Who We Are: The Gulf Centre for Human Rights (GCHR) is an independent, non-profit, non-governmental organisation that was founded in April 2011 by human rights defenders in the Gulf region and neighbouring countries. It receives guidance from an Advisory Board composed of regional and international human rights advocates, including academics and lawyers. GCHR is based in the region.

Where We Work: GCHR is based in Lebanon and documents the environment for human rights defenders in the Gulf region and neighbouring countries, specifically Bahrain, Kuwait, Iran, Iraq, Jordan, Oman, Qatar, Saudi Arabia, Syria, the United Arab Emirates and Yemen.

Mission: The Gulf Centre for Human Rights (GCHR) is an independent, non-profit and non-governmental organisation that provides support and protection to human rights defenders in the Gulf region and neighbouring countries in order to promote human rights, including but not limited to freedom of expression, association and peaceful assembly.

Vision: To have vibrant civic spaces in the Gulf region and neighbouring countries in which human rights are fully respected and human rights defenders, including journalists, bloggers and Internet activists, can work free from oppression and fear.

Core Values:

We believe in:

Justice: We call for fairness in a just society where human rights are respected and impunity for human rights violations is overcome by holding all perpetrators accountable.

Equality: We respect everyone’s right to be treated equally in terms of rights, status and opportunities, regardless of any differences. We are guided by the principles of non-discrimination and gender equality.

Freedom: We believe that everyone should be free from any form of oppression and that voices of people who engage in peaceful protest must not be silenced.

Safety: We aim to establish safe spaces and maintain a secure environment for human rights defenders to ensure well-being, as well as physical and digital security.

Solidarity: We support a culture of trust and exchange among human rights defenders to build a stronger and more collaborative network throughout our region.

GCHR Anti-Bribery and Anti-Corruption Policy

1. Introduction

The Gulf Centre for Human Rights (GCHR) is committed to applying the highest standards of ethical conduct and integrity in its activities throughout the world. Every employee and individual acting on GCHR’s behalf is responsible for maintaining the organisation’s reputation and for conducting the work of the organisation honestly and professionally. GCHR takes a zero-tolerance approach to bribery and corruption, and is committed to acting professionally, fairly and with integrity in all its dealings and relationships. Consistent with this, GCHR’s employees, officers, agents and others acting on GCHR’s behalf may not offer or accept bribes in any form.

2. Definitions

Corruption is commonly defined as the abuse of entrusted power for private gain. Bribery is a form of corruption and means:

• offering, promising, giving, receiving or soliciting money, gifts or anything else of value;

• as an inducement or a reward to a person to perform a relevant function or activity improperly. Bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business or a service, often a public official or employee in the procurement department of a private entity.

3. Purpose and Principles

The purpose of this policy is to ensure that anyone acting on GCHR’s behalf:

• Promote a culture of honesty and openness among GCHR personnel and management.
• Be transparent in all work-related financial transactions.
• Never steal, misuse or misappropriate GCHR funds or property, ensuring that financial and other resources are used solely for the intended purposes.
• Create a work environment where communities and personnel can safely and confidentiality raise and report all serious concerns about suspected fraud and corruption.
• Never support individuals or entities involved in illegal activities.
• Conduct all business in accordance with internationally accepted practices and procedures and uphold the highest standards of accountability and transparency in relation to finances, management and governance, where relevant

4. Exceptional circumstances

Improper payments, gifts or inducements may be justifiable in exceptional circumstances. If a GCHR Staff member is faced with a threat to his/her health or personal safety, or that of another person, if a payment, gift or other inducement is not made, he/she should:

• make the relevant payment or gift or give the inducement without fear of recrimination;

and

• report the incident to the Executive Director as soon as possible.

NOTE: For additional information, please see GCHR’s Procurement Policy, which governs contracts involving items, services (including personal services), supplies, equipment, programs, and real estate (i.e., purchases/sales and leases). It provides guidance on conflict of interest and on gifts, entertainment, hospitality and meals; as well as segregation of duties and supplier agreements.

