This Privacy Policy explains how the International Sanctions Delisting Commission (“ISDC”) may collect, use, store and protect personal information obtained through this website and through communications submitted to ISDC.
ISDC is an independent non-governmental sanctions review institution. Personal information is handled in connection with the operation of the website, institutional correspondence, case submissions, research and related administrative functions.
Privacy at a Glance
| Area | What may be processed | Why |
|---|---|---|
| Website Use | Technical information such as IP address, browser type, device information and basic usage data | Security, diagnostics and website operation |
| Contact Enquiries | Name, email address, organization and message content | Responding to institutional or general enquiries |
| Case Submissions | Identity, contact details, supporting documents and other information relevant to a proposed review | Assessing whether a matter falls within the scope of ISDC review |
| Evidence Submissions | Documentary material and information concerning a sanctions case | Verification, research and evidentiary assessment |
Information We May Collect
Information You Provide Directly
ISDC may receive personal information when you contact the institution, submit a case, provide evidence, request information or otherwise communicate through the website or designated institutional channels.
Depending on the context, this may include:
- your name and contact details;
- your organization, role or professional affiliation;
- the identity of a person or entity connected with a review request;
- documents, statements or supporting evidence you choose to provide;
- correspondence and information contained in your communications.
Information Generated Through Website Use
When the website is accessed, limited technical information may be generated automatically by the server, hosting environment or security infrastructure.
This may include IP addresses, request logs, browser information, approximate device information, timestamps and records relevant to security or technical diagnostics.
How ISDC Uses Personal Information
Personal information may be used where reasonably necessary for the operation and institutional functions of ISDC.
Institutional Administration
To receive and respond to correspondence, maintain records and operate the website and related institutional systems.
Sanctions Review
To assess proposed review cases, verify evidence, conduct research and evaluate information relevant to an existing sanctions designation.
Security and Integrity
To detect abuse, investigate suspicious activity, maintain technical security and protect the integrity of ISDC systems and submissions.
Publication and Public Record
Where appropriate and lawful, certain information may form part of a published case record, institutional document or research output. Publication is considered separately from mere receipt of information.
Case and Evidence Submissions
Submission to ISDC does not mean that all information provided will be published or incorporated into a public case record.
Case submissions may contain personal, professional, corporate or other information concerning the person making the submission, the subject of the proposed review or third parties.
ISDC may review, organize, verify and retain such information for the purpose of determining whether a case should be considered and, where applicable, for conducting the review itself.
Where information is sensitive, confidential or subject to restrictions, the person submitting it should clearly identify that fact when making the submission.
Public Information and Third-Party Sources
ISDC research may rely on information already available through public sources, including official sanctions records, court materials, public corporate records, government publications, media reports and other research sources.
The fact that information is publicly available does not necessarily mean that it will be republished in full. ISDC may summarize, cite, contextualize or otherwise use public information according to its relevance to a review.
Sharing of Information
ISDC does not sell personal information.
Information may be shared in limited circumstances where reasonably necessary for institutional operations, including with service providers supporting hosting, website security, technical infrastructure or professional services.
Information may also be disclosed where required by applicable law, lawful process or a binding legal obligation.
Publication of Information
ISDC may publish information as part of a sanctions review case, institutional document, research paper or other public material where publication is considered relevant and appropriate.
Where possible, ISDC seeks to distinguish between:
- official public information;
- independently obtained evidence;
- third-party submissions;
- ISDC analysis and conclusions.
Information received privately is not automatically treated as public.
Data Retention
Personal information is retained only for as long as reasonably necessary for the purpose for which it was collected, for institutional recordkeeping, security, legal compliance or the maintenance of a documented review record.
Retention periods may differ depending on whether information relates to a general enquiry, a rejected submission, an active review, a published case or an institutional administrative record.
Security
ISDC seeks to apply reasonable administrative and technical measures to protect information against unauthorized access, loss, misuse, alteration or disclosure.
However, no internet-based system can be guaranteed to be completely secure. Users should therefore avoid transmitting information that is not necessary for the relevant communication or review.
Cookies and Similar Technologies
The website may use limited cookies or similar technologies necessary for technical operation, security, session management or basic website functionality.
If analytics or other non-essential technologies are introduced, this policy may be updated to describe their purpose and operation.
Your Choices and Requests
Depending on the circumstances and applicable law, individuals may be able to request access to, correction of or deletion of personal information held about them.
Such requests may be submitted through the official ISDC contact channel. ISDC may need to verify identity before acting on a request and may retain information where continued retention is reasonably necessary or legally required.
Third-Party Websites
ISDC materials may link to government websites, public registries, courts, research organizations, media sources or other third-party websites.
Those websites operate under their own privacy practices and ISDC is not responsible for their handling of personal information.
Changes to This Policy
This Privacy Policy may be revised where ISDC changes its website, submission processes, technical infrastructure or institutional practices.
The version published on this website represents the current privacy policy applicable to use of the site.
Privacy Enquiries
Questions or requests concerning privacy or the handling of personal information may be submitted through the official ISDC contact page.