the individual that has nominated you as the emergency contact or next of kin is employed.  

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, typically for the duration of the employment of the individual who listed you as next of kin or emergency contact, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. As soon as we do not need your personal information, we will delete it from our systems.

E. If you are an employee

If you are a Global Initiative employee, the data controller of your personal information is the Global Initiative entity listed on your employment contract.

You have been provided with a specific privacy notice by the GI which sets out the information relevant to how the GI uses your personal information. Please refer to it, or request our Secretariat at (secretariat@globalinitiative.net) for a copy.

F. If you are applying for a job with the GI

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, which will include the duration of your employment with us if you are successful in your application, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. If you are not successful, we may keep your personal information for longer than the recruitment period in order to ensure we are able to consider you for future job opportunities. As soon as we do not need your personal information, we will delete it from our systems.

G. If you are a Global Initiative network member

If you are a Global Initiative network member the Global Initiative entity that is the data controller of your personal information are both the GI HQ, and the Vienna GI. When you are being considered for membership of the GI network, we will conduct a desktop review of publicly available information about you as a form of due diligence and a way of safeguarding the reputation of the GI network. In some cases, where such information is on Google or other public search engines, the review may include information relating to criminal allegations, or other sensitive information about you which is relevant to the due diligence process. Prior to conducting this review we will inform you about it, and ask for your consent. The results of this review will only be shared with the Review Committee, composed of a small number of senior GI advisors, Board representatives, and the Secretariat management team, as part of the process for confirming the membership of Network applicants.

If you have any queries or concerns relating to how the GI uses your personal information, or about your membership of the GI network more broadly, please contact Livia Wagner (Livia.Wagner@globalinitiative.net).

Please note that you may opt out of receiving the newsletter at any time by contacting Claudio Landi (Claudio.landi@globalinitiative.net).

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for, which will typically be for the period of time during which you are a GI network member, and for six months after your membership ceases, together with any audit and document retention requirements. These document retention requirements are linked to applicable laws.

If you do not become a Member of the Network but may do so within two years of the original vetting process, your personal information, will be retained for that period of time to enable the GI to assess you for Membership more quickly at a later date. If it is not likely you will become a Member within two years of the original due diligence process, only the minimum personal information required in order to keep a record of your Membership application will be retained.

As soon as we do not need your personal information, we will delete it from our systems.

1. F. If you are nominating an individual or yourself nominated for a prize co-ordinated by the GI-TOC, including through the IASOC

The data controller of your personal information are both the GI HQ, and the Vienna GI.

What personal information do we collect about you?	What purpose do we collect your personal information for?	How lawfully do we use your information?
Your name, professional affiliation, email address and any personal information provided in the nomination letter.	To assess whether to award a prize to the submission.	We use your information to fulfil the GI-TOC’s legitimate interest in considering your nomination for the IASOC Annual Prize, or other competitions co-ordinated by the GI-TOC.

 

How long do we keep your personal information for?

We will only keep your personal information for as long as is necessary to fulfil the purpose we collected it for. In this case, until the selection for the IASOC Annual Prize, or the relevant award or competition is completed, together with any audit and record-keeping requirements. These document retention requirements are linked to applicable laws. As soon as we do not need your personal information, we will delete it from our systems.