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TCE

Ethical Policy

KEY INFORMATION

At TCE we are committed to working with integrity and ensuring our work – including our training, our research and our monitoring and evaluation – meets the highest ethical standards.

Regulatory & Legal Compliance

  • TCE and its employees and consultants are required to comply with UK law and the laws of the countries in which we work.
  • TCE is fully compliant with the UK Data Protection Act 2018 and works within the limits of data protection policies in the countries in which we work.
  • TCE supports the UK Modern Slavery Act 2015.

Employment & Good Conduct

  • TCE’s employment practices are founded on the basis of non-discrimination. TCE employs its staff, including consultants, on merit and on their qualifications and abilities to carry out the work required of them.
  • TCE expects its employees and consultants to act with integrity at all times and not act in a manner that will damage TCE’s reputation.
  • TCE expects its employees and consultants to avoid conflicts of interest whenever possible and to report them if they arise so that appropriate support and guidance can be given.
  • TCE does not give or receive bribes. If an employee or consultant is offered a bribe, or a bribe is demand, they are expected to report it to TCE and to the relevant authorities in the country in which they are working.

Workplace Equality

TCE is committed to equality and diversity in the workplace. Specific actions undertaken within our Workplace Equality policy include:

  • Carrying out annual evaluations to identify any disparities that may exist among consultants working with TCE. These evaluations are used to ensure not only gender representation but a range of age and ethnicity, especially as regards the balance across teams of local in-country consultants and TCE international consultants.
  • Implementing diverse and inclusive recruitment and promotion practices and creating a culture of inclusivity by promoting open communication and creating a safe and supportive workplace environment for all.
  • Providing opportunities for under-represented groups within local consultant in-country teams and providing additional training or support as needed. In some cases, this might mean prioritising female consultants over male consultants, or early career researchers over mid- or late-career researchers at recruitment stage, all other things being equal.
  • Ensuring equitable pay for local consultants and for international consultants.
  • Collaborating with educational organisations that specifically focus on diversity and inclusion. Recent TCE partnerships include AIWR (The Alliance for International Women’s Rights) in Afghanistan and the Hands Up project in Gaza.

Safeguarding

  • TCE is committed to ensuring the well-being of the people we work with and that the children and vulnerable adults we work with are protected.
  • TCE evaluators and researchers working with children and vulnerable adults are required to undergo a DBS (Disclosure and Disbarring Service) check and obtain a DBS certificate.

Ethical Code of Conduct

  • TCE’s monitoring, evaluation and research activities are guided by the principles of informed consent, voluntary participation, confidentiality and anonymity. Where anonymity cannot be guaranteed – for example, when a person’s position may lead to their identification – any public reporting of data generated by their participation will be discussed with them first and their consent to its use will be requested.
  • TCE encourages its employees and consultants to publish their work. Where that work has been externally funded, the approval of funders is to be sought before publication. All contributors to publications are to be acknowledged.

Environmental Protection

  • TCE will always seek to minimise the impact of its work on the environment. 

Data Management

Data management system
As a company demonstrating strong compliance with the GDPR and its relationship to the UK GDPR and amended UK DPA 2018, we take data collection, retention and removal very seriously. For more information on our general privacy policy and data collection practices, please see here. Our Data Protection Officer – Gavin Dudeney – can be contacted at gavin.dudeney@theconsultants-e.com. Apart from UK GDPR and UK DPA 2018 compliance, we are familiar with working in environments where other practices may be more commonplace, or lawful requirement. We aim to maintain our data practices outlined below, whilst recognising that local factors may be brought to bear on any individual project.

Data collection
Data collection for M&E projects of this nature is carried out by authorised staff, using a variety of on-the-ground tools and devices, as well as secure online forms and other collection tools. Our consultants will only collect the data needed for any given project, as agreed with the contractor. When data collection is carried out, participants are made fully aware of what data is being collected, how it will be stored and used, and what measures are in place for its automatic removal, or for its removal on request (where such a request is in line with UK GDPR and UK DPA 2018 regulations and the project aims). Where physical data collection involving hard-copy matter is necessary, paper-based data will be input and transferred to digital storage as soon as feasibly possible, and hard copies destroyed where appropriate. All digital collection is carried out using secure online tools and sites.

Data storage
Once collected, data is transferred to secure storage online, and access limited only to those working on any given project, and then on a more granular level within the given project. Collected and current data stored online for the purposes of carrying out data analysis is backed up on an hourly basis to a secure storage facility at the registered UK address of the company, where secure daily on-site backups are also made. This level of redundancy ensures that data is both available to project consultants, but also safe, secure and easily recoverable in the case of any storage failure at any given node in the process. Data storage is limited not only by agreements set at the time of the data collection, but also by UK GDPR and UK DPA 2018 rules regarding data retention. For projects of a sensitive nature, we are able to offer encrypted data storage and sharing. TCE operates a clean desk policy in its physical offices.

Data sharing
Data sharing is only carried out upon agreed lines with the contractor, and with company staff on a role-by-role basis. TCE consultants will only be given access to the data that they need to successfully carry out any given part of a project. This access will normally be via secure online services but may also be in the form of physical media such as a secure USB drive or similar, as required. Data is never transferred using unsecured or non-encrypted means.

Data removal
Once a project has successfully finished – and with the agreement of the contractor – all stored copies of the data may, where appropriate, be deleted from both the online and local storage facilities. If this is not carried out as standard, TCE will apply workable GDPR practices to ensure that data is deleted at an appropriate juncture and point in time. For longitudinal projects, data can be safely stored if so requested by the client, for later retrieval and review.

Data breaches
Data breaches, should they happen, should be reported in the first instance to the TCE Data Protection Officer (see above) who will take any and all appropriate steps to minimise the potential damage of such a breach, and to inform involved parties so that they make take similar actions as appropriate. It should be noted that in sixteen years of operation we have never suffered a data breach.

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