Privacy Notice for Participants in Surveys

This privacy notice describes how Finger on the Pulse Research Limited (FOTP) and its clients use personal data relating to participants in surveys (you) as part of research projects within the UK.

We may update this notice from time to time. It was last updated on the 31^st March 2021.

Some projects may involve processing activities which are not covered by this notice or which require variations to the information within this notice. If this is the case, additions or variations to this notice will be communicated to you separately.

This notice is set out in the following sections:

Who we are and what we do
What data we collect and how we use it
Sharing your data
Legal basis for use of your data
International data transfers
Retaining your data
Security of your data
Your rights, including your right to access a copy of the data we hold
FOTP contact details

WHO WE ARE AND WHAT WE DO

Finger on the Pulse Research Limited is a company registered in England and Wales with company number 06268323. FOTP conducts market research projects within the UK.

FOTP conducts these projects on behalf of UK clients, both manufacturers and other types of companies, across various industries. Your involvement in our surveys enables these organisations to give and receive feedback from their key stakeholder groups with whom they work, and assists them in understanding and improving their performance. These stakeholder groups are predominantly employees, customers and suppliers.

In relation to each project, FOTP and its client act as joint controllers under data protection laws in our use of your data. This means that FOTP and its client together determine how and why your data is collected and used for that project. At the beginning of a project, the relevant client and FOTP will ensure you have the identity of the client (who may be your employer, or a customer or supplier of the organisation for whom you work).

Whilst FOTP and its client work together to deliver the project, FOTP does not, as part of the project, share with its client your individual survey feedback, either quantitative or qualitative (in a form which identifies you). The approaches for sharing survey data with clients are described at section 2.3 below.

FOTP will act as your main point of contact for data protection queries relating to a project. You may contact FOTP with any queries or concerns about use of your data, and to exercise your data protection rights (see section 7 below). FOTP’s contact details are set out at section 8 below.

You may also wish to contact the relevant client if you have any concerns about it sharing your contact details with FOTP (as described in section 2.1 below).

WHAT DATA WE COLLECT AND HOW WE USE IT

2.1. Initial communications about a research project

Your name, the company you work for, your role and your contact details will be provided to FOTP by the client, who has suggested that FOTP obtains your feedback as part of the research project. FOTP uses these details to send you an initial email or other communication about the specific project and the survey (e.g. online questionnaire), and to request your participation. We may also follow up with you to encourage participation. It is voluntary to participate in this survey.

The client may also be involved in assessing whether or not you should be involved at different stages of the project, and in encouraging you to participate in the survey, and may contact you directly in relation to this. We may provide the client with updates on whether or not you have participated in the survey for these purposes (but we do not share your individual survey responses in a form which identifies you – see section 2.3 below).

FOTP may also retain your name and contact details for up to 18 months to cross-check against databases provided to it for the equivalent project the following year, or similar projects for the same client or its related entities (if relevant). You may contact FOTP (see section 8) to request that it does not retain your details for these purposes.

2.2. Survey responses

FOTP’s initial communication may contain a link to an online questionnaire, or otherwise describe how you may participate in the survey (such as an initial qualifying interview). It is voluntary to participate, but if you decide to do so, your responses may be used in the way described in this notice.

FOTP may initially ask you to confirm some business information, including:

your name, telephone number and email address, which will be used to contact you in relation to the survey; and
your job title, your company and information about your relationship with the client, which will be used to check that you are an appropriate participant for the survey and to aggregate your data into the appropriate respondent group/segment/channel.

If you participate in qualifying interviews, FOTP may ask you some initial questions aimed at developing questions for the full survey. These interviews may be done by telephone. Telephone calls may be recorded so that FOTP can make an accurate record of your qualitative feedback. The recording is destroyed within six months.

For the full survey, you will be asked a series of more specific research questions aimed at providing feedback to your employer or commercial partners. These may include, for example, your assessment of the quality of your business relationship and people you deal with.

You should not ordinarily provide information which identifies another individual as part of your survey responses. However, if you do provide any information about another individual (such as a specific person within the organisation about whom you are providing feedback), please inform that other individual that you are doing so. In addition, the feedback provided by you should be yours only. If you forward your unique survey link to a colleague for them to complete the survey, you should request they complete it using their own personal details, and direct them to this privacy notice for information about how their details will be used.

