Background
SQW takes data privacy seriously. We are committed to ensuring the privacy and security of the personal data we process and maintain the confidence of those whose data we are entrusted with.
This Privacy Policy aims to help you understand how SQW collects your personal data, how we use it, who we may disclose or share personal data with, and explains:
- Who we are and what we do
- What personal data we collect about you
- How we obtain personal data about you
- How we use your personal data
- Who we share your personal data with
- How we store your personal data
- How we protect your personal data
- Who is the controller in relation to your personal data
- How we use cookies and similar technologies
- What happens if ownership of SQW changes
- Your rights in relation to your personal data
- How long we keep your personal data
- How you can contact us
- Your right to complain
- How we update this Privacy Notice
By using this website, you are agreeing to the terms of SQW's Privacy Policy and you expressly consent to the processing of your personal data as set out in this policy. You should not provide SQW with any personally identifiable information unless you would like those data to be used by SQW in accordance with this policy. .
SQW's website may contain links to other websites. Please note that SQW has no control over how your data are collected, stored or used by other websites. SQW advises you to check the privacy policies of any such websites before providing any data to them.
1. Who we are and what we do
SQW is a leading independent provider of research, analysis and advice in economic and social development. Established in 1983, and operating across the UK, Europe and internationally, we work for clients from the public, private and voluntary sectors. We are experts in public policy and work with our clients to research, develop, implement and evaluate social and economic development interventions across a wide range of policy domains.
The company is registered in England under company number 01701564 whose registered address is Oxford Centre for Innovation, New Road, Oxford, OX1 1BY, United Kingdom. SQW is a trading name of SQW Limited, and our VAT number is GB844286704.
2. What personal data we collect about you
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 and financial information, etc. It includes any data that could be linked to individuals and used to identify them.
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 email addresses and telephone numbers
- Employment details
- Education
- Photographic
- Address
- Online identification such as IP addresses
- 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 clients/Data Controllers, the nature of SQW's business model requires the firm to collect data on your:
- Gender
- Family and relationship information
- Employment
- Financial situation
- Personal opinions
- Personal experiences
- National identification number.
On some research projects, SQW collects and processes 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.
SQW may also collect and process 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).
3. How we obtain personal data about you
SQW may collect or receive your personal data in a number of ways. For example, when:
- you complete surveys that we use for research purposes
- you provide information via the SQW website e.g. as part of a recruitment process
- you contact us via phone, email, social media, Microsoft Teams, in person or via the SQW website, when we may keep your contact details to respond to your query or concern.
- you visit our website, leaving information about your computer and visits (please see SQW's cookie policy)
- you consent to our use of your personal data for marketing or other purposes.
4. How we use your personal data
SQW's use of your personal data will always have a valid 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 to:
- provide and manage your access to the SQW website
- supply consultancy services to your organisation e.g., collecting and processing personal data to perform research and deliver our consultancy services to your organisation (please note that we require your personal data in order to enter into a contract with you)
- personalise and tailor services for your organisation
- reply to emails or telephone calls from you
- assist with a job application you have submitted
- handle your enquiries or complaints and to provide you with customer services
- analyse your use of SQW's website (and gathering feedback) to enable us to continually improve the site and your user experience.
With your consent and/or when permitted by law, SQW may:
- create respondent lists
- liaise with external parties that we have business relationships with
- also use your data for marketing purposes which could 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.
More broadly, SQW may use your personal data to:
- fulfil legal obligations when demanded by administrative, governmental, or judicial authorities
- enter into a contract or perform our contract with you
- achieve a legitimate interest and our reason for doing so outweighs any prejudice to your data protection rights
- use your information where it is required to defend, prosecute or make a claim against you, SQW or a third party.
You have the right to withdraw your consent to SQW using your personal data at any time and to request that it is deleted.
5. Who we share your personal data with
Personal data that we collect or which you provide to us may be shared with and processed by any of member of the SQW Group, so that beneficial services can be offered to you.
We may share personal data with our professional advisors such as our outsourced Data Protection Officer to ensure we provide you with the highest level of data protection and comply with applicable law. Our outsourced Data Protection Officer is Darren Boyd-Annells who can be contacted at: dpo@sqwgroup.com
Your personal data may also be shared in compliance with our regulatory requirements, such as regulators, law enforcement agencies, government bodies in connection with enquiries, proceedings or investigations when compelled to do so.
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 of 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.
SQW never shares your data with third party marketing companies.
6. How we store your personal data
SQW ensures that all personal data is stored locally here in the United Kingdom in compliance with industry standards or in a territory recognised by the United Kingdom as adequate or offering the same level of protection to personal data as that provided in the United Kingdom. Where it becomes necessary to store or transfer personal data outside the United Kingdom, SQW ensures that an appropriate level of privacy and security is applied.
