THE ADVANTAGE GROUP UK LIMITED
PRIVACY NOTICE FOR PARTICIPANTS IN SURVEYS
This privacy notice describes how The Advantage Group UK Limited (“we” or “us“) uses personal data relating to participants in our surveys as part of research programmes within the UK and Ireland (referred to as “you“).
We may update this notice from time to time. It was last updated on the April 17 2018.
This notice is set out in the following sections:
- Who we are
- What data we collect and how we use it
- Sharing your information and our relationship with other parties
- Consents and legal basis for use of your data
- International data transfers
- Retaining your information
- Security of your data
- Your rights, including your right to access a copy of the data we hold
- Our contact details
1. WHO WE ARE
The Advantage Group UK Limited is a company registered in England and Wales with company number 06268323. We are registered with the Information Commissioner’s Office (the UK data protection regulator) under number ZA282615 (although registration requirements are due to change in May 2018).
We operate as a franchise of The Advantage Group International, Inc. based in Canada (“Advantage International“) and conduct market research programmes within the UK and Ireland.
We conduct these programmes on behalf of UK and Irish business clients, both retailers and other traders and suppliers. Your involvement in our surveys enables these organisations to give and receive feedback from and to the retailers and traders with whom they work and assists them in understanding their performance and benchmark their activities against other companies.
We act as a ‘controller’ for the purposes of data protection laws in our use of your data for these programmes. This means that we will determine how and why your data is collected and used, and we do not share your individual survey feedback, either quantitative or qualitative (in a form which identifies you) with our clients. Our approaches for sharing survey data with clients are described at section 3.2 below.
Advantage International also assists us with processing and aggregating the survey data.
We are also involved in global market research programmes led by Advantage International. In these cases, Advantage International will have access to UK and Irish data in preparing the cross-market reports. However, we take steps to ensure that Advantage International cannot identify you as an individual from this information (see section 2.3 below).
You may contact us with any queries or concerns about our use of your data, and to exercise your data protection rights (see section 7 below). Our contact details are set out at section 8 below.
2. WHAT DATA WE COLLECT AND HOW WE USE IT
2.1 Initial communication about a research programme
Your name, the company you work for, your role and your contact details may be provided to us by organisations who have suggested that we obtain your feedback as part of one or more research programmes. These organisations may be either:
- the organisation for whom you work (i.e. your employer); or
- an organisation with whom you have had contact as part of your role, for example supplier organisations provide us with details of their contacts at retailer organisations or vice versa.
If you would like to know the specific source of your contact details, please ask us using the contact details at section 8 below.
We use these details to send you an initial email or other communication about the specific programme and the survey we are undertaking, and to request your participation. It is voluntary to participate in this survey.
We may also retain your contact details for use in the following year’s programme (unless you request us not to use them for this purpose).
2.2 Survey responses
Our initial communication may send you a link to an online questionnaire, or otherwise describe how you may participate in the survey. It is voluntary to participate, but if you decide to do so, you are indicating your consent to us using your responses in the way described in this notice.
We will initially ask you to confirm some business information, including:
- your name, telephone number and email address, which we will use to contact you in relation to the survey; and
- your job title and your company, which we use to check that you are an appropriate participant for the survey.
We then ask you a series of more specific research questions aimed at providing feedback to your commercial partners. These may include, for example, your assessment of the quality of your business relationships and people you deal with.
We may follow up with an email and/or telephone interview to discuss your responses in more detail. Subject to obtaining your consent, telephone calls may be recorded so that we can make an accurate record of your qualitative feedback. The recording is destroyed within six months.
Your ratings are then analysed, and aggregated results of the surveys are reported to our clients and related organisations. Scores are anonymised, and we take reasonable precautions to ensure you are not identifiable from your comments, which will not be attributed to you as an individual. Advantage International in Canada assists us with data processing (see sections 3.1 and 5 below).
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 and those of your colleagues. You should inform your colleagues if you are providing feedback on their behalf.
2.3 Global programmes
The data we collect from surveys within the UK and Ireland may also be used as part of global research programmes led by Advantage International, for their international clients (for example, if our client for a UK or Irish programme also subscribes to a cross-market report). Advantage International may have access to UK and Irish survey feedback (both quantitative and qualitative) in conducting global analysis and preparing their aggregated cross-market reports. However, we take steps to ensure that Advantage International cannot identify you as an individual from this information. These steps include removing your name from your survey responses prior to sending them to Advantage International. Your responses will instead be assigned an individual code and only we will have the key to identifying you from that code.
Your personal data may also be used by us:
- to maintain appropriate records of our business communications and transactions. For example, if you contact us to discuss the survey or our use of your data, we will retain a record of the communications between you and us;
- to protect or enforce legal rights, or for other purposes permitted or required by law (including data protection law);
- we may subsequently contact you to share any relevant aggregated data from the programme with you.
- we may also contact you to understand your interest in joining the programme.
2.5 Sensitive personal data
We do not currently collect sensitive categories of data as part of our surveys (for example, information about health, racial or ethnic origin, or criminal convictions). If any such data becomes relevant as part of any research programme, we will seek to provide you with more information about this at the time.
