PURPOSE
The purpose of this policy is to establish standards for the collection and use of Contributors' stories within the IRCT. The policy aims primarily to ensure the privacy, security and dignity of those affected by torture in the use of their stories and images and to minimize ethical and legal risks associated with the collection of Personal Information.
This policy uses the following key definitions:
 Personal Information: Any information or opinion, recorded in any form, about a person whose identity is apparent or can be ascertained from the information and which is collected for the purpose of IRCT communication. This excludes publicly available information not subject to a property right.
 Particularly Sensitive Information: Secondary information obtained about a contributor which is not customarily public knowledge and which, if disclosed, may place the contributor at risk of severe harassment, discrimination, or serious physical or psychological harm. Whether a given piece of information is considered particularly sensitive will depend in large part on the specific context, but examples of such information may include HIV/AIDS status, abortion, sexual orientation or political affiliation.
 Contributor/Participant: Any individual or group of individuals from whom the IRCT receives Personal Information. Contributor and Participant are used interchangeably throughout this policy.
A.
COLLECTION OF PERSONAL INFORMATION FROM CONTRIBUTORS
The following requirements apply to all situations where IRCT collects images, stories, film, or other similar information directly from Contributors.
A.1
Training
The Communications Unit, in consultation with the IRCT medical staff, will provide support and training to designated IRCT staff members in the collection of personal information from contributors. Only designated staff members who have completed this training are authorized to collect testimonies directly from contributors.
A.2
Inform
The IRCT will fully inform Contributors of the anticipated uses of their Personal Information in a manner that ensures that the Contributor understands the nature and extent of any consent given. Staff may produce a sample of publicity material to aid in explaining the uses of the Personal Information.
A.2.1
Vulnerable populations
Members of vulnerable groups such as detainees and women in various contexts may be at additional risk of exposure to harassment, discrimination, or other negative consequences if their identity were revealed. It is particularly important that the IRCT ensure that members

of vulnerable populations understand to what extent their story, image, or other Personal
Information may be made public.
A.2.2
Withdrawal of Consent
The IRCT must also inform Contributors that their consent may be modified or withdrawn at any time and for any reason by notifying the IRCT. In the event of consent withdrawal or modification, the IRCT will take all reasonable steps to respect the wishes of the Contributor.
The IRCT will immediately discontinue use of withdrawn Personal Information and remove any such information from the website or other materials within the control of the IRCT. If the withdrawn Personal Information has been released to any third party organisations, the
IRCT will notify the organisation(s) and request discontinuance and removal of any withdrawn Personal Information from the organisation's website or other materials. It will be made clear, however, that an effective withdrawal of information already in the public domain may not be possible.
A.3
Obtain Consent
Contributors must give consent for the IRCT to use their story, image, audio, or visual recording. It is recommended that Contributors sign a written release documenting their understanding of and consent to IRCT's use of the specified Personal Information. Where necessary, contents of the consent form should be read aloud to Participants or translated orally into Participants' language. If the Contributor cannot sign his/her name, a mark or fingerprint may be substituted in the signature section of the release form.
A.3.1
Verbal Consent Exceptions
If a Contributor understands and verbally consents to IRCT's use of specified Personal
Information but for practical reasons cannot or will not sign the consent form, this fact may be documented separately with a brief explanation of the situation signed and dated by the
IRCT representative. This may apply in contexts where the use of the consent form is not practical – for example if the Contributor is illiterate - but the Contributor understands and consents to the release of Personal Information.
A.3.2
Particularly Sensitive Information
Participants must specifically give consent for the IRCT to make Particularly Sensitive
Information public. Consent to disclose Particularly Sensitive Information should be documented in the consent form.
A.3.3
Minors
As a policy the IRCT will not collect contributions from minors under the age of 18.
A.3.4
Use by third parties/partners
A written release is required for a Contributor's Personal Information to be used by a third party. If a Contributor's story is to be used by an IRCT partner or third party organisation, the IRCT representative will seek additional consent and signature from the Contributor in the 'Third Party Release' section of the consent form.
A.4
Consideration
At the time consent is obtained, the IRCT will provide Participants with a copy of the signed consent form and a Certificate of Appreciation as a show of thanks for the use of his/her story or other Personal Information in promoting the mission of IRCT.

