Privacy Policy
Last updated: March 2026
Data Controller
Georgian Accountability Project (CIC)
Registration number to be added upon completion
United Kingdom
Contact: [email protected]
Legal Basis for Processing
We process personal data of public officials and public figures under GDPR Article 6(1)(f) — legitimate interest. Our legitimate interest is public accountability and the documentation of threats to democratic governance, which serves the public interest.
What Data We Process
Public figures and officials (profiled individuals):
- Full name and title
- Current and former public positions
- Documented public actions relevant to democratic accountability
- Accountability score (analytical assessment)
- Publicly available photographs
Victims and witnesses:
- Processed ONLY with explicit consent
- Anonymized by default (pseudonyms used unless consent given)
- Contact information never published; accessible only to supervisory staff
Website visitors:
- Minimal analytics data (if applicable)
- No tracking cookies without consent
Data Subject Rights
Under UK GDPR, profiled individuals have the right to:
- Access their data
- Request correction of inaccuracies
- Request erasure (subject to our legitimate interest assessment)
- Object to processing
- Lodge a complaint with the UK Information Commissioner's Office (ICO)
To exercise these rights, contact: [email protected]
We will respond within 30 calendar days.
Right of Reply
Profiled individuals or their legal representatives may submit a response to their profile.
Data Retention
Profiles and incident records are retained as long as they serve the public accountability purpose. Victim data is deleted upon request at any time.
International Transfers
Data may be accessed from outside the UK. We apply appropriate safeguards in accordance with UK GDPR.
Changes to This Policy
We may update this policy. Changes will be posted on this page with an updated date.