This policy document has been designed to keep stakeholders informed about activities performed by SQW involving personal data and individuals’ legal rights regarding how we collect, use, share, store, protect, and delete their personal information.
SQW wants you, or the entity you are authorised to represent ("you", or "your") to visit this website knowing that you have control over your personal data. Your right to privacy and data security is a primary concern for SQW and the firm will take all reasonable measures to protect your information while it is in its care.
SQW respects and values the privacy of everyone who visits this website.
www.sqw.co.uk ("SQW's site") will only collect and use personal data in ways that are described here, and in a manner that is consistent with the firm's obligations and your rights under the law. SQW is committed fully to protecting your privacy.
Should you have questions concerning your personal information or any questions on our use of the information, please direct these to Paula Brand, SQW Group's Data Protection Manager (DPM) who can be contacted by email at firstname.lastname@example.org, by telephone on 01865 261480, or by post at the Oxford Centre for Innovation, New Road, Oxford OX1 1BY.
This site is owned by SQW, a limited company registered in England under company number 1701564 whose registered address is Oxford Centre for Innovation, New Road, Oxford OX1 1BY. SQW is a trading name of SQW Limited, and our VAT number is GB844286704.
What is personal data?
Personal data is any information related to an identified or identifiable natural person – such as names, surnames, location data, home address, health data, identification card number, e-mail address, internet protocol (IP) address, financial information, etc. It includes any data that could be linked to individuals and used to contact, locate, or track them.
When does SQW collect personal data?
SQW only collects data when there is a legitimate business need to do so or when such information is made available to us with your consent. For example, when:
- you complete surveys that we use for research purposes, which we conduct on behalf of our clients when acting as a Data Processor
- you provide information via the SQW website e.g., as part of a recruitment process
- you contact us via phone, email, in person or via the SQW website, when we may keep your contact details
What personal data does SQW collect?
Depending upon your use of the site, SQW may collect some or all the following:
Personal (and non-personal) data:
- Personal identification such as name and date of birth
- Contact information such as physical addresses, email addresses and telephone numbers
- Employment details
- Online identification such as IP addresses, cookies, or other online identifiers
- Personal data embedded in the messages you may send us on our contact forms e.g., in relation to job applications.
On some research projects, when acting on behalf of our clients/Data Controllers, the nature of SQW's business model requires the firm to collect data on your:
- Family and relationship information
- Financial situation
- Personal opinions
- Personal experiences
- National identification number.
On some research projects, to collect and process information which is sensitive, and which requires additional security. Special categories of data include:
- personal data revealing racial or ethnic origin
- personal data revealing political opinions
- personal data revealing religious or philosophical beliefs
- personal data revealing trade union membership
- genetic data
- biometric data (where used for identification purposes)
- data concerning health
- individualised records of pupils with disabilities
- individual offence history
- data concerning a person’s sex life
- data concerning a person’s sexual orientation
- sensitive commercial data, disclosure of which could adversely affect another organisation's reputation or operations (for example, confidential information on a business's product development plans obtained through a consultation process).
How does SQW use your data?
All personal data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. SQW will comply with its obligations and safeguard your rights under the DPA 2018 and the UK GDPR at all times.
SQW's use of your personal data will always have a lawful basis, either because it is necessary for the firm's performance of a contract with you, because you have consented to its use (e.g. by subscribing to emails), or because it is in the firm's legitimate interests. Specifically, SQW may use your data for the following legal basis and purposes:
To guarantee the performance of our contract and services
- Providing and managing access to the SQW website
- Supplying consultancy services to your organization e.g., collecting and processing personal data to perform research and deliver our consultancy services to your organisation (please note that we may require your personal data in order to enter into a contract with your organisation)
- Personalising and tailoring services for your organisation
- Replying to emails or telephone calls from you
- In support of a job application you have submitted
- Handling your enquiries, complaints and providing you with customer services
- Analysing your use of SQW's website (and gathering feedback) to enable us to continually improve the site and your user experience.
With your consent
- Create respondent lists
- Liaise with external parties we may have business relationships with
- Marketing purposes: With your permission and/or where permitted by law, SQW may also use your data for marketing purposes which may include contacting you by email with information, news and developments in relation to SQW's services. SQW will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with the firm's obligations under the DPA 2018/ UK GDPR.
You have the right to withdraw your consent to SQW using your personal data at any time, and to request that it is deleted.
