CUSTOMER CLOSENESS COMPANY LTD PRIVACY POLICY

INTRODUCTION
1. At The Customer Closeness Company Ltd we are committed to maintaining the trust and confidence of anyone who discloses their details to us, including market research respondents. In particular, we want you to know that The Customer Closeness Company Ltd is not in the business of passing on your personal information to other companies and businesses for marketing purposes. Just in case you want to find out more, in this Privacy Notice, we’ve provided lots of detailed information on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose it to others, how we keep it secure and how you can get in touch to delete or amend any of your personal information.
2. The Customer Closeness Company Ltd are the data controller and data processor, which means we are responsible for deciding how we use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
TYPE OF DATA WE COLLECT
1. We operate a strict data minimisation approach at The Customer Closeness Company Ltd, so we only collect and process data that is necessary for us to effectively run and manage projects including occasionally sharing information about who we are and what we do.
2. We also only keep it for as long as it is needed to do this. Once it isn’t essential, we remove it from our systems
3. We collect, store and process the following categories of personal information about you:
  1. Contact details such as name, title, addresses, telephone numbers, and a contact email address
  2. Location
  3. Gender
4. We may also collect, process and store the following “special categories” of more sensitive personal information including health data:
  1. Audio/video recording of interviews
  2. Adverse event reporting forms
5. We collect personal information about respondents via the following channels:
  1. 3rd party fieldwork agencies
  2. Telephone interviews
  3. Face to face interviews (at central locations/in office/in home)
  4. Online surveys
WHAT WE DO WITH DATA
1. We will only process the personal information you provide when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
  1. When you have provided fully informed consent
  2. Where it is necessary for legitimate interests
CHANGE OF PURPOSE
1. We will only use your personal information for the purposes for which we collected it.
2. With whom might we share your data: We may have to share your data with:
  1. Commissioning clients (only when you have given informed consent)
  2. 3rd party transcribers for analysis purposes
3. We require third parties to respect the security of your data and to treat it in accordance with the law.
4. We may transfer your personal information outside the EU.
5. If we do, you can expect a similar degree of protection in respect of your personal information.
6. Why might you share my personal information with third parties? We may share your personal information with third parties for the purpose of:
  1. Transcription
  2. Market Research analysis
7. How secure is my information with third-party service providers and other entities in our group? All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. Transferring information outside the EU. The data that we collect from you is stored with a provider that may be in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with the applicable laws.
9. For transfer outside the EEA, The Customer Closeness Company Ltd Ltd will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.
HOW DO WE PROTECT YOUR DATA
1. We have put in place measures to protect the security of your information. Details of these measures are available in the data protection policy.
2. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
3. We only ever use IT platforms that are GDPR compliant.
4. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
5. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
HOW LONG DO WE KEEP YOUR DATA
1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. Details of retention periods for different aspects of your personal information are confirmed below. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
2. In some circumstances we may anonymise your personal information so that it can no longer be associated with you.
3. We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require. This includes requiring third parties to delete such data where applicable.
4. The documentation retention periods which we will apply in relation to certain data are as follows, but we will from time to time record separately the periods for which we will retain other data not covered by the headings below (documentation will be retained for a slightly longer period to ensure that the relevant period has expired and destruction or erasure of records may take place periodically meaning that records will be retained slightly longer than detailed):
  1. Audio video recordings – for as long as required (project duration).
  2. Transcripts – for as long as required (project duration).
  3. Contact details, email name and phone number – for as long as required (project duration).
YOUR PRIVACY RIGHTS AND WHO TO CONTACT ABOUT THEM
1. Your rights in connection with personal information. Under certain circumstances, by law you have the right to:
  1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  4. Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  6. Request the transfer of your personal information to another party.
  7. Right to be informed the right to be informed encompasses the obligation to provide ‘fair processing information’, through a privacy notice.
  8. Right in relation to automated decision making & profiling can only carry out this decision making where it is authorised by Member State Law.
2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer.
3. No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
4. What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
5. Right to withdraw consent. In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO OUR PRIVACY NOTICE
1. We monitor our privacy notice regularly and may update it at any time. You can access it on our website at www.customer-closeness.com. This notice was last updated on May 24th 2018.
The Customer Closeness Company Ltd has a strong and clear commitment to equality, diversity and inclusion.
It is our policy that all eligible persons shall have equal opportunity for employment and advancement in The Customer Closeness Company on the basis of their ability, qualifications and aptitude for the work. Everyone has a right to equality of opportunity and to a good and harmonious working environment and atmosphere where they are treated with dignity and respect.
We all want to work in a harmonious workplace where we feel valued, respected and included, irrespective of gender, including gender reassignment, marital or civil partnership status, race/ethnic origin, religious belief or political opinion, disability, having or not having dependants, sexual orientation and age.
In order to provide a high-quality service, The Customer Closeness Company needs to attract, recruit, develop and retain the very best people at all levels. Our approach is based on three key principles:
Equality – we promote equality of opportunity by seeking to remove barriers, eliminating discrimination and ensuring equal opportunity and access for all groups of people.
Diversity – we accept each person as an individual. We believe that everyone should feel valued for their contributions. By working together, we will deliver the best possible service for our staff and stakeholders.
Inclusion – we value impartiality, honesty, integrity and objectivity. Our aim is to be an organisation where people feel involved, respected and connected to our success.

The Customer Closeness Company Ltd has a strong and clear commitment to equality, diversity and inclusion.

It is our policy that all eligible persons shall have equal opportunity for employment and advancement in The Customer Closeness Company on the basis of their ability, qualifications and aptitude for the work. Everyone has a right to equality of opportunity and to a good and harmonious working environment and atmosphere where they are treated with dignity and respect.

We all want to work in a harmonious workplace where we feel valued, respected and included, irrespective of gender, including gender reassignment, marital or civil partnership status, race/ethnic origin, religious belief or political opinion, disability, having or not having dependants, sexual orientation and age.

In order to provide a high-quality service, The Customer Closeness Company needs to attract, recruit, develop and retain the very best people at all levels. Our approach is based on three key principles:

Equality – we promote equality of opportunity by seeking to remove barriers, eliminating discrimination and ensuring equal opportunity and access for all groups of people.
Diversity – we accept each person as an individual. We believe that everyone should feel valued for their contributions. By working together, we will deliver the best possible service for our staff and stakeholders.
Inclusion – we value impartiality, honesty, integrity and objectivity. Our aim is to be an organisation where people feel involved, respected and connected to our success.

CUSTOMER CLOSENESS COMPANY LTD DIVERSITY POLICY