Data Protection & Privacy Policy

(As of May 2018)

Introduction

The Gulf Centre for Human Rights (GCHR) has always been committed to protecting any private information held by it. In particular, we protect subscribers’ privacy by keeping their email information secure and do not share it with anyone.  GCHR only holds subscribers’ information so they can continue to receive GCHR news updates, reports, announcements, and calls for action. GCHR has recently updated its policy on this subject, after the General Data Protection Regulation (GDPR) came into force on 25 May 2018. 

Definitions

GCHR means Gulf Centre for Human Rights.

GDPR means the General Data Protection Regulation.

Responsible Person means the Executive Director.

 Register of Systems means a register of all systems or contexts in which personal data is processed by the NGO.

1. Data protection principles

GCHR is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes shall not be considered incompatible with the specified, explicit and legitimate purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, updated; every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods only insofar as the personal data will be processed for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that as far as possible ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General Provisions

1. This policy applies to all personal data processed by GCHR.
2. The Responsible Person shall take responsibility for GCHR’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.  

3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, GCHR shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to GCHR shall be dealt with in a timely manner.

4. Lawful purposes

1. All data processed by GCHR must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. GCHR shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in GCHR’s systems.

5. Data minimisation

1. GCHR shall ensure that personal data are adequate relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

1. GCHR shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, GCHR shall put in place an archiving policy for each area in which personal data is processed and review this policy annually.
2. The archiving policy shall take into account which data should/must be retained, for how long, and why.

8. Security

1. GCHR shall ensure as far as possible that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access, and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is as far as possible irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, GCHR shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Data Protection Commission (DPC). (See more information on the DPC website).

Anti-Discrimination, Non-Harassment, and Anti-Retaliation Policy (June 2018) - DRAFT

The Gulf Centre for Human Rights (“GCHR”) is committed to providing an environment free from segregation, discrimination and harassment. GCHR strictly prohibits discrimination or harassment based on a person’s race, colour, gender, age, disability, religion, national origin, sexual orientation, ancestry, pregnancy, marital status, familial status, or any other status protected by law. GCHR also strictly prohibits discrimination or harassment on the basis of an individual’s protected activity, such as opposing prohibited discrimination or participating in the statutory complaint process. In addition, GCHR upholds, as a matter of normal business practice, the freedom from harassment provisions of applicable statutes across Lebanon, Ireland, and of other jurisdictions in which it is present or carries on its activities (“applicable law”).

This policy applies to everyone who works at GCHR (including all board members, employees, volunteers, and consultants working for GCHR, including contract staff). In addition, for purposes of this policy, the workplace includes any place where GCHR conducts its business or activities, or where GCHR functions occur (for example, at the office, in the course of work assignments outside the office, at work-related conferences or training sessions, during work-related travel, and at social functions supervised by GCHR). It is the responsibility of everyone to whom this policy applies to ensure that their behaviour supports a workplace free from discrimination and harassment, to report any known harassment incident or allegation, and to cooperate with the conduct of related investigations.

Harassment and discrimination prohibited by this policy will not be tolerated. Any individual determined to have violated this policy will be subject to appropriate disciplinary or other action, which, in the case of an employee, may include termination of employment.

GCHR wants to create a safe workspace for everyone who works at or with GCHR. As well, GCHR is trying to build a network that includes women human rights defenders and therefore it is particularly important to ensure that all defenders feel comfortable working with GCHR, a primary goal of this policy.

^{_{A. Definition of Harassment.}}

Prohibited harassment under this policy consists of unwelcome verbal or physical conduct or communication either of a sexual nature or based upon an individual’s protected class status that has the purpose or effect of creating an intimidating, hostile, or offensive work environment, which environment unreasonably interferes with an individual’s work performance. Harassment may occur as a result of one incident or a series of incidents. The behaviour does not have to be directed at a specific person for harassment to occur. Behaviour that tends to ridicule or disparage a group may give rise to a harmful work environment and thus to harassment.

