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PRIVACY POLICY

  1. General
    1. Project Associates UK Limited trading as Project Associates (“we”, “us” or “Project Associates”) take the privacy of your information very seriously.
    2. 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, lawyers, 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.
    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.
    4. This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.
    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
    1. Personal data we hold about you will be lawfully processed based on one of the following legal reasons (known as a “legal basis”):
      1. 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.
      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
      3. Because you have consented to the processing.
  3. Personal data which we collect
    1. We may collect and process the following personal data about you:
      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) (“Client Contact Information”)
      2. Biographical and other personal information which you provide to us as a client or in your capacity as an employee of our client, as part of our services (“Biographical Information”);
      3. 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, lawyer, academic or public policy researcher or journalist) (“Third Party Contact Information”);
      4. Records of emails and other correspondence between you and us and our employees (“Communication Information”);
      5. Information about your expertise, memberships, areas of interest or publications (“Interest Information”);
      6. Other public information which is generally available (“Public Information”).
    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. How we process your personal data
    1. Please see the table below, which sets out the manner in which we will process the different types of personal data we hold and the legal basis which is used for the processing:

      Purpose/Activity

      Type of data

      Lawful basis for processing including basis of legitimate interest

      When you or your employer engage us to provide services

      Client Contact Information

      Biographical Information

      Performance of a contract with you.

      Necessary for our legitimate interests (to establish necessary information about you in order to provide our services).

      When we provide services to you / your employer.

      Client Contact Information

      Biographical Information

      Communication Information

      Interest Information

      Performance of a contract with you.

      Necessary for our legitimate interests (for running our business and to provide you with communications services).

      When we communicate with third parties on behalf of our clients in the provision of our communications services.

      Third Party Contact Information

      Biographical Information

      Interest Information

      Public Information

      Necessary for our legitimate interests (in providing communications services to our clients).

      To manage and administer our relationship with you as a client or third party which may include:

      (a) Notifying you about changes to our privacy notice or engagement terms;

      (b) dealing with a complaint or observation.

      Client Contact Information

      Third Party Contact Information

      Communication Information

      Performance of a contract with you.

      Necessary to comply with a legal obligation.

      Necessary for our legitimate interests.

      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);

      Client Contact Information

      Third Party Contact Information

      Interest Information

      Necessary for our legitimate interests in providing communications services to our clients.

      Engage, provide information and communicate with you, on our own behalf or on behalf of our clients, about: our clients; areas of interest or concern; public and economic policy; or other organisations and individuals.

      Third Party Contact Information

      Biographical Information

      Interest Information

      Public Information

      Necessary for our legitimate interests.

  5. Data Retention
    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:
      Category of personal data Length of retention
      Records relevant for tax purposes 8 years from the end of the tax year to which the records relate
      Personal data processed in relation to a contract between you (or your employer) and us 7 years from the end of our contract with you or your employer
      Personal data held on general contact or marketing databases 3 years from the last date on which you have interacted with us
      Personal data held on recruitment databases 1 year from the date on which the application was made and the relevant information was collected
    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.
    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).
    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. 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
    1. We do not disclose personal information you provide to any third parties other than as follows:
      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);
      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;
      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);
      4. in order to enforce any terms or agreements for our services;
      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. 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.
    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
    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):
      1. protecting our servers by both hardware and software firewalls;
      2. locating our data processing storage facilities in secure locations;
      3. when necessary, disposing of or deleting your data so it is done so securely;
      4. encrypting email communications in transit;
      5. regularly backing up all data we hold.
    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.
    3. This notice and our procedures for handling personal data will be reviewed as necessary.
  8. Your privacy rights
    1. The GDPR gives you the following rights in respect of personal data we hold about you:

      The right to be informed

      You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.

      The right of access

      You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.

      The right to correction

      Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.

      We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.

      The right to erasure (the ‘right to be forgotten’)

      Please notify us if you no longer wish us to hold personal data about you (although in practice this may limit or restrict our ability to provide services or assistance). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in backup form, but we will take steps to ensure that it will not be accessible.

      We will communicate the erasure to any third parties to whom we have passed the same information.

      The right to restrict processing

      You can request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data.

      The right to data portability

      You have the right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).

      The right to object

      Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing.

      Right to withdraw consent

      If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

    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 or datamanager@projectassociatesltd.com
    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
    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).
    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 Europe
    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 EEA.
    2. We will not transfer any data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
      1. We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information);
      2. We may be required to provide certain personal information as part of a legal reporting obligation to an entity outside the EEA (for example the US Federal Government) and some of that information may be made public;
      3. From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
    3. If we transfer your information outside of the EEA, and 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, SW1Y 4EX 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 https://ico.org.uk/ for further assistance.