A.5
Record Keeping
Documents containing identifiable information, including consent and release forms, unredacted versions of stories collected, and other Personal Information will be stored in a secure location according to IRCT's Confidentiality/Privacy Policy.
B.
COLLECTION FROM OTHER ORGANISATIONS
The following requirements apply when the IRCT receives Contributors' stories from another organisation.
B.1
Verification of Information
The IRCT will verify that the Contributor has been adequately informed that the released
Personal Information may be used in promotional materials, web content, international advocacy and awareness raising campaigns, or other public formats.
B.1.1
Anonymity
The IRCT representative will inquire into the level of anonymity discussed and requested by the Contributor. Where anonymity is not specified or unclear, all identifying information will be removed before reproducing materials.
B.2
Verification of Consent
The IRCT will verify that the Contributor has consented to use of the Personal Information by third parties. General consent to the initial organisation for use of the Personal Information is not sufficient to transfer use to the IRCT. The Participant’s consent must specifically extend to the use and transfer of Personal Information to third parties in general or to the
IRCT in particular. This is especially important where use by the IRCT may mean significantly broader or more international exposure than would otherwise be expected. The
IRCT representative will verify consent with an organisation in one of the following manners.
B.2.1
Written Original Consent
Where original consent is written, the IRCT will obtain a copy of the original consent with signature. Subsequent uses of Contributor's Personal Information will be limited to those uses indicated in the consent form. For uses beyond those permitted by the original consent, the IRCT will obtain additional consent from the Contributor.
B.2.2
Verbal Original Consent
Where original consent is verbal, the intermediary organisation must sign 'Verification of
Verbal Consent for Release of Personal Information form indicating the information given and nature of consent granted by the Contributor. This will guide subsequent uses of the
Personal Information by the IRCT.
B.2.3
No/Insufficient Consent
If the Contributor has not given consent or consent is insufficient to permit IRCT to use the information, the required consent must be obtained before proceeding to use the Personal
Information. Where the Contributor is identifiable and traceable, the IRCT will contact him/her directly or through the intermediary organisation, explain the use and purpose of the Personal Information, and request retrospective consent for use of the information. The requirements outlined in Section A of this policy on 'Collection From Contributors will apply when requesting retrospective consent for the use of information. Failure to secure a consent or release will render the specific information unusable by the IRCT.

B.2.4
Sensitive Information
An IRCT representative will identify Particularly Sensitive Information and inquire into specific consent to reveal any such information. If no specific consent is available,
Particularly Sensitive Information will be evaluated by the respective IRCT Secretariat staff member in light of the level of anonymity requested and the nature of the information, and a determination will be made by IRCT Secretariat Management as to whether inclusion of the information exposes the Contributor to unnecessary risks of physical or psychological harm.
B.3
Consideration
IRCT member centers and intermediary organisations with whom the IRCT works regularly will receive copies of the Certificate of Appreciation to distribute to Participants.
C.
ANONYMIZATION OF INFORMATION
While the IRCT recognizes that testimonies are an essential element in communicating the
IRCT mission and objectives, our primary concern is the physical, emotional, and psychological well-being of contributors. To ensure that we have taken all possible measures to protect contributors from the potentially harmful consequences of giving testimony, all contributors' Personal Information will be additionally evaluated under the following criteria to determine whether the information will be anonymized prior to publication. Please note that this evaluation will be undertaken in addition to any requirements contained in previous sections of this policy.
1.
Will public exposure subject the contributor to increased security and safety risks?
This assessment may take into account the following: a.
Does the testimony contain any Particularly Sensitive Information b.
Does the contributor continue to live or work in the context giving rise to the personal testimony i.
Has the contributor permanently relocated ii.
Has the social or political environment changed in such as way as to significantly diminish the risk of retaliation? c.
Has the person(s) responsible for the acts giving rise to the personal testimony been prosecuted or otherwise brought to justice.
2.
Will public exposure subject the contributor to additional emotional or psychological harm. This assessment may take into account the following: a.
Has the contributor received or is the contributor currently receiving counselling or treatment related to the incidents giving rise to the personal testimony? b.
Does the contributor have access to psychological support structures (i.e. rehabilitation centres, community centres, family support systems)? c.
How long ago did the incident giving rise to the personal testimony take place?
3.
Does publication of the story reflect the interest and will of the contributor. This assessment may take into account the following: a.
Has the contributor indicated a desire to publicize the testimony independent of a request from the IRCT

