Privacy Policy

Summary

This privacy policy explains how GMT Economics Ltd. (“GMT Economics”) collects, uses, shares and otherwise processes personal data, and the rights of the data subjects (and/or the entities with which they are affiliated or which employ them) in relation to the personal data it holds.

This privacy policy refers to GMT Economics’ processing of personal data of past and present clients, suppliers, service providers, subcontractors, external consultants and any entity which may contract or interact more generally with GMT Economics (“you”, “your”).

GMT Economics is committed to respecting your privacy and the confidentiality of your personal data.

GMT Economics is the data controller of personal data it has received or collected about you and is subject to the United Kingdom Data Protection Act 2018 (“DPA”), the United Kingdom General Data Protection Regulation (“UK GDPR”). It is also subject to the European Union General Data Protection Regulation (“EU GDPR”) insofar as it processes personal data of data subjects located in the European Union.  It may further be subject to other data protection legislation that is applicable elsewhere.

By contrast, GMT Economics is not the controller of any personal data which is provided by its clients for the purposes of carrying out services that its clients have engaged GMT Economics for.  In these circumstances, GMT Economics will be acting as a data processor and any specific requirements will be set out in the terms of engagement between GMT Economics and its clients as appropriate, along with any agreed measures to protect commercially sensitive information over and beyond personal data.

Please note that GMT Economics’ website does not use cookies or any other web site analytics tools. Should this change in the future, an updated privacy policy will be issued.

How GMT Economics collects your personal data

GMT Economics may collect your personal data in different ways.  For example, it may receive this data from you:

  • during your interaction with GMT Economics before becoming a client, supplier, service provider or subcontractor, such as when you show an interest in GMT Economics’ services or seek to offer your services to GMT Economics;
  • in relation to a prior engagement with GMT Economics;
  • as part of general communications with GMT Economics;
  • during face-to-face interaction with GMT Economics staff, for example at professional events or conferences.

GMT Economics may also collect and store some of your personal data from third parties, including for example from public information available on websites, social media or industry publications, from other entities with which you have dealings, or as part of any “know your client” checks performed.

Types of personal data GMT Economics collects

GMT Economics may collect the following types of personal data:

  • your full name, and contact information such as email addresses, business addresses and telephone numbers;
  • your job title and employer or affiliation;
  • administrative, financial and transactional information (such as bank account details and invoice dates and amounts) used for example for billing and financial reporting purposes;
  • data generated through any “know your client” checks performed;
  • limited technical data (such as your Internet Protocol ‘IP’ address) when you visit the GMT Economics website.

Legal bases for processing your personal data

GMT Economics processes your personal data on one or more of the following legal (or “lawful”) bases:

  • the processing is necessary to enter into or perform a contract for you;
  • it has a legitimate interest that is not overridden by your interests, or by your rights and freedoms;
  • you have consented to the processing; and/or
  • the processing is necessary for GMT Economics to comply with legal, regulatory and/or tax requirements.

“Legitimate interests” include GMT Economics’ commercial interests in promoting and providing economic consulting services, in accordance with all applicable legal and regulatory requirements, and subject to due consideration for your interests and fundamental rights and freedoms.  Examples of such legitimate interests include:

  • delivering client services;
  • from time to time, sharing news or publications such as thought leadership, and promoting GMT Economics’ services; if at any stage you prefer not to receive such communications, please let GMT Economics know, using the email address provided below, and you will no longer receive communications from GMT Economics, unless you request GMT Economics to resume them;
  • financial and administrative purposes;
  • fraud prevention purposes;
  • system and technical maintenance;
  • developing and maintaining client relationships;
  • addressing feedback and responding to enquiries.

Sharing personal data with other parties

GMT Economics may share your personal data with:

  • subcontractors and third party data processors (such as suppliers hosting GMT Economics’ email systems and any servers hosting data) which may process data on GMT Economics’ behalf to enable it to carry out its usual business practices; any such data sharing will only occur so that GMT Economics can process your personal data for the purposes set out in this privacy policy;
  • third party professional advisers such as accountancies, audit firms, banks, insurance firms and law firms;
  • tax, legal and other authorities and courts, including those which may request your personal data, to report any potential or actual breach of applicable laws or regulations, or to exercise GMT Economics’ rights of defence;
  • third parties which are considering or have decided to buy some or all of GMT Economics’ assets or shares, merge with GMT Economics or to which GMT Economics may transfer its business.

GMT Economics does not sell any personal data, nor does it accept advertising on its website.

International personal data transfers

To deliver services to you, it may occasionally be necessary for GMT Economics to transfer your personal data outside the UK, the EU, or the European Economic Area (EEA), for example in the following circumstances: if your or GMT Economics’ service providers are located outside the UK/EU/EEA; if you are based outside the UK/EU/EEA; or where there is an international dimension to the services GMT Economics is providing to you.

If GMT Economics processes data outside the UK, the EU, or the EEA, this will take place in accordance with the relevant legal requirements and in any event GMT Economics will apply standards that are not inferior to those applicable in the UK (unless prohibited by local legislation, or at its clients’ requests).

Personal data security and retention

GMT Economics has commercially reasonable and proportionate technical safeguards, security policies and procedures in place to protect personal information from unauthorised use, loss, alteration or destruction.  These are in accordance with legal requirements and take into account the nature of the personal data and the scope, circumstances and purposes of the data processing. These also take into account the different probabilities of data breaches or incidents occurring and the likely extent of the consequent impact on the rights and freedoms of natural persons, so as to ensure a level of protection proportionate with those risks.

The security of your personal information is very important to GMT Economics, and GMT Economics strives to use commercially suitable means to protect your personal data.  However, it is important to note that no method of transmission over the Internet, or method of electronic storage, is 100% secure, and GMT Economics cannot be responsible for unauthorised or unintended access that is beyond its control.

If you ask GMT Economics not to send any further communications to you, your email address will be stored as part of a dedicated list of email addresses that will no longer be used by GMT Economics, to ensure compliance with your request.

GMT Economics will only retain your personal data for as long as necessary to fulfil the purposes GMT Economics collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for personal data, GMT Economics considers the nature (in particular, the sensitivity) of personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which GMT Economics processes your personal data and whether GMT Economics can achieve those purposes otherwise, and any applicable legislation and regulations.

Your rights

The DPA and UK GDPR stipulate that you have the following rights:

  • Your right of access – You have the right to ask GMT Economics for copies of your personal data.
  • Your right to rectification – You have the right to ask GMT Economics to rectify information you think is inaccurate.  You also have the right to ask GMT Economics to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask GMT Economics to erase your personal data in certain circumstances.
  • Your right to restriction of processing – You have the right to ask GMT Economics to restrict the processing of your information in certain circumstances.
  • Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
  • Your right to data portability – You have the right to ask that GMT Economics transfers the information you gave GMT Economics to another organisation, or to you, in certain circumstances.

If you wish to exercise any of these rights, please contact GMT Economics using the contact details set out below, and GMT Economics will seek to address your query or request within one month.

Contact GMT Economics in relation to its privacy policy

If you have any queries about this privacy policy or how GMT Economics processes your personal data, or if you wish to exercise any of your rights under applicable law, please contact: info@gmt-economics.co.uk.

If you are not satisfied with how GMT Economics is processing your personal data and with GMT Economics’ response to the concerns you have raised, you can make a complaint to the Information Commissioner’s Office:

Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow (Cheshire) SK9 5AF

Helpline number: 0303 123 1113