FOTP then analyses your ratings and responses, and aggregated results of the surveys are reported to the client and related entities. Scores are anonymised, and FOTP takes reasonable precautions to ensure you are not identifiable from your comments, which will not be attributed to you as an individual.

2.3. Aggregated results

Aggregated results will mainly be used by the client to identify opportunities for improvement, develop action plans and trend performance over time, in case the projects are repeated.

The results are aggregated as follows. If you represent a customer of the client, both scenarios may apply to you.

Scenario 1 – If you represent a customer of the client

Your individual ratings are aggregated with others from your company before any quantitative data is released to clients. Your qualitative feedback is edited and only identified by company name. Company name will only be identified subject to a sufficient response rate.

Scenario 2 – If you are an employee of the client or represent a supplier of the client

Your individual ratings are aggregated with those of other participating suppliers or employees. Your qualitative feedback is edited and aggregated with the comments from other participating suppliers, or employees. It is not identified by company or individual.

2.4. Other

Your personal data may also be used by FOTP and the client as follows:

to maintain appropriate records of business communications and transactions. For example, if you contact FOTP to discuss the survey or our use of your data, it will retain a record of these communications;
to protect or enforce legal rights, or for other purposes permitted or required by law (including data protection law);
to share with you any aggregated data from the project relevant to your responses.

2.5. Sensitive personal data

FOTP does not usually collect sensitive categories of data as part of its surveys (for example, information about health, racial or ethnic origin, or criminal convictions). If any such data becomes relevant as part of any research project, FOTP and the client will seek to provide you with more information about this at the time.

SHARING YOUR DATA

3.1. Qualtrics

Qualtrics software is used to process your personal data in relation to the project. Qualtrics uses data centres within the European Union for processing and storage of data for FOTP research projects. Qualtrics acts as a processor, meaning that FOTP and the client remain primarily responsible for how Qualtrics uses your data (and FOTP has the main relationship with Qualtrics in relation to its activities).

Qualtrics software is used to design online questionnaires and collect quantitative feedback from you. It is also used to process and aggregate your individual quantitative feedback received as part of the research projects. The software may also be used for FOTP to report the survey results to its clients.

3.2. Other service providers

Other technology service providers may also handle your data, such as FOTP’s e-mail provider (currently Microsoft Office 365).

Interviewers and transcribers may also assist in processing your personal data. These are located within the UK.

These parties act as processors, meaning that FOTP and the client remain primarily responsible for how they use your data.

3.3. Other recipients

FOTP or the client may also share your data with the following parties:

legal authorities or regulatory bodies;
legal or other professional advisers, insurers and auditors;
prospective or actual purchasers of their company or business; and
other parties to the extent you have consented, or where they are otherwise required or permitted by law to share the data.

LEGAL BASIS FOR USE OF YOUR DATA

In accordance with data protection laws, FOTP and the client have identified the legal bases for the collection, use and disclosure of your data, as described above. The following apply.

4.1. Legitimate interests

Most of the processing of your personal data in carried out using the legal basis of ‘legitimate interests’:

The client shares your name and contact details with FOTP at the beginning of the project, assesses whether you should be involved at different stages, and encourages you to participate in the survey, in its and FOTP’s legitimate interests in conducting the project.

FOTP shares with the client updates on whether or not you have participated in the survey in its and the client’s legitimate interests in conducting the project.

Your survey responses (and any qualifying interview responses) are generally collected and processed in the client’s and FOTP’s legitimate interests in conducting the project. You have an option not to participate in the survey (or any such interview) and therefore an option not to provide this information.

FOTP collects, uses and retains some of your personal data (including your name and contact details, and general communications with you) which is necessary for its legitimate interests in running the research projects and in the operation of its business, for example to request your participation in surveys, manage and administer its relationship with you and our clients, maintain records of communications, and protect its legal rights and those of others.

FOTP may retain your name and contact details for up to 18 months in its legitimate interests to cross-check against databases for the equivalent project the following year, or similar projects for the same client or its related entities (if relevant). You may contact FOTP (see section 8) to request that it does not retain your details for these purposes.

