Equiniti Limited (EL) Privacy Notice
We understand how important your personal data is and are committed to protecting and respecting your privacy.
‘Personal data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers (such as an account number), location data or online identifiers. Personal data can be held electronically or in certain paper records.
This notice explains:
- Who is responsible for your data
- Products and services covered by this Privacy Notice
- How your personal data is collected
- Why your personal data is collected
- How long personal data is held
- The conditions under which we can share it with others
- Overseas processing
- How your personal data is kept secure
- Your personal data rights and how to exercise them
- Useful information and
- Any further questions
1. Who is responsible for your data
Equiniti Limited (EL) collects anonymous information through questionnaires about the quality of service you have recently received. No personal information is required to be provided in order to complete the questionnaires.
We offer these questionnaires on the instructions of Data Controllers with whom you already have an existing relationship with for example:
- If you hold ordinary shares in certificated form, the company you hold shares in is your data controller
- If you hold shares via a nominee company, the nominee company is your data controller
- If you are a member of a pension scheme, the Pension Trustee is the data controller
If you provide information as part of the questionnaire which identifies you and requires a response, your existing data controller will remain responsible for the processing of your personal data.
Any incentives that may be offered in relation to the completion of the questionnaires will clearly indicate who is offering the incentive.
Equiniti Limited (EL) is one company within the Equiniti Group. Our main business is administration services. Our registered address is Aspect House, Spencer Road, Lancing, West Sussex, BN99 6DA and our ICO registration number is: Z1028602.
If you have any questions about this questionnaire service please contact the Customer Insight team at email@example.com; via telephone on the number you originally contacted us on or in writing to : Customer Insight, 1st Floor East, Highdown House, Worthing, West Sussex BN99 3HH and we will respond to your query within 5 working days.
2. Products and services covered by this Privacy Notice
This notice applies to our questionnaires issued via paper, telephone or online using SmartSurvey together with any related incentives that are offered in relation to questionnaire participation.
3. How your personal data is collected
The following personal data about you may be collected and processed:
Information you provide to us
- As part of completing the questionnaires
- Through entering competitions and other incentives
- When you report any problem or complaints about our questionnaires
Information we collect about you when you use our services
- Voice recordings of your communications with us for quality control, training, security and regulatory purposes, but these can also capture your location i.e. use of home landline number
Information we receive from your data controller
- In order to respond to your enquiries
- To select you for questionnaire participation
Special types of data – The law and other regulations treat some types of personal information as special.
- Criminal convictions and offences
- Genetic and bio-metric data
- Health data including gender
- Racial or ethnic origin
- Religious or philosophical beliefs
- Trade union membership
Please do not include this information as part of our questionnaires.
Other people’s personal data
If you provide us with information about another person, you confirm that they have appointed you to act for them, they consent to you providing their personal data to us and any processing of their personal data and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice.
4. Why your personal data is collected
In the table below we demonstrate why and how we use your personal data (only if you provide it) as well as providing the legal reasons which are relied upon.
Under Data Protection legislation there must always be a legal reason for processing your personal data.
Any personal data that you supplied is considered to be provided with your consent or because there is a legitimate business reason for the personal data to be collected, however, this must always be balanced against your interests to ensure that the use is fairly balanced.
Our legitimate interests are the proper administration of our service and business for example:
- Keeping accurate records
- Defining types of customers for new products and services
- Seeking your consent when we need it to contact you
- Operating efficiently
- Enabling and monitoring the use of our website and services
Why your personal data is used
How your personal data is used
Prize draws and incentives to complete our questionnaires
To administer any prize draws that you are offered and elect to enter as an incentive to complete our questionnaire
Improving our products and services
· To identify service improvements such as when troubleshooting, undertaking data analysis, testing new products, using your personal data for research, statistical and questionnaire purposes
· To ensure that content from our websites are presented in the most effective manner for you and for your device
· To develop and manage products, brands and services and to calculate how to structure any fees and charges
· How we manage and work with other companies in the delivery of your products and services
· To study how you and our other customers use products and services
5. How long your personal data is held
Personal data will not be retained for longer than necessary to achieve the purpose for which your personal data was obtained. We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.
The provision of the questionnaire and incentives are subject to a retention period of three months, for the reasons noted below:
- To respond to enquiries
- To use the feedback you provide effectively
- To maintain records to meet rules and regulatory requirements that are applicable to the administration of incentives
We can keep your data for longer than three months if we cannot delete it for legal, regulatory or technical reasons. We can also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
For full details of our retention policies, please contact us.
6. The conditions under which we can share your personal data with others
The personal information you provide to us is confidential and we will only share it to enable the delivery of your product(s) or service(s), examples are as follows:
- At your request, or with your consent
- With the Data Controller of the product or service that your questionnaire response relates to, or their appointed agent(s)
Non Equiniti entities, such as our agents in connection with running the questionnaire or incentives for you, including service suppliers to facilitate email, IT, web and administration services.
