AGROFUTURES

Privacy Policy
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GDPR & CSDDD Data Controller Notice

Under Article 5(4) of the Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760), a multi-year (minimum 5-year) audit trail of field labour transactions must be retained. Brand/buyer views display a tokenized identifier in place of the raw National ID. This masking is enforced server-side: the raw National ID and phone number are withheld before the response ever reaches a non-privileged session, satisfying GDPR Data Minimization (Article 5(1)(c)) for that view. Compliance Auditors are granted full access to unmasked records under lawful basis Article 6(1)(c) (compliance with a legal obligation), verified through a real, server-side authenticated login. The role selector is not just a client-side display toggle; switching to Compliance Auditor requires a password checked against the server before any unmasked data is returned. This is currently one shared password for the Auditor role, not individual per-user accounts. Real per-user accounts (with distinguishable per-person audit trails) are a planned future step, not yet built.

Who This Policy Covers

Registered farmers, laborers, and cooperative officers whose data flows through this platform in the course of labour logging, wage payment, grievance reporting, and EUDR/CSDDD compliance documentation.

What Data Is Collected

Data Category Examples
Identity Full name, National ID
Contact Phone number (msisdn)
Employment / Payment Wage records, hours logged, task type, mobile-money payout references
Grievance Reports Report type, description, resolution status (reporter identity is never collected in this field)
Location Plot coordinates, sub-county (for deforestation screening and traceability)

Data Controller / Processor Roles

[PENDING: this characterization has not yet been finalized. Determining whether AgroFutures acts as a data controller, joint controller (alongside each participating cooperative), or processor for each category of data above requires a decision this document does not make on its own. To be confirmed before this section is treated as final.]

Who Data Is Shared With, and Why

Recipient Purpose
EU Brand / Buyer EUDR/CSDDD compliance documentation (Due Diligence Statement)
PawaPay Mobile-money payout processing
Africa's Talking SMS / USSD message delivery
Google Earth Engine Deforestation screening (coordinates only; no name, ID, or phone data is sent)

Data Subject Rights & Contact

Data subjects have the right to access, rectify, and (where applicable) request erasure of their personal data, and to object to certain processing, subject to the retention obligations described above.

[NEEDS: a real contact point / Data Protection Officer email address, not yet provided.]