This notice sets out how Palladium International Limited and the Department for Business, Energy & Industrial Strategy (BEIS) will 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 Department for Business, Energy & Industrial Strategy (BEIS), the 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 BEIS 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 is a £60m capacity-building programme, which is part of the Department for Business, Energy and Industrial Strategy’s (BEIS) International Climate Finance portfolio. To deliver the programme, BEIS works in collaboration with Foreign, Commonwealth and Development Office colleagues across countries that are relevant to UK PACT’s delivery, including FCDO officials in Embassies and High Commissions who are part of UK PACT teams.
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.
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 BEIS 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 BEIS and Palladium staff involved in managing the programme.
The Data Controller, Data Processor, and trusted representatives will not:
As this activity involves the processing of personal data, it is subject to data protection rules as established by European Union: EU Directive 95/46/EC and EU Directive 2002/58/EC, in each case as transposed into domestic legislation of each Member State of the European Economic Area (EEA) and in each case as amended, replaced or superseded from time to time, including without limitation by the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (GDPR) and any data protection laws substantially amending, replacing or superseding the GDPR. The United Kingdom General Data Protection Regulation (UK GDPR) is the UK's data privacy law that governs the processing of personal data domestically. It sits alongside the UK Data Protection Act 2018.
Palladium’s sub-contractors HubSpot, which hosts the client relationship management system on which your personal data will be held, and Skotkonung, who are configuring the Touchstone licence for the grant management system, will encrypt data at rest and in transit.
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 2022 but may be extended for up to 3 years until January 2025.
Your personal data will not be subject to automated decision making.
As your personal data is stored on BEIS 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 BEIS.
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
0303 123 1113
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 Department for Business, Energy & Industrial Strategy (BEIS) and the Data Processor is Palladium International Limited (“Palladium”).
You can contact the BEIS Data Protection Officer at: BEIS Data Protection Officer, Department for Business, Energy and Industrial Strategy, 151 Buckingham Palace Road, Victoria, London SW1W 9SZ
If you would like to contact the UK PACT team for any questions on data processing, please do so via firstname.lastname@example.org