Privacy Policy

1.    General

1.1    The Project Associates Group is made up of different entities, including Project Associates UK Limited. On this basis, a reference to “we”, “us” or “Project Associates” in this privacy notice refers to the Project Associates Group however, if you would like to know which specific Project Associates entity is processing your personal data in accordance with this notice, please contact us. Our contact details can be found in the last section of this notice.

1.2    We take the privacy of your information very seriously and this privacy notice is designed to explain our practices regarding the collection, use and disclosure of personal information we may hold about clients and customers, suppliers, experts, officials, academic researchers, journalists and other third parties. This privacy notice does not apply to information we hold in relation to our staff and contractors which is covered by a separate privacy notice.

1.3    This notice applies to any personal information we hold about individuals (other than staff), whether they are a client or otherwise. In this notice “you” refers to any individual whose personal data we hold or process.

1.4    This notice is governed by the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR (as and when it is implemented into UK data protection law).

1.5    This notice applies to personal data we hold about you. “personal data” means information that relates to you as an identified or identifiable person.

2.    Legal basis on which we process personal data

2.1    Personal data we hold about you will be lawfully processed based on one of the following legal reasons (known as a “legal basis”):

• 2.1.1    Because you have consented to the processing;
  
• 2.1.2    Because the processing is necessary in order for us to comply with our obligations under a contract between you or your employer and us; or
  
• 2.1.3    Because the processing is necessary for a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.

3.    Data which we collect

3.1    We may collect and process the following personal data about you:

• 3.1.1    Contact information which we hold because you are employed or engaged by a client of ours (for instance your email address or contact telephone number);
  
• 3.1.2    Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a supplier, public official, expert, academic or public policy researcher or journalist);
  
• 3.1.3    Records of emails and other correspondence between you and us and our employees;
  
• 3.1.4    Information about your expertise, memberships, areas of interest or publications;
  
• 3.1.5    Biographical and other personal information which you provide to us as part of our services;
  
• 3.1.6    Other public information which is generally available.

3.2    You do not have to supply any personal information to us  and you may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 8) at any time.

4.    Reasons why we process your personal data

4.1    We may use your information to:

• 4.1.1    Contact you in relation to our services if you are a client or are employed or engaged by our client;
  
• 4.1.2    Invite you to events on behalf of our clients or to general events in given areas of interest or concern (which may or may not be hosted by us);
  
• 4.1.3    Engage, provide information and communicate with you, on our own behalf or on behalf of our clients, about:
  (a)    our clients;
  (b)    areas of interest or concern;
  (c)    public and economic policy;
  (d)    other organisations and individuals.
  
• 4.1.4    carry out and administer any obligations arising from any agreements entered into between you (or your employer) and us.

5.    Data Retention

5.1    Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

5.2    For any category of personal data not specifically defined in this Notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.

5.3    The retention periods stated in this Notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

5.4    We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.

5.5    If you wish to request that data we hold about you is amended or deleted, please refer to clause 8 below, which explains your privacy rights.

6.    Sharing your information

6.1    We do not disclose personal information you provide to any third parties other than as follows:

• 6.1.1    As part of the provision of communications services we may disclose information to associates and suppliers, journalists, media organisations, public policy and academic researchers, and other interested parties (although we will not generally disclose personal contact information without your consent);
  
• 6.1.2    If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
  
• 6.1.3    if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  
• 6.1.4    in order to enforce any terms or agreements for our services;
  
• 6.1.5    we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  
• 6.1.6    to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information for the purposes of fraud protection and credit risk reduction.

6.2    Other than as set out above, we will not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

7.    Security

7.1    We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

• 7.1.1    protecting our servers by both hardware and software firewalls;
  
• 7.1.2    locating our data processing storage facilities in secure locations;
  
• 7.1.3    when necessary, disposing of or deleting your data so it is done so securely;
  
• 7.1.4    encrypting email communications in transit;
  
• 7.1.5    regularly backing up all data we hold.

7.2    We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

7.3    This notice and our procedures for handling personal data will be reviewed as necessary.

8.    Your privacy rights

8.1    The GDPR gives you the following rights in respect of personal data we hold about you:

8.2    All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to Project Associates (UK) Limited, FAO Data Protection Manager, 30 Haymarket, St. James’s, London, SW1Y4EX datamanager@projectassociatesltd.com

8.3    We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

9.    Data Breaches

9.1    If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager or officer (if an officer has been appointed).

9.2    If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

10.    Transferring your information outside the UK or EEA

10.1    Our services are international in nature. As part of the services we provide information may be transferred to, processed and stored at, countries or international organisations outside of the UK or European Economic Area (“EEA”).

10.2    We will not transfer any data in a systematic way outside of the UK or EEA but there may be circumstances in which certain personal information is transferred outside of the UK or EEA, in particular:

• 10.2.1    We may communicate with individuals or organisations outside of the UK or EEA in delivering our services- those communications may include personal information (such as contact information);
  
• 10.2.2    We may be required to provide certain personal information as part of a legal reporting obligation to an entity outside the UK or EEA (for example the US Federal Government) and some of that information may be made public;
  
• 10.2.3    From time to time your information may be stored in devices which are used by our staff outside of the UK or EEA (but staff will be subject to our cyber-security policies).

10.3    If we transfer your information outside of the UK or EEA, and (as the case may be) the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and your privacy rights will continue to be enforceable against us as outlined in this notice.

11.    Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following addresses Project Associates (UK) Limited, FAO Data Protection Manager, 30 Haymarket, St. James’s, London, SW1Y4EX datamanager@projectassociatesltd.com.

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.

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