Version 2: 08.11.23
1. Introduction
This Privacy Policy is provided by the Survey Initiative Limited, a company registered in England and Wales under company number: 08338173 with registered office Abbey Farm Spinnels Lane, Wix, Manningtree, Essex, England, CO11 2UJ (‘we’, ‘our’ or ‘us’) for participation in our surveys which we conduct on behalf of our clients including our web-based platform on which the surveys are hosted (Surveys). We have a separate privacy policy that applies in respect of our website www.surveyinitiative.co.uk and our goods and services, which is available here: [https://surveyinitiative.co.uk/wp-content/uploads/2023/11/Privacy-Policy-General-V2-08.11.23.pdf].
We conduct the Surveys on behalf of our clients, and act as data processors on their instructions, in respect of the personal data we collect in the Surveys. We will inform you, in the Survey, of the relevant data controller, the organisation legally responsible for deciding how and for what purposes it is used, whose own privacy and data protection policies shall apply.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
This privacy policy relates to your participation in our Surveys only.
The Surveys may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Surveys. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
2. Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through the Surveys. We will collect and use the following personal data about you:
| Category of data | In more detail |
| Sensitive data when you participate in a Survey | Depending on the circumstances, it may include but not limited to: – Nationality, ethnicity and; – Socio economic background – racial or ethnic origin; – religious or philosophical beliefs; – health; – sexual orientation – gender identity – disability – caring responsibilities (to the extent that this information is special category data, we will only collect it with your explicit consent) |
| Data we may collect from the data controller about you to provide the Survey | – Your name, phone number, postal or home address, and email address – Your employer, job position, team, location, grade, contract type, line manager, and contract start date Depending on the circumstances, it may also include but is not limited to the follow sensitive data: – Nationality, ethnicity and; – Socio economic background – racial or ethnic origin; – religious or philosophical beliefs; – health; – sexual orientation – gender identity – disability – caring responsibilities
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| Data collected when you use specific functions in the Surveys | Data you store online with us using the Survey including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were) |
| Other data the Survey collects automatically when you use it | Your activities on, and use of, the Survey which reveal your preferences, interests or manner of use of the Survey and the times of use |
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
3. Sensitive Data
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
We may collect special category data as part of the Surveys, to which additional protections apply under data protection law. Where we process such special category data, we will also ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent.
4. How your personal data is collected
We collect personal data from you directly when you use or participate in a Survey, or indirectly, such as your activity while using the Survey. In order to conduct the Survey, we also may collect your personal data (including sensitive data) from the data controller who have engaged us to provide the Surveys or to survey you.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.
5. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Providing the Surveys and the functionality of the Surveys to you and to the data controller | To perform our contract with the relevant data controller to provide you with a Survey and collect your Survey responses on behalf of the data controller |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
| Protect the security of systems and data | To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Operational reasons, such as improving efficiency, training, and quality control or to provide support to you | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
| Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app |
| Updating and enhancing user records
| To comply with our legal and regulatory obligations |
| To comply with our legal and regulatory obligations
| To comply with our legal and regulatory obligations
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| To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
6. Who we share your personal data with
We are conducting the Survey as a data processor on behalf of a third-party data controller, who we will share your Survey responses with on an anonymous, aggregated basis. This means that the way we process your personal data is determined by the data controller, not by us. We will also inform you of the data controller before you participate in the Survey and you should not participate in a Survey unless you agree to the data privacy policies of the data controller, and our sharing of your personal data and Survey responses, with that entity.
We also routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including consultants, developers, cloud storage.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
7. How long your personal data will be kept
We will keep your personal data for as long reasonably required to perform our obligations with the data controller and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
8. Transferring your personal data out of the UK
We may, in limited circumstances, engage third-parties based outside of the UK to process your personal data. In these cases, we will comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
9. Your rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
| Access to a copy of your personal data | The right to be provided with a copy of your personal data. |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data. |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations. |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
| To object to use | The right to object: · at any time to your personal data being used for direct marketing (including profiling) · in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
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| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Surveys. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
10. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
11. How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
12. Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
13. How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
- Abbey Farm Spinnels Lane, Wix, Manningtree, Essex, England, CO11 2UJ
- info@surveyinitative.co.uk
- 01255 870735