One specific form of prohibited harassment is sexual harassment. Sexual harassment includes unwelcome sexual advances, requests for sexual favours, sexually motivated physical contact, or other verbal or physical conduct or communication of a sexual nature when any of the following conditions are present:

1.    Submission to that conduct or communication is made a term or condition, either explicitly or implicitly, of obtaining employment;

2.    Submission to or rejection of that conduct or communication by an individual is used as a factor in decisions is affecting that individual’s employment; or

3.    That conduct or communication has the purpose or effect of substantially interfering with an individual’s employment or creating an intimidating, hostile or offensive work environment.

4.   Finally, it is especially important to be mindful that if you are in a position of power, this may increase the impact of such harassment, and therefore you must take extra care in how you communicate or deal with others.

Sexual harassment can occur in a variety of situations. The following examples may constitute sexual harassment. While the examples listed below illustrate the kind of conduct prohibited by this policy, this list is not exhaustive and doesn’t exclude complaints about other forms of sexual harassment being reported:

1.      Unwelcome verbal conduct, which may include remarks, jokes, or innuendos related to sex or sexual orientation, suggestive comments, or inappropriate inquiries into personal matters;

2.      Unwelcome non-verbal conduct, which may include displaying suggestive objects, pictures, or language that imply offensive behaviours or making suggestive or insulting noises or obscene gestures;

3.      Unwelcome touching, which may include pats, pinches, hugs, or any other non-consensual bodily contact;

4.      Indecent exposure, stalking or sexual assault;

5.      Making sexual or romantic advances toward an individual and persisting despite the individual’s rejection (expressed in any fashion) of the advances;

6.      Refusing to work with people, or to extend work opportunities or other benefits, because of their sex or sexual orientation;

7.      Offering or granting employment benefits or opportunities conditioned on an individual’s submission to sexual advances or sexual favours; or

8.      Harassment not of a sexual nature directed against an individual due to his or her gender, including persistent unwanted attention.

More broadly, examples of racial harassment or harassment based on religious belief may include, but are not limited to:

1.      Comment or conduct which disparages or ridicules a person’s race, ethnic origin, colour, language or religion;

2.      Insulting gestures or jokes which relate to race, ethnic origin, colour, language or religion;

3.      Mimicking a person’s accent, speech or mannerisms;

4.      The display or distribution (including use of electronic media) of derogatory materials which relate to race, ethnic origin, colour, language or religion; or

5.      Refusing to work with people, or to extend work opportunities or other benefits, because of their race, ethnic origin, colour, language or religious background.

Harassment on other grounds may follow similar patterns.

^{_{B. Reporting Discrimination or Harassment.}}

Any individual who feels that she or he has been the victim of discrimination or harassment, or who knows of or suspects the occurrence on discrimination or harassment, is responsible for immediately reporting the incident to the person she or he feels most comfortable contacting, whether the Executive Director, any member of the Advisory Board including the Chairperson, or the Finance Manager, who is responsible for human resources. It is not sufficient to report a complaint of harassment or discrimination to any person other than one of the individuals designated above.

Anyone else connected to GCHR who receives a complaint, and, in the case of a complaint from an individual, must remind the individual of his or her obligation to contact one of the aforementioned people above. Any supervisor or manager who fails to comply with these provisions may be subject to disciplinary action, up to and including termination of employment.

GCHR encourages the reporting of all occurrences of harassment or discrimination under the procedures set forth in this policy, and no retaliatory action will be taken against people making complaints. (See section D below).

GCHR will announce the policy during all events and workshops, both at the beginning of the event and during the evaluation process, so that participants know whom to contact if they have a complaint.

 C.           Investigation and Action.

Upon receipt of a discrimination or harassment complaint, GCHR will investigate and work to resolve all complaints in a confidential, timely, and thorough manner. While complete confidentiality cannot be guaranteed during the course of an investigation, every attempt will be made to use confidential information in a discreet manner. (See section D on No Retaliation below.)

Cooperation with any investigation is required of all employees as part of their job responsibilities. Any employee who fails to cooperate in an investigation may be subject to disciplinary action, up to and including termination of employment.

If the investigation of a reported or suspected occurrence of discrimination or harassment reveals that an individual has not engaged in any form of discrimination or harassment, management will inform both the individual and the complaining party (if their identity is known) that an investigation has been conducted and that no evidence supports the report or suspicion.

