Quality Assurance and Data Protection Policy

1. Purpose and scope

Axiom Santé's clients take decisions based on its data and analysis; respondents entrust it with their information. Both must be able to trust it. This policy addresses both requirements: Part A (sections 2 to 4) covers quality assurance and Part B (sections 5 to 10) covers data protection.

It applies to all Axiom Santé assignments and to everyone who contributes to them: permanent staff, associate experts, enumerators, supervisors and subcontractors. It complements the research and evaluation ethics policy. Where it differs from the terms of a contract, the more protective provision applies.

2. Quality principles

• Rigour: methods suited to the questions asked, stated explicitly and justified.
• Transparency: sources, assumptions, limitations and deviations from the protocol are documented in deliverables.
• Reproducibility: every quantitative result can be traced back to the data and the analysis code.
• Independence: findings reflect the evidence, including when they are unfavourable to the client or a partner.
• Usefulness: readable deliverables, submitted on time, with realistic and prioritised recommendations.
• Continuous improvement: every assignment ends with a lessons-learned review.

3. Quality at every stage of an assignment

1. Inception. Every evaluation or study begins with an inception report containing an evaluation matrix that links each question to judgement criteria, indicators, sources and methods. The report is validated by the client before data collection starts.
2. Tool design and pre-testing. Questionnaires and guides are translated into the required local languages, back-translated for sensitive concepts and pre-tested with a comparable population. Digital forms include consistency checks, value ranges and automatic skip patterns.
3. Enumerator training and certification. Enumerators are trained on the study objectives, ethics, consent, data protection and practical exercises. Only those who pass the final assessment (written test and observed interview) are deployed.
4. Real-time data quality checks. During data collection, Axiom Santé applies:
   • daily high-frequency checks for duplicates, missing or outlying values, interview duration and productivity per enumerator;
   • back-checks on a random sample of interviews, in person or by telephone, using a short questionnaire on stable variables;
   • GPS and timestamp audits to verify the location, date and duration of each interview.
   Anomalies are recorded in a log and resolved with the enumerator concerned; where necessary, interviews are repeated or an enumerator is withdrawn.
5. Reproducible analysis. Cleaning and analysis are carried out using commented scripts (for example in R, Stata or Python) kept under version control. Raw data are never altered: every transformation is recorded in the code.
6. Peer review. Every major deliverable (inception report, draft report and final report) is reviewed before submission by a senior expert who was not involved in producing it. The reviewer's comments and the team's responses are recorded.
7. Client feedback and corrective action. Client comments are addressed in a response matrix showing how each one has been handled. At closure, feedback on client satisfaction is requested; any shortcomings identified lead to corrective actions monitored by Management.

4. Evaluation standards and team composition

Axiom Santé's evaluations draw on the OECD Development Assistance Committee criteria (relevance, coherence, effectiveness, efficiency, impact and sustainability) as revised in 2019, and on the DAC Quality Standards for Development Evaluation (2010). They comply with the United Nations Evaluation Group (UNEG) Norms and Standards for Evaluation (2016), in particular as regards independence, impartiality, credibility and utility.

Quality also depends on people. Before any proposal or assignment, Axiom Santé verifies the CVs of the experts proposed: qualifications, stated experience (by contacting referees) and actual availability. It includes no expert without their written agreement and replaces a key expert only with the client's agreement, by a profile of at least equivalent standing. Each expert declares any conflict of interest in accordance with the anti-corruption policy.

5. Data protection principles

Axiom Santé processes personal data in line with internationally recognised standards, in particular the Personal Data Protection and Privacy Principles adopted by the United Nations system in 2018, and with applicable Congolese law, notably Ordinance-Law No. 23/010 of 13 March 2023 establishing the Digital Code (Code du numérique), which contains provisions on the protection of personal data. Where an assignment takes place in another country, that country's law and the client's rules also apply.