i.
Did the victim approached the IRCT or vice-versa ii.
Has the victim already publicized the story in a national or international media context b.
Are there any concerns that the contributor may have been vulnerable to coercion or undue influence to provide testimony or consent to its publication i.
Did the contributor have a need or expectation of treatment from the organization requesting the testimony or consent to its publication? ii.
Were any incentives offered for contribution likely to unduly influence a contributor's decision to provide testimony or consent to its publication?
If publication of Personal Information raises serious concern as to any one of the above assessment criteria, the IRCT will anonymize a personal testimony prior to publication.
The IRCT may decline to publish a personal testimony in its entirety where, based on the above assessment criteria, publication of the story may not be in the best interests of the contributor.
1.
Anonymization Approvals
Prior to publication of Personal Information, the IRCT employee responsible for collecting the information shall evaluate it under the anonymization criteria in this section and present a recommendation to the Head of Communications and a member of the IRCT medical team for express approval. Where there is no consensus can be reached between approving staff, the testimony will be anonymized.

Personal Information Consent Form
This Consent Form is for the Following Personal Information:
(Initial next to each item for which permission to use is being given)
______Story ______Image/Visual likeness
______Name ______Voice/Audio
______Sensitive Information (Please list information) ___________________________________
_______________________________________________________________________________
Please indicate below if there is specific information you would like the IRCT to exclude from future publications, promotional materials, web content, and other IRCT materials.
_______________________________________________________________________________
_______________________________________________________________________________
I give my consent and authorize the IRCT to use, adapt, and reproduce all or part of my Personal Information indicated above in a manner consistent with the mission of the IRCT. This includes, but is not limited to, use in promotional materials, fundraising materials, web content, advocacy and awareness raising campaigns, and publications.
I understand and accept the risks of public disclosure of the above information
I understand that I may withdraw my consent at any time in the future and for any reason without consequence, however it may not be possible to effectively withdraw information already released into the public domain.
I understand that any consent granted on this date to use and disclose the above information remains in effect indefinitely unless and until withdrawn.
By signing below, I confirm that I have read this Consent form, or someone has read this Consent form to me, and I understand its terms. Any questions I have related to this consent have been answered to my satisfaction.
Printed Name: ______________________ Signature: ______________________ Date: _______
Signature of parent or guardian (if under age 18): __________________________Date: _______
THIRD PARTY RELEASE
I give my consent and authorize the IRCT to permit third parties to use, adapt, and reproduce my Personal
Information in a manner consistent with the mission of the IRCT and on terms identical to those outlined above for the IRCT.
Printed Name: ______________________ Signature: ______________________ Date: _______
Signature of parent or guardian (if under age 18): __________________________Date: _______

Organisation Name: _____________________________________________________________
Organisational Representative: ___________________Survivor Name: ____________________
(Initial next to each item for which permission to use has been given)
______Story ______Image/Visual likeness
______Name ______Voice/Audio
______Sensitive Information (Please list information) __________________________________
______________________________________________________________________________
Please indicate below if there is specific information the contributor would like the IRCT to exclude from future publications, promotional materials, web content, and other IRCT materials.
______________________________________________________________________________
______________________________________________________________________________
I confirm that I have fully informed ___________________________________________
[Insert Name of Contributing Torture Survivor] of the purpose and use of his/her Personal Information by the IRCT or a third party organisation and the associated risks and he/she has verbally consented to the use, reproduction, and adaptation of the indicated
Personal Information in promotional materials, fundraising materials, web content, advocacy and awareness raising campaigns, publications, and other materials.
Signature of Representative: _____________________________ Date: ____________________