Internal Policy

Use and Protection of Personal Data within the Wheat Initiative

Version: 1.0
Effective date: 19 June 2026
Scope: All bodies, committees, Expert Working Groups and the Secretariat of the Wheat Initiative

1. Purpose of the Policy

This Policy sets out binding rules for the handling of personal data within the Wheat Initiative.
Its purpose is to ensure compliance with applicable data protection law and to prevent the unauthorised disclosure or misuse of personal data, in particular in the context of international cooperation.

2. Scope of Application

This Policy applies to all persons who, in the context of the Wheat Initiative, have access to personal data, including in particular:

  • members of the Board, the Research Committee and the Scientific Board,

  • Chairs and Co-Chairs of committees and Expert Working Groups,

  • members of Expert Working Groups,

  • staff of the Secretariat,

  • other designated representatives of member institutions.

3. Principle of Purpose Limitation

Personal data made available within the framework of the Wheat Initiative may be used exclusively for purposes related to the activities of the Wheat Initiative, including in particular:

  • the organisation, coordination and conduct of committee and Expert Working Group activities,

  • scientific networking and collaboration,

  • internal communication and governance of the Initiative.

Any use of personal data for national, institutional, commercial or other independent purposes is strictly prohibited.

4. Disclosure of Personal Data

4.1 Permitted disclosure

Disclosure of personal data is permitted only if:

  • it takes place within the framework of the Wheat Initiative, and

  • the recipient acts as a member or representative of a member institution within the scope and for the purposes of the Wheat Initiative.

4.2 Prohibited disclosure

In particular, the following is prohibited:

  • disclosure of personal data to third parties outside the Wheat Initiative,

  • incorporation of personal data into national or institutional databases or systems,

  • use of personal data for purposes outside the Wheat Initiative,

  • creation of external mailing lists or contact databases.

5. International Cooperation

The Wheat Initiative is an international research network.
Access to personal data by members or committee participants located outside the European Union may occur in the context of the Initiative.

Such access does not constitute an independent transfer to third parties, provided that the data are used solely for purposes of the Wheat Initiative and remain under the responsibility of the EU-based Managing Institution.

6. Technical and Organisational Measures

To protect personal data and limit access appropriately, the following measures shall apply in particular:

  • access only for designated and authorised persons,

  • role- and function-based access rights,

  • no publicly accessible lists of members or contact details,

  • disclosure on a “need-to-know” basis only,

  • use of communication and collaboration tools provided or approved by the Secretariat.

7. Intermediation Principle

Where external entities or member institutions wish to contact Expert Working Group members, an intermediation approach via the Secretariat should be used wherever possible, rather than the disclosure of complete contact lists.

8. Responsibility and Commitment

All persons with access to personal data are required to comply with this Policy.
Key persons (in particular Board members, Chairs, Co-Chairs and Secretariat staff) shall additionally sign a Personal Data Use Commitment.

9. Entry into Force

This Policy enters into force upon approval by the competent bodies of the Wheat Initiative and applies for the duration of the respective role or involvement in the Initiative.