HERA France’s Privacy Policy covers our grantees and other program beneficiaries (e.g., trainees), Association officers and members, volunteers, local and international partner organizations, and donors. We apply the same standards of maintaining the privacy and confidentiality of all associated with HERA France’s programs and activities no matter who they are or how they are involved in our programs and operations. To date, we have not had security breaches or shared personal information in our reporting without the individual’s permission. Usually, that permission has been given orally in face-to-face meetings or in email exchanges. Going forward, we will ask that you give us your permission in writing either through hard copy or online.

Here is what the HERA France Association agrees to do:

We collect data on women grantees’ and their ventures prior to the grant, during the field site visit, and during a follow-up visit to evaluate the impact of our grant. Any woman venture or social enterprise owner in our countries of operation (currently Armenia, Georgia, Moldova, and Ukraine) may send an application to hera.grants@gmail.com. Their application is then filed on a google docs drive by year and country. Access to those files is restricted to the Panel Members for that particular year.

The application data include the women’s names, addresses, telephone numbers, Facebook or other social media sites (depending on what they decide to provide), products and/or services, sales and marketing information, any competition for their products or services, requests for specific equipment and/or capital investment, employees (gender and age), reasons for launching the business or social enterprise, and why their request fits with our grant requirements.

During our onsite assessments, we gather further data about business operations, including sales, management structure, employment, and future plans for sustainability or growth. With the grantee’s permission, we also take photos of the venture, the grantee, and any employees (with their permission as well). In the grantees’ own follow-up reporting and during the HERA team follow on assessments, we obtain the same data, including photos and videos which the grantees may send. Permission to use this information in the past has been given orally or online. Going forward, the HERA France Association will ask for all grantees and assessors (volunteers) to sign written permission to use these data in our reporting.

We obtain the grant application data so that seven or more independent, international reviewers each year may evaluate and score each application. Based on summary scores we then rank all applications by country. We send rejections to those applicants who do not score in the second quartile or higher. Nevertheless, we keep the rejected applications in case there is a request for information on why the applicant did not

Companies House Reg. 05401337 UK Registered Charity No: 1115628 HERA France: Association régie par la loi du 1er juillet 1901 – SIRET: 80344762200017

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qualify, and we may also encourage an application in a future year when the grantee has had a chance to develop the venture or social enterprise further.

During the assessment, we compile qualitative in-depth reports on each grantee visited both for the first-time assessment and for follow up evaluation of prior year grantees. These in-depth reports are shared with our donors, who fund the specific grants, and profiles of successful applicants may be shared publicly and online. We obtain the applicants’ permission to share the reports with the relevant donors. To date, this permission has been obtained orally. Going forward, the HERA France Association will request the grantees and assessors/evaluators to provide written permission to use these data for reporting to our donors and for publicizing profiles of successful applicants.

For training activities, we follow the same procedures as for grantees. We hold those data to send information about our new grant competitions and applications. We also compile information on the number and interests of the trainees, trainers, and training topics. These training are offered free-of-charge, so we need this general information to report to our donors and for quarterly and annual reporting on our activities. We also request oral permission for group photos. Going forward, we will ask all participants to tick a box if they are willing to be in these group photos that may be published.

Each year we compile summary statistics on all the data obtained from the current and past years. These summary statistics may include the number of grants by country, amount of funding by country, types of ventures by year and by country, average grant size by year and by country, evaluation outcomes by year, and success ratings by the size of the grant. These data are reported at the population level and no individual identifiers are included. For any photos used in the reporting, we obtain written permission from the grantee and only provide information about the business and country (but not individual identifiers unless requested by the grantee).

We retain the grant application information for current and past years on google docs with restricted access to the teams of reviewers by year. The Panel Members who have access to these files change from year-to-year. Once the reviewer is no longer a member of our panel, they no longer have access to the new files. To date, we have had no security breaches. Going forward, the French Association is designating a Data Protection Manager, who will change the password quarterly so that it will be available only to the Panel Members for the given period. The Data Manager will also encrypt the application files. We will also ask all Panel Members to destroy any application files they may have downloaded once the scoring is completed.

We also keep data on our local NGO, Foundation, Consulting Group, bilateral agency, university and other partners in order to inform them about our annual grant competitions (currently in four countries in which we work – Armenia, Georgia, Moldova, and Ukraine). These data include the name of the organization, key organizers/contacts, and address and telephone number. These names of key organizers and the organizations only are included in our public reports. If they do not wish to be cited in our reporting, we do not include them. We cannot take them out once the report has

Companies House Reg. 05401337 UK Registered Charity No: 1115628 HERA France: Association régie par la loi du 1er juillet 1901 – SIRET: 80344762200017

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been published. However, we request their permission each year before releasing the report to the public. Until now, as indicated, permission has been given orally. In the future, we will ask all partners to provide consent online or in hard copy before including them in the public documents released for that year.

All data are collected for our annual financial and narrative reporting for the Paris Prefecture, UK Companies House, and the England and Wales Charities Commission, country trip assessment and evaluation reports, development of training materials, and for Quarterly Global Giving and other donor reporting. These reports are public and available through our website and other social media. They may be provided to all involved with the HERA program (including our partners), be part of Global Giving Quarterly and other donor reporting; and are public documents available for officials and the general public in the countries in which we work or from which we receive funding (including but not limited to Armenia, Austria, Canada, France, Georgia, Germany, Moldova/Transnistria, Romania, Switzerland, Ukraine, United Kingdom and United States).

Our annual reports are retained online with the UK Charities Commission and Companies House and Paris Prefecture and may be accessed through their websites. We do not provide access to our data files to anyone other than our France Association and Panel Members. We also do not publicize our donors’ names unless explicitly requested and/or contracted in writing. We will continue to observe this practice. The vast majority of our venture owners are pleased to have the publicity and recognition for their ventures and the Association and Panel Members, international and local partners, and volunteers, for their hard work and support for promoting women’s entrepreneurship to prevent dangerous migration and trafficking.

As approved by the HERA France Association on 24 May 2018.