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.

See our Methodology page for the full procedure.

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.