7. How we protect your personal data
Data security is very important to SQW, so to protect your data, the firm has taken suitable measures to safeguard and secure all data it has collected The information that you provide to SQW is stored on SQW owned servers or those of our service providers. Such personal data may only be accessed in accordance with our Information Security Policy or in accordance with the security standard agreed with our service providers. We also ensure that all of our staff and sub-contractors are contractually obliged to respect the confidentiality of personal data. SQW applies robust access controls to all data to ensure access is restricted. SQW has the Cyber Essentials Plus[1] accreditation.
8. Who is the controller in relation to your personal data.
SQW collects personal data for several business functions. In relation to some of those functions, SQW will be the Controller of your personal data. This may include where we collect personal data to enter contracts, to respond to your queries or concerns, or in relation to personal data we collect as part of our recruitment activities.
Where your personal data has been provided to us by a third-party to enable us to provide a service to them, SQW will be the processor of that data and the Data Controller will be our client who has provided us with your data. If your data is being collected and processed for research purposes, please note that our clients are the Data Controllers and are responsible for executing your data subject rights related requests. SQW, as a Data Processor, will liaise and cooperate with them to fulfil such requests.
9. How we use cookies and similar technologies
Like any other website, SQW uses 'cookies'. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise the users' experience by customising SQW’s web page content based on visitors' browser type and/or other information. You can disable cookies through your individual browser options.
SQW also uses log files. It follows a standard procedure of using log files. These files log visitors when they visit websites. All website hosting companies do this. The information collected by log files includes 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.
10. What happens if the ownership of SQW changes?
SQW may, from time to time, expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of the firm. Any personal data that you have provided will, where it is relevant to any part of SQW that is being transferred, be transferred along with that part of the business. The new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data for the same purposes for which it was originally collected by the firm.
11. Your Rights in relation to your personal data
How can you access your data?
You have the right to know if SQW processes your personal information and ask for a copy of any of your personal data held by the firm. Under the DPA 2018 and the UK GDPR, no fee is payable, except where an exemption applies. An exception may apply where the request is manifestly unfounded and excessive or further copies of the data provided is being requested. In all other circumstances, SQW will provide all relevant information in response to your request free of charge. Your data rights are set out below. Should you wish to exercise any of your data protection rights please contact us by sending an email to: dpo@sqwgroup.com.
Your right to withhold information
You may access certain areas of the SQW website without providing any data at all. For certain services provided by us, you may be required to provide your contact details to assist us in responding to you. You may decide to withhold such information but doing so may affect what services we are able to provide to you.
Your right to be forgotten
SQW only collects data when there is a legal basis 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:
- the firm no longer needs to process your information for the purposes for which it was provided
- the firm has requested your permission to process your personal information and you wish to withdraw your consent
- the firm is not using your information in a lawful manner
- you have objected to your data being processed.
Please note that if you request the deletion of your personal data, we may have to suspend the provision of our services or products to you.
Should you wish to make a request, for the deletion of your data, you may contact SQW by sending an email to: dpo@sqwgroup.com.
Your right to have data rectified
If you believe that any of the information that SQW holds about you is inaccurate or out of date, you have a right to request that the firm restricts the processing of that information and to rectify the inaccurate personal information.
Please note that SQW is required by law to ensure the accuracy of its data. SQW therefore, proactively cares about the quality of the personal data it holds and may contact you periodically to verify your information to ensure that our personal data records are up-to-date and accurate.
Your right to data portability
You may request SQW to transfer your data to a third-party in a machine-readable format where the:
- personal information was provided on the basis of consent
- processing is by automated means
- processing is based on the fulfilment of a contractual obligation.
12. How long do we 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
- Any other data are kept for as long as is required by applicable law, or deleted or destroyed when no longer required.
13. How you can contact us
Should you have questions concerning your personal information or any questions on our use of your personal data, you may direct your concerns in the first instance to our Data Protection Officer Darren Boyd-Annells at: dpo@sqwgroup.com.
14. Your right to complain
If you have a concern about any aspect of SQW’s privacy practices, including the way it has handled your personal information, you may complain to our Data Protection Officer Darren Boyd-Annells at: dpo@sqwgroup.com.
You are also entitled to complain to the Information Commissioner Office (ICO). We hope that before you do so you would afford us an opportunity to resolve your concern. However, should you feel the need to complain to the ICO, their contact details are provided below:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
15. How we update this Privacy Policy
SQW reviews this Privacy Policy on a regular basis (for example, if the law changes and annually). Any changes will be immediately posted on SQW's website, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the site following the alterations. SQW recommends that you check this page regularly to keep up-to-date and to make sure that you are happy with the changes.