PRIVACY POLICY
Processing purpose:
Directions Research & Marketing (Directions) processes personal data for the purpose of conducting market research. This is most often on behalf of another organisation(s), when they have a need for independent market research. However, on occasion Directions also conducts its own research, and may also conduct research on behalf of another organisation because we have specific research expertise or resource.
Lawful basis for the processing:
Consent:
Where personal data is collected by Directions for research purposes, it is always collected and processed with informed consent as the lawful basis for processing. Informed consent is always transparent, ensuring the data subject is fully informed before they take part in the research about what, how and where their data will be used before they begin to give their data. This information is always available in the introduction to the research task before you take part. Informed consent is always collected by way of an affirmative action such a recorded verbal agreement when taking part in an in-depth interview, or writing your name in the consent field when conducting mobile research.
Legitimate interest:
Where personal data has been shared with Directions by a data controller for research purposes, and Directions is acting as the data processor, we process that data under the lawful basis of ‘legitimate interest’. It is within Directions’ legitimate interest to receive personal data from our clients to invite data subjects to take part in independent research on behalf of our clients, as this is Directions’ core business and purpose. This lawful basis is always given in the introduction to the research task that you take part in. Where a data controller shares personal data with Directions, we will process only personal data that has been shared securely and lawfully according to the GDPR.
Personal data we collect:
If you have been invited to take part in a Directions research study you will have given your consent for us to receive your contact details (name, address, email address, mobile phone number etc.) and some details about you as a ‘consumer’ (e.g. your age, gender, shopping habits) before taking part in research. During our research study we will also collect your attitudes, behaviours, perceptions etc. in relation to a given subject/topic.
Who will personal data be shared with?
Following your participation in our research study, all information will be reported to the client that has commissioned the research anonymously, with the following exceptions and always with your prior consent:
We may use audio, or video clips, or photos from the research session/mobile task. These will be shared with the client and only used for market research purposes. Whilst we won’t identify you by naming you, or giving away other identifying information, your image may be used to help to bring to life the findings. Clients will only be permitted to use the audio/ visual materials internally and in trade discussions with retailers. The clips or photos will not be in the public domain.
You may be asked to share photos, audio clips or videos with other participants and clients as part of the market research process too. We’ll let you know this is going to happen before you are asked to share anything, and it’s up to you what you want to share. Again, the other participants won’t know any identifying personal details about you – other than the images or thoughts you chose to share.
Directions also shares your data with third parties to perform functions on our behalf. We require these third parties to comply strictly with our instructions and data protection laws and we make sure that appropriate controls are in place. We enter into contracts with all our third parties and regularly monitor their activities to ensure they are complying with our policies and procedures.
For example, we use third-party software/platform providers (MyInsights and Zoom) when conducting mobile and online research, therefore these providers may store your personal data during a research project. These providers have strict data protection and security processes in place – see below:
MyInsights:
Directions uses MyInsights App provided by Mobile Market Research to conduct its ethnographic mobile research. To find out more about their security and privacy policy, please click on the following link: https://www.mobilemarketresearch.com/application/privacy
Zoom:
Directions uses Zoom to conduct online focus groups and in-depth interviews. When we use it for online focus groups/depths we provide participants with account login details and ask them not to give any of their personally identifiable information. Zoom content is protected with the Advanced Encryption Standard (AES) 256 using a one-time key for that specific session. To find out more about their security and privacy policy, please click on the following link: https://zoom.us/privacy
Other software:
If Directions uses any software that will have access to personal data for research purposes, we will inform you of the software being used and provide a link to their GDPR/privacy/data protection/security policy. Directions will always ensure that the organisations running the software comply with the GDPR.
Transfer of personal data to another country:
We regularly conduct international research and some of our clients are global businesses with offices worldwide, therefore the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by one of our suppliers operating outside the EEA. By submitting your personal data, you agree to this transfer, storing or processing.
Protection of your data:
Directions maintains appropriate technical, administrative and physical safeguards to protect information, including, without limitation, personal data, received or collected by us. We review, monitor and evaluate our privacy practices and protection systems on a regular basis.
Retention period or criteria used to determine the retention period:
Directions does not keep personal data longer than is necessary and anonymises data where possible, securely deleting personal data associated with it at the earliest possible point. As a minimum, Directions reviews whether it is necessary to keep personal data one year after data is collected and deletes any personal data which it is not necessary to keep.
Your rights:
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access - you have the right to request a copy of the information that we hold about you.
Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing - where certain conditions apply to have a right to restrict the processing.
Right to object - you have the right to object to certain types of processing such as direct marketing.
Right to judicial review - in the event that Directions refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
Queries and complaints:
If you have any queries concerning this policy, or would like to make a subject access request, please contact:
Kirsty Boyce
Managing Director
Directions research & marketing
Knightway House, Park Street,
Bagshot, Surrey, GU19 5AQ
Email: kirsty@directions.uk.com
Phone: +44 1344 625975
If you wish to make a complaint about how your personal data is being processed by Directions (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint with Kirsty Boyce (MD at Directions) or with the supervisory authority – see below:
Website: https://ico.org.uk/concerns
Telephone helpline: 0303 123 1113