In the event an investigation reveals evidence that discrimination or harassment has occurred, management will take whatever steps it deems necessary and appropriate to prohibit further acts of discrimination or harassment, up to and including terminating the employment of an offending employee. These steps will be determined on a case by case basis commensurate with the situation, and with the requested level of anonymity. GCHR may also seek legal redress, including attorneys’ fees and costs, against any employee or other person who causes GCHR to incur any expense or liability as a result of prohibited behaviour.

Disciplinary action, up to and including termination of employment, may also be taken against any employee who witnesses discrimination or harassment and does not report it as described above, including any manager who fails to report a complaint of discrimination or harassment or who fails to take corrective action after being informed of a hostile work environment or other incident involving harassment.

D.           No Retaliation.

GCHR is committed to maintaining an environment in which individuals feel free to report all incidents of harassment or discrimination. GCHR encourages the reporting of all occurrences of harassment or discrimination under the procedures set forth in this policy. No retaliatory action will be taken against any person who in good faith reports conduct which he or she believes may violate this policy. Similarly, no retaliatory action will be taken against any individual who in good faith assists or participates in an investigation, proceeding, or hearing relating to a harassment or discrimination complaint. Any person who violates these provisions may be subject to discipline, up to and including termination of employment.

While a complaint is pending, the person about whom the complaint has been made shall not participate in any formal or informal evaluations of the person who has made the complaint. Any attempt to do so constitutes a separate violation of this policy that may result in discipline, up to and including termination of employment.

E.           Consenting Sexual or Romantic Relationships.

GCHR discourages consenting sexual or romantic relationships between employees when there is any direct or indirect reporting relationship between them. Any employee acting in a supervisory capacity who enters into such a relationship with a subordinate employee must promptly inform the Executive Director or Financial Manager of such relationship. Any employee acting in a supervisory capacity who fails to notify the Executive Director or Financial Manager may be subject to disciplinary action, up to and including termination of employment. GCHR is fully committed to complying with all applicable law protecting employees from discrimination based on marital and other protected relationship status, and this policy is in no way intended to interfere with, nor shall it be applied in violation of, such protections.    

We work with:

Integrity: We are adamant about being credible and trustworthy. We are bound by impact-oriented processes and the highest ethical standards.

Independence: We do not take funds from governments in the countries in which we work, or any party that may compromise our values.

Cooperation: We cooperate with all local, regional and international partners through networking and complementary efforts to promote and protect human rights for all.

GCHR’s Overall Objectives:

1. To provide protection for human rights defenders and enhance their effectiveness in the Gulf and neighbouring countries.
2. To raise awareness locally, regionally and internationally about issues pertaining to human rights defenders at risk.
3. To enable a safer environment for human rights defenders at risk, through advocacy at regional fora and via international mechanisms.
4. To facilitate networking and exchanges between human rights defenders and social movements.

Staff:

Khalid Ibrahim, Executive Director and co-Founder 

Sabah Faour, Financial Manager

Hilary Daly, Human Rights Researcher

Lisa O’Higgins, Human Rights Researcher

Note: Other staff remain anonymous for their security.

Founding Directors:

Abdulhadi Al-Khawaja

Nabeel Rajab

Advisory Board:

Dr. Hala Al-Dosari

Joshua Colangelo-Bryan

Brian Dooley

Melanie Gingell

Ahmed Mansoor

Jalila Al-Sayed

Dr. Khouloud Al-Khatib, Chair

Joe Stork

Radhya Al-Mutawakel

Emadeddin Baghi

Habiba Al-Hinai

Donors:

GCHR is funded by Open Society Foundation, Sigrid Rausing Trust, the Global Fund for Women and International Media Support, among other donors. We do not accept funds from any governments in the countries in which we work.

Memberships:

GCHR is a member of:
CIVICUS
FIDH
IFEX
Women Human Rights Defenders (WHRDs) International Coalition

Gulf Centre for Human Rights has Special Consultative Status with the Economic and Social Council of the United Nations.