• Lawfulness and fairness: every processing operation has a legitimate basis, most often informed consent or the contract with the client.
• Purpose limitation: data are used only for the stated purposes.
• Data minimisation: only the data needed are collected; direct identifiers are avoided where they are not essential.
• Accuracy: data are checked and corrected in accordance with the procedures in section 3.
• Storage limitation: data are not kept longer than necessary (section 8).
• Security: technical and organisational measures protect data against loss, unauthorised access and disclosure (section 7).
• Accountability: Axiom Santé documents its processing and can demonstrate compliance with these principles.

6. Informed consent and information

Before any data collection, each respondent receives clear information, in a language they understand, on: the purpose of the study and who commissioned it; the nature of the questions; the voluntary nature of participation and the right to refuse or stop without consequence; how data will be used and stored; the confidentiality measures; and how to contact Axiom Santé. Consent is obtained in writing or recorded in the digital form. For minors, the child's assent is required in addition to the consent of a parent or guardian. Photographs, audio recordings and household GPS coordinates are specifically mentioned. Where a protocol requires ethics committee approval, no data collection begins until that approval has been obtained.

7. Pseudonymisation, anonymisation and security

As soon as data collection ends, direct identifiers (names, telephone numbers, precise addresses) are separated from responses and replaced with a code. The key linking codes to identities is stored separately, with restricted access. Any dataset shared with a third party or published is anonymised: direct identifiers are removed, GPS coordinates are aggregated or displaced, and combinations of variables that could re-identify a person in small populations are checked.

Security measures are proportionate to the size of the firm and the sensitivity of the data:

• encrypted, passcode-protected computers, telephones and data collection tablets; encrypted collection forms; data deleted from tablets after verified transfer;
• strong, unique passwords and two-factor authentication on all work accounts;
• access granted on a need-to-know basis and withdrawn at the end of the assignment;
• storage in an encrypted professional cloud environment, never on an unencrypted USB stick or drive;
• no personal data sent through personal email or entered into public artificial intelligence tools;
• transfer only via a secure, access-controlled link or as an encrypted file, with the password sent through a separate channel.

8. Retention, ownership and sharing

Ownership. Unless the contract provides otherwise, data collected during an assignment belong to the client. Axiom Santé makes no other use of them, including for publications, without the client's written agreement.

Retention and destruction. The retention period is the one set in the contract. Failing that, data containing personal information are returned to the client or securely destroyed no later than twelve months after acceptance of the final report, with a certificate provided on request. Identification keys are destroyed first. Deliverables and administrative and financial records are archived for the period required by the contract or by law.

Sharing. No assignment data are disclosed to a third party without the client's authorisation. Any subcontractor or expert with access to personal data is bound by a confidentiality clause and by this policy.

9. Data breaches

A data breach is any actual or suspected loss, disclosure, alteration of or unauthorised access to data (for example a stolen tablet or a file sent to the wrong recipient). Anyone who becomes aware of one alerts Management immediately. Management:

1. contains the incident (blocking accounts, remote wiping, revoking links);
2. assesses the data affected and the risk to individuals;
3. notifies the client within 72 hours of becoming aware of the breach, and the competent authority where the law so requires;
4. informs the individuals concerned where the risk is high, in agreement with the client;
5. records the incident, its causes and the measures taken in a breach register.

10. Rights of data subjects

Anyone whose data Axiom Santé processes may request access to, rectification of or deletion of those data by writing to info@axiomsante.org. Axiom Santé responds within one month. Where the data belong to a client, the request is handled in consultation with that client. Deletion may be impossible once data have been anonymised, since the person can no longer be identified.

11. Responsibilities and review

• Management is responsible for applying this policy, designates a quality and data lead for each assignment, organises peer review, keeps the breach register and approves any exception.
• The assignment lead implements the quality assurance plan, controls access and ensures that data are retained and destroyed as required.
• Every contributor signs this policy before their assignment, complies with it and reports any incident.

Any breach of this policy may lead to disciplinary measures or the end of the working relationship. The policy is reviewed annually by Management, and sooner if regulations or client requirements change.

12. Reporting and contact

Questions, requests to exercise data rights and reports of breaches of this policy should be sent to info@axiomsante.org. For a report, use the subject line "CONFIDENTIEL : Signalement": the message is handled by Management only, and anonymity is possible. See also the PSEA policy.