Policies


Definitions

Adam Smith International, ASI, we, us
refers to Adam Smith International Limited and its affiliates

Personal Data
means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Regulation
General Data Protection Regulation (GDPR)

Sensitive Personal Data
means data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.

Why do we collect your personal data?

We are Adam Smith International, a global advisory company that operates locally to enable governments, economies and societies to transform lives.

We partner with governments, businesses and civil society to create and deliver custom-made solutions to the big challenges facing the world.

We take your privacy very seriously and, in order for us to keep you informed about relevant opportunities, we request to hold your personal data. If you do not allow us to do this, we will be legally obliged to remove you from our database and can no longer put you forward for such opportunities.

What information do we collect?

We will only collect personal data where the personal data is reasonably necessary for a function or activity of ours.

The types of personal data we may collect includes, but is not limited to:

  • Name and gender
  • Date of Birth
  • Postal address
  • Telephone number
  • Email address
  • Occupation, references and previous employment history, qualifications and skills
  • Relationship or marital status
  • Information provided by you through our website, Facebook or Twitter accounts
  • Your contractual and performance history with us

Personal data will be collected using lawful and fair means and will be collected only from you unless this is unreasonable and impracticable. Personal data may be collected in a variety of ways, including:

  • Applications submitted by you or responses to employment advertisements;
  • Enquiries made by you through our websites and comments you make through our websites or social media accounts;
  • When you follow our social media accounts, and register or subscribe to our mailing list;
  • Through government agencies or third party reporting services;
  • You applying to participate in a conference, training session or other event;
  • Through direct contact between you and our staff – e.g. email, phone and direct meeting.

We will take reasonable steps to ensure that the personal data we collect is accurate, up to date and complete.

In the event we are required to process sensitive personal data, for example, to comply with our vetting and duty of care obligations or for any other necessary reason, we shall seek your explicit consent to do so.

Cookies

Cookies are small text files that are stored on your computer as a result of visiting a website. This allows the site to know that you have visited before and, in some cases, can be used to record your preferences. Cookies can be used/stored for two reasons:

  • To help track usage patterns in order to improve and manage a website; or
  • To record preferences in order to personalise your visit to that website.

ASI uses cookies on its website. There are options within your browser to not accept or delete cookies should you wish to do so.

What will we do with your personal data?

The way we use your personal data will depend on the reason(s) why we have received your personal data. The basis for the way we will use your personal data will be disclosed at the time of collection or later processing.
We collect your personal data for purposes including, but not limited to:

  • Provision of services to you, employing you, or receiving services from you;
  • Responding to enquiries;
  • Assessing your suitability for potential employment or other contractual engagement;
  • Submission of documents to our clients including expressions of interest, capability statements and tenders; and
  • Compliance with all relevant laws, court/tribunal orders or enforcement related activities.

Who will we share your personal data with?

We may disclose personal data that we collect from you for the purpose(s) that it was collected. We may disclose the personal data for other purposes where we have received your consent to do so or are required to do so by law. We will only share information outside Adam Smith International to the organisation we are working with when you are put forward for an opportunity or where required for the fulfilment and ongoing management of a contract you are performing services on.

We may also disclose your personal data to third parties:

  • if we use third parties to provide safeguarding or location based communications that you may require in order to fulfil our duty of care requirements;
  • if we use third parties for running our business processes. An example of this might be that we have our emails or our database hosted in the cloud. Whilst these cloud providers would not typically have direct access to your information, storage is considered processing under the relevant data protection legislation. Similarly, as an example, if we have employed you directly, we would need to send your data as required by law to local tax authorities;
  • if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use, which includes exchanging information with other companies and organisations for the purposes of fraud protection.

​We will take reasonable steps to ensure that the personal data we disclose is accurate, up to date, complete and relevant to the purpose of disclosure.

Overseas disclosure of your personal data

ASI is a global company and we may disclose your personal data to our related entities and subsidiaries, suppliers and services providers. Arrangements are in place between each relevant global entity across ASI to protect the personal data to a common standard. This standard includes company-wide compliance to data protection policies and guidelines.

We will take steps to limit the flow of your personal data across borders, transferring only where protection is in place, where the transfer is required for legitimate use, contract administration (e.g. making payments) or where you otherwise consent. Subject to the above, your personal data may be accessible to our entities or offices and employees located in various countries, where such accessibility is required for the performance of the contract or you otherwise consent.

When disclosing your personal data, we will take reasonable steps to ensure that the overseas recipients deal with the information in accordance with the Regulation.

Using your information to keep in touch with you

In addition to our typical processing we may use the information we hold about you in order to contact you in the following circumstances:

  • To advise you of changes to our terms;
  • To advise you of any security concerns;
  • Where permitted by law.

How long do we hold personal data for?

Unless otherwise required by law, we will hold your data as follows:

  • For individuals sending ASI information and not subsequently entering into an engagement with ASI, we hold your data for no longer than 2 years from the end of the calendar year in which it is collected before either seeking confirmation that you continue to provide consent for us to keep holding your data or would like us to delete your data.
  • For individuals entering into any form of contract with ASI, we hold your data for no longer than 2 years from the end of the calendar year in which that contract ends before either seeking confirmation that you continue to provide consent for us to keep holding your data or would like us to delete your data.

Secure collection and storing of your information

All information that you provide to us, or we collect about you is stored on our secure servers. We understand that this includes confidential information and we have put in place a range of suitable physical, electronic and managerial procedures to safeguard and secure your information.

Our staff have the minimum required access to your data and are trained to ensure that it is protected and kept secure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We do not store your information for longer than is necessary to provide the service, and to ensure that we have appropriate auditable records for business purposes.

Unsolicited personal data

If we receive unsolicited personal data, we will make a determination whether the information is reasonably necessary for, or directly related to our functions or activities. If it is, we will ensure that the personal data is stored in the same manner as if we received the personal data directly from you. If we find that it is not, we will destroy or anonymise/pseudonymise the personal data. We will comply with any requirement of a relevant law to disclose the collection of such personal data.

Automated decision-making

You will not be subject to decisions based on automated decision-making.

Your rights

You have the right to request from us access to your own personal data. This is sometimes known as a 'subject access request'.

Additionally, you have the right to request from us:

  • that any inaccurate information we hold about you is corrected;
  • that information about you is deleted in certain situations;
  • that we stop using your personal data for certain purposes;
  • that your member profile is provided to you in a portable format;
  • that decisions about you are not made by wholly automated means.

Many of the rights listed above are limited to certain defined circumstances and we may not always be able to comply with your request. We will tell you if this is the case.

You also have the right to ask us not to process your personal data for direct marketing. We will inform you if we intend to use your information for this purpose or if we intend to disclose your information to any third party for this purpose. You can exercise your right to prevent us using your information in this way by contacting us at people@adamsmithinternational.com

If you choose to make a request to us to exercise any of these rights, we will aim to respond to you as soon as we reasonably can but no later than one month. We will not charge a fee for dealing with any reasonable request.

If you are unhappy with how we are using your personal data or if you wish to complain about how we have handled a request, then please contact Adam Smith International’s Data Protection Officer, Adrian Hollister, and we will try to resolve your concerns.

You also have the right to complain to your local Data Protection Authority and a full list can be found here

Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice.

Law and Jurisdiction

This Privacy Notice is subject to the laws of England, and the non-exclusive jurisdiction of the English Courts.

Get in touch

  • Adrian Hollister (Head of IT and DPO) +44203 9988352
  • Tom Walker (Head of Global Operations and Security and internal GDPR lead) +44203 9988418
  • Rebecca Jefferies (General Counsel) +44203 9988342