4.2 Consent

FOTP seeks your consent to the recording of telephone calls (see section 2.2 above in relation to qualifying interviews).

For some projects, FOTP may also seek specific consents from you to the collection and use of certain survey data, which case the legal basis for these activities will be consent rather than legitimate interests.

4.3. Legal obligation

FOTP and the client may collect, use or disclose personal data as is necessary to comply with a legal obligation, such as where law enforcement authorities require them to do so or to address rights of other individuals under data protection laws.

INTERNATIONAL DATA TRANSFERS

Both FOTP and the client, and their activities, are based in the UK.

Some of the technology systems used to process your personal data in relation to the project are provided by third parties, who may be located in countries outside the UK, where the laws may not provide the same level of protection for personal data as under UK law. FOTP and the client have procedures to check that safeguards are in place to protect your data to a similar standard as under UK law. As specified in section 3.2 above, the Qualtrics data centres for FOTP projects are located within the EU, and the EU has similar standards of data protection to those within the UK.

RETAINING YOUR DATA

FOTP and the client will retain your personal data for as long as they need it for the relevant purposes specified above, in accordance with their records retention procedures. In particular:

FOTP may retain your name and contact details for a period of up to 18 months to cross-check against databases provided to it for similar projects for the same client or related entities (see section 2.1 above).
FOTP will retain your original responses to the surveys (including ratings, comments and interview notes) by reference to identifying details (such as your name) for a period of 12 months. These are retained for the purposes of quality control and to address any queries arising. Your responses may be retained beyond this, with identifying details removed.
Aggregated Information obtained from your responses and forming part of our survey analysis and reports may also be retained by the client and FOTP beyond 12 months. These are used for research and statistical purposes, including to identify trends and developments within the research projects. Note that reports containing aggregated data may also be shared with other third parties, who may also retain copies.
Telephone recordings are destroyed within six months.

FOTP and the client may continue to maintain records relating to you (such as communications with you) beyond these periods for their own record-keeping purposes, including to comply with their legal obligations and to defend their legal rights.

YOUR RIGHTS

7.1. List of your rights

In accordance with data protection laws, you have a right:

to obtain a copy of the personal data held about you, together with other information about how FOTP and the client process it. This includes your survey responses and a transcript of any telephone interviews;
to withdraw any consent which you have given relating to use of your data (see section 4.2 above);
to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict the use of your data (and see below for additional detail on your right to erasure),
where the legal basis for processing is legitimate interests (see section 4.1 above), to object to the processing of your data for reasons relating to your particular situation;
to object to the use of your data for direct marketing purposes (see below for additional detail on direct marketing objections);
to receive a copy (in a machine-readable format) of personal data which you have provided to us, to the extent it is processed electronically based on your consent (see section 4.2 above);
not to be subject to a decision based solely on automated processing, which significantly affects you (though, as at the date of this notice, FOTP does not make any such automated decisions about you); and
to make a complaint about how FOTP and the client handle your data to the UK Information Commissioner’s Office. Please visit ico.org.uk for further information about how to do this.

Note that there are certain limitations and exemptions to these rights which FOTP and the client may apply depending on the circumstances.

Please contact FOTP (see section 8 below) to send requests to exercise these rights (specifying what you are requesting), or if you would like further information about them. FOTP will notify and consult with the client in addressing such requests.

7.2. Requesting erasure of your contact details

If FOTP erases your contact details in response to a request for erasure, or if you request that FOTP does not retain them for future surveys (see section 2.1 above), you may still hear from FOTP in relation to another project, if your contact details are subsequently provided to it by the same or a different client. You should inform specific clients if you do not wish them to provide FOTP with your details for the purposes of future projects (and note that clients will generally contact you in advance of providing them to FOTP).

7.3. Requesting erasure of survey data

If FOTP erases your survey data in response to a request for erasure, note that information obtained from your responses may still form part of aggregated and anonymised data sets which have already been collated, used and disclosed for the purposes of the research project.

7.4. Direct marketing

FOTP’s research surveys would not ordinarily be considered as direct marketing, so if you have previously opted out of or objected to direct marketing communications, you may still hear from FOTP or the client in relation to these surveys.