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PA GROUP PRIVACY NOTICE

1. General

1.1. The PA Group is made up of different entities, including Project Associates UK Limited. On this basis, a reference to “we”, “us” or “PA” in this privacy notice refers to the PA Group however, if you would like to know which specific PA 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”)as incorporated into UK law by the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018 and any other applicable data or privacy legislation. This notice applies to personal data we hold in relation to individuals in the UK and European Economic Area.

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 and Applicable Legal Basis

3.1. We may collect and process the following personal data about you, please note that all of this information we will process we will process on the basis that the processing is necessary in order for us to comply with our obligations under a contract or is necessary for a legitimate interest we have in providing services to our clients:

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. However in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data.

3.3. We will collect information either from you directly or from a third party (for instance your employer or an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.

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:

Category of personal dataLength of retention
Records relevant for tax purposes8 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 us7 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

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:

The right to be informedYou 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 accessYou 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 correctionPlease 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 processingYou 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 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 objectUnless 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 consentIf 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).

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@pa.group

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 (“European Area”).

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

10.2.1. We may communicate with individuals or organisations outside of the European Area 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 European Area (for example the US Federal Government) and some of that information may be made public;

10.2.3. Our client may be based outside of the European Area and we may transfer personal data to our client outside of the European Area. For instance we may transfer information to our client outside of the European Area where this is necessary to perform a contract between us and the client and this is in the interests of the data subject;

10.2.4. We may need to transfer personal data to our Group companies based outside of the European Area, however in those circumstances we will ensure that appropriate safeguards are in place.

10.2.5. From time to time your information may be stored in devices which are used by our staff outside of the European Area (but staff will be subject to our cyber-security policies).

10.3. If we transfer your information outside of the European Area, and (as the case may be) the third country or international organisation in question has not been deemed by the UK Secretary of State or 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@pa.group

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.

CCPA/CalOPPA Addendum

The contents in this appendix apply to individuals residing in California from whom we collect personal information in compliance with the California Consumer Privacy Act (“CCPA”) and California Online Privacy Protection Act (“CalOPPA”) and are intended to supplement the information already contained in our privacy notice.

Categories of Personal Information

Below we have set out the categories of Personal Information (as defined in the CCPA) collected in the previous 12 months and whether during such period, we have sold or otherwise disclosed such Personal Information for a business purpose (as defined in the CCPA).

Category of Personal InformationCollected SoldDisclosed for a business purpose

A. Identifiers
Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

YesNoYes

B. Categories of Personal Information in Cal. Civ. Code 1798.80(e)
Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

YesNoYes

C. Characteristics of Protected Classifications under California or Federal Law
Examples: Race, colour, ancestry, national origin, religion or creed, age (over 40), medical condition, genetic information, marital status, military and veteran status, mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression.

NoNoNo

D. Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YesNoYes

E. Biometric Information
Examples: Physiological, biological, or behavioural characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

NoNoNo

F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

NoNoNo

G. Geolocation Data
Examples: physical location.

NoNoNo

H. Sensory Information
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

NoNoNo

I. Professional or Employment Related Information
Examples: Job application or CV information, job history, job performance information.

YesNoYes

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: education records that are directly related to a student maintained by an educational agency or institution or by a party acting on its behalf such as grades, transcripts, disciplinary records.

NoNoNo

K. Inferences drawn from Personal Information
Examples: profiles reflecting an individual’s preferences, characteristics, psychological trends, preferences, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

NoNoNo

Use, Collection and Disclosure of Personal Information

For details on how we use your personal information, please refer to the section “Personal data we collect and how we process this data”.

As set out above in our privacy notice, we generally collect information from you directly however we may also collect certain information from the organisation for whom you work (such as your contact information and job title/role) or other third party. If we obtain your personal data from a third party, your privacy rights under appendix are not affected and you are still able to exercise the rights contained within this appendix.

For details on who we share your personal information with, please refer to the section “Sharing your information” above.

Your California Privacy Rights

  • The Right to Receive Information on Privacy Practices and Access to Information (including as part of an Access Request) – i.e. the right to request certain personal information we have collected about you (including the categories and specific pieces of personal information).
  • The Right to Deletion – i.e. the right to request that we delete certain personal information which we have collected about you (subject to certain exceptions).
  • The Right to Receive Information about Onward Disclosures – i.e. the right to request information about personal information we hold about you which is either disclosed for a business purposes or sold.
  • The Right to Prohibit the Sale of your Information (also referred to as the Right to Opt Out) & the Right Not to be subject to Price Discrimination based upon the exercise of the Opt Out Right- however please note that we do not sell your personal information to third parties.
  • California's "Shine the Light" law (Civil Code Section 1798.83) permits users of our website/platform (as the case may be) that are California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes.

Contact Information

If at any time you would like to contact us with your views about our privacy practices, would like to exercise any of your rights as set out above or have another enquiry or complaint relating to your personal information, you can do so via email at datamanager@pa.group or by post to Project Associates (UK) Limited, FAO Data Protection Manager, 30 Haymarket, St. James’s, London, SW1Y4EX

We will accordingly aim to get to back to you as soon as reasonably practicable. To the extent you have made a specific request as set out under “Your California Privacy Rights”, we will confirm receipt of the request within 10 business days and respond more substantively to the request within 45 days from the time the request is received.