This notice sets out how Palladium International Limited and the UK Government’s Foreign, Commonwealth and Development Office (FCDO) FCDOwill use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK General Data Protection Regulation (UK GDPR). The Data Controller is the Foreign, Commonwealth and Development Office (FCDO), FCDOthe Data Processor is Palladium International Limited (“Palladium”).
You may also find a related privacy statement on Palladium’s website here which contains further information concerning the processing of your personal data undertaken by Palladium. A further related privacy statement for the Country Programmes Grant Management portal can be found here, this contains further information concerning the processing of your personal data undertaken by Skotkonung and Touchstone within the grant management system. Given that FCDO FCDO will be the owner of the data, the overall UK PACT Privacy notice is also available here.
We will process the following personal data:
UK PACT (Partnering for Accelerated Climate Transitions) is a flagship programme under the UK’s International Climate Finance (ICF) portfolio. The UK is committed to tackling climate change and is investing £11.6bn via ICF over the five years to March 2026. UK PACT was established in 2018 with £70m funding for an initial three-year period. In September 2021, the UK Prime Minister announced £200m of new funding for UK PACT to continue its delivery and grow as a programme over the next four years to March 2026.
UK PACT supports countries with high emissions reductions potential to accelerate their climate change mitigation efforts and move towards clean growth trajectories in line with national commitments and international efforts to limit climate change. UK PACT Country Programmes will support innovative capacity-building projects to support emissions reductions in line with our partner countries’ priorities. The Country Programmes are delivered by Palladium. In addition, Palladium will lead on external communications for the whole UK PACT programme.
The data we have requested above will be essential to carry out competitive grant funding rounds, assessment of prospective projects, communications with applicants, funding allocations, project and performance management of Implementing Partners, effective communication with UK PACT stakeholders and external communications activities.
The nature of the processing will include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available of data.
The nature of processing will include the storage and use of names and business contact details of staff of Implementing Partners, members of the UK PACT mailing list, UK PACT stakeholders, including stakeholders who participate in and benefit from projects in recipient countries, parties who have registered for UK PACT events and staff of organisations applying for funding as necessary to deliver the services, run competitive grant application processes, review applications, contact applicants about their applications, award funding and to undertake projects and performance management. All those, whose data is being processed, will be provided with a contact email address for the UK PACT programme.
Lawful basis of processing
The lawful basis for processing your personal data is processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller, such as the exercise of a function of the Crown, a Minister of the Crown, or a government department; the exercise of a function conferred on a person by an enactment; the exercise of a function of either House of Parliament; or the administration of justice. Data will also be processed on the basis of consent: the individual has given clear consent for us to process their personal data for a specific purpose.
Your personal data will be shared:
As your personal data will be stored on FCDO and Palladium IT infrastructure, it will also be shared with our data processors Microsoft and Amazon Web Services.
UK PACT stakeholders will be required to opt in to the UK PACT mailing list to receive updates about UK PACT. UK PACT stakeholders will be provided with a UK PACT contact point in case of any queries. UK PACT stakeholders may unsubscribe from the mailing list at any time.
Implementing Partners will be provided with names and business contact details of FCDO and Palladium staff involved in managing the programme.
The Data Controller, Data Processor, their trusted representatives (please see Palladium’s Privacy Policy and UK PACT Privacy Notice for further information relating to disclosures and the recipients of your personal data) alongside the above recipients who will only use your data in the context of this programme.
The Data Controller, Data Processor, and trusted representatives will not:
The Data Controller, Data Processor and their representatives or agents will strive to implement commercially reasonable physical, administrative and technical safeguards to help us protect the confidentiality, security, and integrity of your personal data and prevent the loss, misuse, unauthorised access, unauthorised interception, or alteration of your information. Your choice to disclose personal data in an email submission or online form is voluntary. Unfortunately, no data transmission over the Internet is 100% secure and we cannot ensure or warrant the security of any such personal data or fully ensure that your private communications and other personal data will not be inadvertently disclosed.
Your personal data will be kept by us for the duration of the Palladium contract, 2 years, plus a 12-month retention period. The contract will end in January 2023 but may be extended for up to 3 years until January 2026.
Your personal data will not be subject to automated decision making.
As your personal data is stored on FCDO and Palladium IT infrastructure and shared with our data processors Microsoft and Amazon Web Services, it may be transferred and stored securely outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses where stored by FCDO.
If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
casework@ico.org.uk
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
The data controller for your personal data is the UK Government’s Foreign, Commonwealth and Development Office (FCDO)
You can contact the Data Protection Officer at the Foreign, Commonwealth & Development Office:
Data Protection Officer
Information Management Department
Information and Digital Directorate
Room K4.04
Foreign, Commonwealth & Development Office
King Charles Street
London
SW1A 2AH
Email: Data.Protection@fcdo.gov.uk
Telephone: 020 7008 5000
If you have any questions about anything in this notice, or if you consider that your personal data has been misused or mishandled, contact us at data.protection@fcdo.gov.uk.
If you would like to contact the UK PACT team for any questions on data processing, please do so via communications@ukpact.co.uk.
UK PACT (Partnering for Accelerated Climate Transitions) is a unique capacity-building programme. Jointly governed and funded by the UK Government’s Foreign, Commonwealth and Development Office (FCDO) and the Department for Energy Security and Net Zero (DESNZ) through the UK's International Climate Finance, it works in partnership with countries with high emissions reduction potential to support them to implement and increase their ambitions for tackling climate change.
