Privacy Policy – Market Research Participation

Introduction

Cognitant takes your privacy very seriously.  This privacy policy sets out how we collect and process your personal data for the purposes of your participation in certain market research activities that you have agreed to take part in (“Research”) under the agreement with you for that Research (“Agreement”).

Who we are

Cognitant Group Limited is the controller and is responsible for your personal data (collectively referred to as “Cognitant”, “we”, “us” or “our” in this policy).

Our full contact details are:

  • Name: Cognitant Group Limited
  • Email address: dataprotection@cognitant.com
  • Postal address: Data Protection, Cognitant Group Limited, 6-7 Citibase, New Barclay House, 234 Botley Road, Oxford OX2 0HP, United Kingdom

Changes to our privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 25 October 2023.  It may change and if it does, these changes will be sent to you by email using the contact details that you have provided to us.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Name, phone number, email address (“Identity Data”)
  • If applicable, payment details for your participation and the method of making payments to you (which may include bank account details) (“Payment Data”)
  • Confirmation about your health condition which makes you eligible for the Research (“Eligibility Data”)
  • Anonymised audio/video recordings and any text-only quotations of your comments provided in your participation in the research or any follow-up call/meeting with you (“Research Data”)

Please note that your Eligibility Data and Research Data may contain information that could be used to make inferences about your health, race or ethnicity.  This therefore constitutes ‘Special Category Personal Data’.  We will only ever use your Research Data on a fully anonymised basis so that it cannot be linked to you.

Except for this, we do not otherwise collect or process any Special Categories of Personal Data.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity Data or Eligibility Data) you give us by registering to take part in Research or by corresponding with us (for example, by email).
  • Information we collect about you during your participation in the Research. We will collect Research Data about you and your experiences relating to the subject matter of the Research. This could be during your initial participation or any follow-up by us.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have consented for the type of processing.
  • Where we need to do this in order to manage your Agreement to participate in the Research and to make any payments due to you (if applicable).
  • Where we process this on an anonymised basis to as part of the Research for our partners
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

Purpose/activity Type of data Lawful basis for processing
To register you for the Research and to manage your participation or any follow-up Identity Data

Eligibility Data

 

 Your consent

Performance of our Research and the Agreement

Necessary for our legitimate interests
To manage any payments to you for your participation in the Research Identity Data

Payment Data

 Performance of our Research and the Agreement
To create our reports and other deliverables for the Research and to provide anonymised text answers to our Research partners Research Data Your consent

Performance of our Agreement

Necessary for our legitimate interests in performing the Research
To administer and protect our business including for legal purposes Identity Data

 

 Necessary for our legitimate interests (for running our business and to manage any legal issues)

Disclosures of your personal data

We do not disclose your personal data to any third parties except for the strict performance of the Research, which may include:

  • Service providers acting as processors who provide IT and system administration services, including video/audio transcription services.
  • Professional advisers acting as processors including lawyers, auditors and insurers based in the UK who provide consultancy, legal and insurance services.
  • Research partners who receive your anonymised comments/quotations as text in our Research reports and related deliverables
  • Third parties who acquire parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may retain and use your personal data in the same way as set out in this privacy policy.
  • In exceptional circumstances, we may have to use your personal data to contact relevant health or other authorities if we considered that your use of the platform gives rise to a risk of serious harm to yourself or anyone else.

International transfers

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner; or
  • Where we use certain reputable service providers, we may use specific contracts approved by the Information Commissioner which give personal data the same sort of protection it has in the UK.

Please contact us if you want further information on where this is required for your personal data and the specific mechanism used by us when transferring that data out of the UK or EEA.

Data security

All information you provide to us is stored on our secure servers. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Except for the operations listed below, your data is kept exclusively within physically secure ISO-27001 compliant data-centres located within the UK or EEA.

In line with many other responsible businesses, we keep back-ups of all our data in our backup service provider’s SOC 2 Type II certified and HIPAA compliant data-centres, hosted in the USA.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We store your personal data as required for the Research or any reasonable follow-up purposes.  This retention period is usually set out in your Agreement with us or, if no specific period is mentioned in that Agreement, then this will be for 3 years.   In either case, if the law or any regulation requires us to keep it for longer then we will have to do this in order to comply with such requirements.

You can ask us to delete your personal data at any time: see ‘Your legal rights’ below for further information.   However, the deletion of data will not affect our continued use of any anonymised data that we have collected and used in our Research.

In some circumstances, we may choose to anonymise all of your personal data (so that none of it can be associated with you any longer) for product development, research or statistical purposes.   If that happens, then we may use this information indefinitely without further notice to you.

Your legal rights

You have the right to:

  • Request access to a copy of your personal data (commonly known as a ‘data subject access request’).
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data unless there is a specific legal reason not to. 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 the law.
  • 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. 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. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • 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
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to carry out the Research.
  • 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 then you will no longer be able to take part in the Research.

You can exercise any of these rights at any time by contacting us at dataprotection@cognitant.com.

Complaints

Please let us know if you have any complaints regarding our use of your personal data by contacting us at dataprotection@cognitant.com.

You also have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues – https://ico.org.uk/make-a-complaint