- To fulfill legal obligations when demanded by administrative, governmental, or judicial authorities.
For other necessary purposes upon the customers and users’ further notification.
How long does SQW keep your personal data for?
SQW does not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- General enquiries - completion of enquiry plus six months
- Projects - specifically defined for each project and held within SQW’s Processing Activity Record (PAR), in accordance with the Data Controller’s instructions
- Suppliers (excluding sub-contractors on consultancy assignments) – as per current legislation (seven years)
- Employees – most data are held for one year from the last day of employment, but there are some exceptions e.g. bank account details and national insurance number (see the SQW employee privacy notice for details)
- Recruitment candidates – six months.
SQW follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.
Cookies and Web Beacons
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.
How and where does SQW store your data?
SQW only keeps your personal data for as long as it is necessary in order to use it as described above, and/or for as long as the firm has your permission to keep it.
Data security is very important to SQW, so to protect your data, the firm has taken suitable measures to safeguard and secure data collected through this website. Further details are provided in SQW's Information Security Policy, which is available on request.
Does SQW share your data?
SQW never shares your data with third party marketing companies.
SQW may share your data with other companies within the SQW Group so that beneficial services can be offered to you.
SQW may sometimes contract with third parties to supply services to you. In some cases, the third parties may require access to some or all your data. Where any of your data is required for such a purpose, SQW will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, SQW's obligations, and the obligations of the third party under the law.
SQW does not sell personal data in any form, including mailing lists. All of the personal data that we collect is for internal use only.
SQW may compile statistics about the use of this site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any pseudonymised data that can be combined with other data and used to identify you. SQW may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared with your consent and used within the bounds of the law.
In some circumstances, SQW may be legally required to share certain data held by us, which may include your personal data, for example, where the firm is involved in legal proceedings, complying with legal requirements, a court order, or a governmental authority.
What happens if the ownership of SQW changes?
How can you control your data?
You have the right to ask for a copy of any of your personal data held by SQW under the DPA 2018 and the UK GDPR. Any reasonable request is free of charge and SQW will provide all relevant information that is held by the firm. SQW also wants to make sure that any information it stores on you is correct. Please contact us for more details at email@example.com.
Furthermore, if your data is being collected and processed for research purposes, please note that our clients/the Data Controllers are responsible for executing your data subject rights related requests, and SQW, as a Processor, will liaise and cooperate with them to fulfill such requests.
Your right to withhold information and withdraw your consent
You may access certain areas of the SQW website without providing any data at all. For certain services provided by us, you may be asked for your contact details, and you have the right to object the processing of your information.
Your right to be forgotten
As mentioned above, SQW only collects data when there is a legitimate business need to do so. SQW only holds the minimum amount of personal data required and for a limited amount of time. However, you have the right to request that SQW removes or deletes your personal data from its systems if you believe that:
- we no longer need to process your information for the purposes for which it was provided.
- we have requested your permission to process your personal information and you wish to withdraw your consent.
- we are not using your information in a lawful manner; or
- you have objected to your data being processed.
Please note that if you request us to delete your information, we may have to suspend the provision of services, products, or both to you.
Please contact firstname.lastname@example.org for more details.
How can you access your data?
You have the right to know if we process your personal information and ask for a copy of any of your personal data held by SQW. Under the DPA 2018 and the UK GDPR, no fee is payable and SQW will provide all relevant information in response to your request free of charge.
Please contact SQW for more details at email@example.com.
Your right to lodge a complaint with the ICO
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the Information Commissioner Officer (ICO). The Information Commissioner can be contacted at:
Information Commissioner's Office
0303 123 1113
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
Your right to have data rectified
If you believe that any of the information that we hold about you is inaccurate or out of dated, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Please note that we proactively care about the quality of the personal data we hold and maintain our personal data records updated and accurate.
Your right to data portability
You may request us to transfer to a third-party your data in a machine-readable format where the:
- personal information was provided on the basis of consent;
- processing is by automated means; and
- processing is based on the fulfilment of a contractual obligation.
Your right not to be subject of a fully automated decision
We may use automated systems or profiling to make decisions about you by using your personal data.
You have the right to request further information about the criteria upon which the automated processing and profiling activities we perform function, as well as the right of objecting such decisions.
You may as well request for a review of the results generated by the automated decision making or profiling processes and challenge a decision.
DATA PROTECTION OFFICER: Darren Boyd-Annells, firstname.lastname@example.org