ScotPulse is a trading name of STV Central Limited, with its registered office at Pacific Quay, Glasgow, G51 1PQ (“ScotPulse”, “We”, “Us”) which is the data controller responsible for looking after your personal data in line with data protection and privacy laws. Personal data means any data relating to an identified or identifiable individual (“Personal Data”).
WHAT PERSONAL DATA SCOTPULSE COLLECTS ABOUT YOU AND WHEN
You provide us with Personal Data in the following circumstances:
In order to register with us and join the ScotPulse panel, we ask you to complete an initial survey and provide some Personal Data, including for example, your name, email address, postcode, date of birth and gender. We also ask for general economic and household information.
Once you have registered, you will be invited to participate in further surveys. During the course of participating in a Survey, you will be asked to provide further personal information necessary for the purposes of the relevant market research. You may be asked to provide responses which reveal or may reveal details about your health and medical conditions, sexual orientation or sexual life, race/ethnic origin, political views, religious beliefs, and/or trade union membership, where relevant to the market survey “Special Categories of Personal Data” and/or information relating to criminal convictions and offences. Please remember that Survey submissions shall at all times remain anonymous. All surveys are completed on a voluntary basis. Where required by law, we will obtain your explicit consent to the processing of your Personal Data which is classified as any of the “Special Categories of Personal Data” criminal convictions and offences.
We may also augment personal data you have shared with us with information from other sources such as i) public sources (for example we may compare your postcode against public registers to determine which local authority area you reside in) and ii) data matching partners such as Experian who provide consumer classifications which may help us segment our survey data on the basis of lifestyles etc.
We may post results of surveys on our website, however we will do so on an anonymous basis. Results may also be posted, again on an anonymous basis, on our clients’ websites.
When you email or otherwise contact us with feedback, comments or questions.
If you win a prize draw we may require your address in order to deliver your prize.
ScotPulse also collects the following types of data:
HOW SCOTPULSE WILL USE YOUR PERSONAL DATA
We only use your Personal Data where permitted in accordance with data protection and privacy laws. The key legal grounds upon which we rely are:
Where we need it to perform the contract we have with you (please see our Terms and Conditions)
Where we have your consent
Where it is necessary for our legitimate interests and/or those of third parties with whom we share your data as described in this policy, and your interests and fundamental rights do not override those interests (please see below for more info)
In order to comply with a** legal or regulatory obligation**
ScotPulse uses your personal data to register you as a member of the ScotPulse panel (as described above) in order to perform the contract we have with you.
In the following circumstances we use your personal data on the grounds that it is necessary for our legitimate business interests, namely the ability to process your personal data in order to provide market research services to our clients, namely the production of aggregated, anonymised reports based on survey responses collected from our panel members:
to send you invitations to take part in our Surveys that we believe are relevant to you based on the information that you have provided to us as part of the registration process and/or that you have provided in response to our surveys;
to otherwise contact you with important information relating to your account and membership of the ScotPulse panel;
to deal with any queries or complaints you may have;
to enter you into the ScotPulse free prize draws and other competitions and incentives run by ScotPulse and to enable us to notify you if you win and to issue prizes (this information will also be published on our website and social media pages unless you ask us not to);
to provide you with research results and other survey related information;
to analyse the information so that ScotPulse can administer, support and improve and develop the business and services we offer;
to append your Personal Data to your responses to any surveys you participate in, such as geographical location or age group in order to better analyse the survey responses and produce anonymous, statistical results
to create anonymous, statistical profiles of members of our panel
to ensure a smooth and enjoyable experience of our website and our surveys, including quality control, and tracking of completed surveys.
SHARING YOUR PERSONAL DATA
Please note that all survey responses are aggregated and anonymised before being shared with our clients. However, we share your data in the following circumstances:
When we engage data processing companies from time to time to help store, manage your data, and to deliver specific functionality, including industry leading supplier Confirmit which provides the functionality to host and operate our panel base register and our surveys. These companies must comply strictly with our instructions and we do not permit them to further use or share your personal data. We also require them to have appropriate technical and operational security measures in place. We limit access to your Personal Data to those employees, agents, and subcontractors who have a business need to know and they are subject to a duty of confidentiality.
In the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer, or new business partner.
If we have to enforce our Terms and Conditions.
Where we are required by law to do so.
Where we obtain your explicit consent to do so as part of a survey, we may pass your individual survey responses together with your email address to the client who commissioned the survey. Where you explicitly agree to this, the client may use your information in order to contact you to invite you to participate in further research they conduct.
Your Personal Data is stored in the UK however some support services are provided by supplier staff based outside the European Economic Area (EEA), which means that your personal data may be transferred outside the EEA.
Whenever we transfer your Personal Data outside the EAA, we ensure that a similar degree of protection applies to your Personal Data by ensuring one or more of the following:
the country to which your personal data is transferred is deemed by the European Commission to provide a similar degree of protection for your Personal Data
we have entered into a specific contract with the relevant service provider that has been approved by the European Commission as providing a similar degree of protection for your Personal Data
where a service provider is based in the US, they have self-certified under the EU-US Privacy Shield Framework which requires them to provide a similar degree of protection for your Personal Data.
If you no longer wish to be contacted by ScotPulse, then you can unsubscribe from ScotPulse at any time by sending an email to firstname.lastname@example.org with unsubscribe in the subject line. You will receive notification that you can unsubscribe every time ScotPulse contact you by e-mail.
SECURITY AND DATA RETENTION
The security of your data is important to us. We have technical and operational security policies in place to protect the data we collect, use and store, against unauthorised access or disclosure; improper use, alteration, unlawful or accidental destruction of loss.
However, please be aware that the sending of information through the internet is not completely secure. We do not guarantee the security of your data transmitted to and from our services over the internet, and you accept the inherent security implications of using the internet, and will not hold us responsible for any breach of security unless we have been negligent.
We will only keep your Personal Data for as long as necessary in connection with the purposes we collected it for and to comply with any legal, accounting or reporting requirements. To determine how long we keep your Personal Data for, we consider the amount, nature and sensitivity of the Personal Data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.
We will hold the Personal Data you provided to us at registration and information from Surveys you have completed which is used to help us identify surveys that may be of interest to you and will retain such data until you tell us that you no longer wish to be a ScotPulse member.
We may retain any data that does not identify you indefinitely.
THIRD PARTY WEBSITES
You have various rights in relation to the Personal Data we hold about you which include a right to: - Request access to a copy of the personal data we hold about you (commonly known as a “data subject access request”)
Request correction of any inaccurate personal data that we hold about you. Please note that you may correct or remove information you think is inaccurate by updating your profile information via the personal page on the ScotPulse website www.scotpulse.com
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Data Portability. You have the right to request the transfer of a copy of the Personal Data we hold about you in an electronic format whether the basis of our holding such information is your consent or the performance of a contract and the information processed is by automated means.
Make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. If you wish to exercise any of the rights set out above, please contact us by email at email@example.com or write to us at
ScotPulse STV Pacific Quay Glasgow, G51 1PQ
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
HOW TO CONTACT SCOTPULSE
Glasgow, G51 1PQ
Last Updated 25 May 2018