We only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this policy.
Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.
We are also required to share your personal data with external third parties as follows (but not limited to):
- Where the law requires or permits disclosure, or there is a duty to the public to reveal it
- We can transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. At all times, we take steps to ensure your privacy rights continue to be protected as per this Privacy Notice.
7. Overseas Processing
Any personal data you supply as part of completing our questionnaires will be processed in the United Kingdom. Please note that information protection laws do vary from country to country. In particular, the law of the country in which you are resident or domiciled may offer a higher standard of protection than the laws in the United Kingdom
8. How your personal data is kept secure
We understand how important your personal data is to you and we take appropriate steps to ensure that it remains secure.
We safeguard your personal data across all our computer systems, networks, websites, and offices as much as possible through appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) and our Information Security policies are aligned to ISO27001, which is an internationally recognised security standard.
We also use secure ways of communicating with you such as when collecting your personal data online through the use of ‘‘https’’ and other security and encryption protocols. This is indicated by a lock icon on the bottom of the web browser, or the address will include the letters https in the top left-hand corner.
If you ever receive a communication from us by post, email or by phone that you are concerned it is not genuine, please contact us using the contact details in section 1.
You must immediately inform us if you become aware, or suspect, that someone else has knowledge of your account details. Do not use our questionnaires to advise us of this information.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of Get Safe Online, which can be accessed at www.getsafeonline.org.
9. Your personal data rights and how to exercise them
You have rights in respect of the personal data held about you by data controllers. They include the right to request a copy of the information is held about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time. Details about all of your rights are provided below.
The right to be informed about how we use your personal data.
The right of access to a copy of any personal data processed about you, together with certain additional information.
The right to request your personal data is rectified or updated.
The right to request the removal of your personal data..
The right to request the restriction of processing your personal data.
The right to request a copy of your information for data portability purposes.
The right to object to the processing your personal data.
Rights related to decisions based solely on automated processing.
Right to lodge a complaint with a supervisory authority. If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection team who will investigate the matter and report back to you.
If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country. In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation. They can be contacted by email: firstname.lastname@example.org; post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; or by telephone: 0303 123 1113.
10. Useful information
10.1 - Children (16 years and under) and Vulnerable Adults
We are committed to the privacy protection of children and vulnerable adults. If you are aged 16 or under‚ and you wish to provide personal data you must obtain the permission of your parent/guardian before you share your personal data with us. If we are notified that you are a vulnerable adult we will liaise with your authorised representative, once we are in receipt of the appropriate permissions.
Cookies are text files placed on your computer to track visitor use of the website and to compile statistical reports on website activity. This helps us to improve our website and deliver a better more personalised service.
10.3 - Links to other websites
Our websites contain links to other websites run by other organisations, or other Equiniti companies. This Privacy Notice applies only to the SmartSurvey website, where the link appears. When you are on another website, we encourage you to read their privacy statements as it will take precedence over this Privacy Notice.
We are not responsible for the privacy policies and practices of other sites.
10.4 - Social media, blogs, reviews, and similar services
Any social media posts or comments you make to us (e.g. on our own Facebook page) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they are made and could be made public by that platform. These platforms are controlled by other organisations, and so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you are unhappy about it.
Any blog, review or other posts or comments you make about us, our products and Services on any of our blog, review or user community services will be shared with all other members of that service and the public at large.
You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
10.5 - Changes to this policy
We review our questionnaires and the use of personal data regularly. In doing so, we can change what personal data we request, how we keep it and what we do with it. As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.
We will endeavour to alert you to these changes so that you can check you are happy with it before proceeding any further. Please look out for notices from us alerting you to these changes, via our websites or other timely communications. If you use our website and see such an alert, please take a moment to ensure that you’re happy with any changes.
By completing our questionnaire and participating in our questionnaire incentives you will be bound by this Privacy Notice.
However, we will also tell you of the changes where required by law to do so.
This policy was issued September 2019. If you require copies of previous versions of our Privacy Notice, please contact the Data Protection Officer using the contact details noted below.
11. Any further questions about this Privacy Notice
We hope that this Privacy Notice has been helpful in setting out how we handle your personal data and your rights to control it. If you have any questions, please visit our Customer Privacy Centre or contact our Data Protection Officer:
- Online at privacy.equiniti.com where you will find general information about your rights and how Equiniti safeguards your data
- By email at DPO@equiniti.com
- By post at Data Protection Officer, Equiniti, Highdown House, Yeoman Way, Worthing, BN99 3HH or
- By telephone UK: 0333 207 5962 International: +44 121 415 0196
Lines are open 8.30am to 5.30pm (UK time), Monday to Friday (excluding public holidays in England and Wales).