WHAT PERSONAL DATA SCOTPULSE COLLECTS ABOUT YOU AND WHEN
You provide us with personal data when you:
register with us;
complete an online ScotPulse questionnaire survey (“Survey”);
email or otherwise contact us with feedback, comments or questions;
otherwise provide us with information by using the www.scotpulse.com website (the “Website”).
To join the ScotPulse panel, we ask you to complete an initial registration 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 a member of the ScotPulse panel and you will be invited to participate in further Surveys by email from time to time. In your Survey responses, you may reveal information about you and your opinions which we collect and collate into anonymous research results for our clients.
Where relevant to a Survey and provided that you are 18 or over, you may be asked to provide responses which reveal, or may reveal, information about you which is more sensitive or special category data, such as details about your health and medical conditions, sexual orientation or sex life, racial or ethnic origin, political views, religious beliefs, trade union membership or information relating to criminal convictions and offences. We use sensitive data and special category data in the same way we use all the other information we collect from you, but the law requires that we have your explicit consent to collect and use it. We will obtain your explicit consent before processing your personal data which is classified as sensitive or special category data. If you do not wish to consent, you will always have the option to skip these questions by answering “Prefer not to say”. Where a question in a Survey may lead to a participant revealing sensitive or special category data, we will not direct that question to ScotPulse panel members who are under 18. Please remember that the research results we provide to our clients will not reveal your identity except where you have given us your explicit consent. All Surveys are completed on a voluntary basis.
We may also augment personal data you have shared with us with information from other sources such as i) public sources, including the Scottish Government’s SIMD postcode lookup file and Urban Rural Classification, and the Scottish Parliamentary Constituency and Region lookup file (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. If you win a prize draw, including a cash prize which we may issue by way of cheque, we may need your address so that we can deliver your prize to you.
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. To comply with our obligations in that contract with you, we will also use your personal data to enter you into the ScotPulse prize draws, to notify you if you win and to issue the prize to you if you win.
ScotPulse provides market research services to our clients which involves the production of anonymised reports based on Survey responses collected from our panel members. We have a legitimate interest in processing your personal data for the purpose of delivering those services to our clients. In the following circumstances, we use your personal data on the grounds that it is necessary for those legitimate business interests:
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.
to otherwise contact you with important information relating to your account and membership of the ScotPulse panel.
to combine information about you with information about other ScotPulse Survey participants to create anonymous and aggregated insights for our clients in the form of reports.
to produce anonymised but non-aggregated data for our clients in the form of spreadsheets. Such spreadsheets provide information about the way each Survey participant has responded to the Survey, alongside certain demographic indicators (such as geographical location or age group), on a row-per-respondent basis, but such data sets do not reveal your identity.
to deal with any queries or complaints you may have.
if you win a prize draw or competition, to publish your first name and town on our Website and social media pages, alongside details of the prize won, unless you ask us not to.
to analyse information so that ScotPulse can administer, support and improve and develop the business and services we offer (for example, making improvements to ScotPulse based on feedback that you provide).
to create profiles of our ScotPulse panel members but only insofar as to allow us to target Surveys appropriately. For example, a ScotPulse client commissioning a market research project with ScotPulse, may ask us only to target Surveys to a specific age demographic that live within a specific area of Scotland. We do not use that information for any other targeting activity.
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 anonymised before being shared with our clients. Our clients may choose to post anonymised results on publicly available sources, including their own websites. ScotPulse may also post results of Surveys on our Website, again on an anonymous basis.
We share your personal 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, Forsta, who provides the functionality to host and operate our panel members 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 to protect your personal data. 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 personal data to the prospective seller or buyer, or new business partner.
If we need 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 and provided that you are 18 or over, we may pass your Survey responses together with your email address and certain demographic indicators to the client who commissioned the Survey. Where you explicitly agree to this, the client may use your information to contact you to invite you to participate in further research they conduct, such as focus groups. This does not apply to ScotPulse panel members who are under 18. ScotPulse panel members who are 16-17 years old will be excluded from receiving questions that ask if they wish to consent to ScotPulse passing on their survey responses with their email address to the relevant client.
Your personal data is stored in the UK however some support services are provided by supplier staff based outside the UK, which means that your personal data may be transferred outside the UK.
Whenever we transfer your personal data outside the UK, we ensure that a similar degree of protection applies to your personal data by ensuring one or both of the following:
the country to which your personal data is transferred is deemed by the UK’s Information Commissioner to provide a similar degree of protection as the level of protection provided in the UK for your personal data.
we have entered into a specific contract with the relevant service provider that has been approved by the UK’s Information Commissioner as providing a similar degree of protection for your personal data.
OPTING OUT AND ENDING YOUR SCOTPULSE PANEL MEMBERSHIP
If you no longer wish to receive any invitations to take part in ScotPulse surveys or otherwise be contacted by ScotPulse, you can end your membership of the ScotPulse panel at any time by going to Unsubscribe in your ScotPulse account or emailing us directly at email@example.com and telling us. You will also be reminded in each email from ScotPulse inviting you to take part in a Survey that you can unsubscribe at any time by email. When you unsubscribe, you will no longer receive email notifications from ScotPulse and we will delete all data which directly identifies you no later than one week after receiving your unsubscribe request.
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 or 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 panel member. We may retain any data that does not identify you indefinitely.
LINKS TO OTHER SITES
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 logging into your ScotPulse account and going to Update Your Profile.
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 a legal obligation. 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 on this ground as you feel it impacts on your fundamental rights and freedoms. 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.
Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: (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.
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. If you wish to exercise any of the rights set out above, please contact us using the details set out below.
Always keep in mind:
- You can update your personal details at any time by logging into your ScotPulse account and going to Update Your Profile.
- You can close your ScotPulse account at any time by going to Unsubscribe in your ScotPulse account or emailing us directly at firstname.lastname@example.org.
- We will process your requests as soon as reasonably practicable.
HOW TO CONTACT SCOTPULSE
Data Governance Manager
STV Central Limited
Glasgow G51 1PQ
Last updated 23 February 2023.