3. SHARING YOUR DATA AND OUR RELATIONSHIP WITH OTHER PARTIES
3.1 Advantage International
Advantage International in Canada is our franchisor, and assists us in analysing, aggregating and anonymising information collected from you as part of our UK and Irish research programmes (see section 2.2 above). In doing so, they act as a processor on our behalf, meaning that we remain primarily responsible for how they use your data. Advantage International also leads global programmes (see section 2.3 above).
We take steps to ensure that Advantage International cannot identify you as an individual from this information. These steps include removing your name from your survey responses prior to sending them to Advantage International. Your responses will instead be assigned an individual code, and only we will have the key to identifying you from that code.
3.2 Clients and related organisations
Aggregated results of surveys (using information from your responses) will be used to provide feedback to our clients (or, for global programmes, clients of Advantage International) and organisations with whom they work and assist them to benchmark their activities amongst their competitors and other companies. See also section 2.2 above.
Scenario 1 – Feedback from retailers and other traders to suppliers
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.
Scenario 2 – Feedback from suppliers to retailers and other traders
Your individual ratings are aggregated with those of other participating suppliers. Your qualitative feedback is edited and aggregated with the comments from other participating suppliers. It is not identified by company or individual.
3.3 Our technology service providers
Our technology service providers may also handle your data, such as our email provider, or the provider of our survey portal. They act as processors on our behalf, meaning that we remain primarily responsible for how they use your data. The relationship with some of these providers is managed on our behalf by Advantage International.
3.4 Other parties
We may also share your data with the following parties:
- legal authorities or regulatory bodies;
- our legal or other professional advisers, insurers and auditors;
- prospective or actual purchasers of our company or business;
- other parties to the extent you have consented to us doing so, or where we are otherwise required or permitted by law to do so.
4. CONSENTS AND LEGAL BASIS FOR USE OF YOUR DATA
In accordance with data protection laws, we have identified the legal basis for the collection, use and disclosure of your data, as described above. The following apply to our activities.
We seek the following consent from you to our use of your personal data.
- Consent to use of your survey responses (including questionnaire and interview feedback) for the purposes of the relevant research programme. Your participation in the survey and submission of your questionnaire responses rely on you consenting to this. See section 2.2
- Consent to the recording of telephone interviews. See section 2.2
- Consent to use your contact details in relation to the following year’s programme
- Consent to use your contact details to share programme outputs, if appropriate
You may withdraw any consent you have given at any time – see section 7 below.
4.2 Legitimate interests
We collect, use and retain personal data (including your contact details and communications with you) which is necessary for our legitimate interests in running the research programmes and in the operation of our business, for example to request your participation in surveys, manage and administer our relationship with you and our clients, maintain records of communications, and protect our legal rights and those of others.
We may also retain your contact details for use in relation to the following year’s programme, unless you indicate to us that you do not wish us to do so.
4.3 Legal obligation
We may collect, use or disclose personal data as is necessary to comply with a legal obligation, such as where law enforcement authorities require us to do so or to address rights of other individuals under data protection laws.
5. INTERNATIONAL DATA TRANSFERS
Advantage International is based in Canada and is subject to data protection laws which provide a similar level of protection to your personal data as under UK and European Union law (in accordance with an adequacy decision of the EU Commission).
Some of our technology systems provided by third parties on our behalf are located in countries outside the European Union, where the laws may not provide the same level of protection for personal data as under UK or European Union law. We do, however, check that safeguards are in place to protect your data to a similar standard as under UK law.
6. RETAINING YOUR INFORMATION
We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures.
We will retain your original responses to our surveys in an identifiable format for a period of two years. Aggregated Information obtained from them and forming part of our survey analysis and reports may be retained beyond this. These are used for research and statistical purposes, including to identify trends and developments within the benchmarking programmes. Note that our reports are also shared with our clients and other third parties, who may also retain copies.
Telephone recordings are destroyed within six months.
We may also continue to maintain records relating to you (such as communications with you) for our own record-keeping purposes, including to comply with our legal obligations and to defend our legal rights.
7. YOUR RIGHTS
If you do not wish us to retain your details to contact you with further surveys, please let us know. Please note that, even if you request this, you may hear from us again if your employer, or parties with whom you work, provide us with your contact details again.
Note that our research surveys would not ordinarily be considered as direct marketing, so if you have previously opted out of direct marketing communications, you may still hear from us in relation to our surveys.
In accordance with data protection laws, you also have a right:
- to obtain a copy of the personal data we hold about you, together with other information about how we process it. This includes your questionnaire responses and a transcript of any telephone interview;
- to withdraw any consent which you have given relating to use of your data (see section 4.1);
- to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your particular situation;
- to receive a copy (in a machine-readable format) of personal data which you have provided to us, to the extent we process it electronically based on your consent (see section 4 above);
- to make a complaint about how we handle your data to the UK Information Commissioner’s Office. Please visit www.ico.org.uk for further information about how to do this.
Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.
If you request erasure of your survey data (for example following withdrawal of your consent to us using it), 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 programme.
Please contact us (see section 8 below) to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about them.
8. OUR CONTACT DETAILS
The Advantage Group UK Limited
Address: Advantage House, Behind Town, Compton Dundon, Somerton, TA11 6PT
Email: Julia Pascu, General Manager, firstname.lastname@example.org
Telephone: 01458 844126