We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
This privacy policy and our website are intended for 18+ individuals only.
The privacy policy applies to the processing of personal data by Research in Finance for: 1) website users; 2) clients engaging our consultancy services; and 3) our survey participants. Please see ‘How and why we use your personal data’ below which breaks down the personal data processing for each element of our services.
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Research in Finance Limited of 80 Coleman Street, London, EC2R 5BJ, registered in England with company number 08441324 and ICO registration number ZA120530. | |
| Contact details | By email: [email protected]
By post: FAO Data Protection, 80 Coleman Street, London EC2R 5BJ |
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| Personal data | Any information relating to an identified or identifiable individual | |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
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| Data subject | The individual who the personal data relates to |
The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you depending on the service you interact with.
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
Under data protection law, we can only use your personal data if we have a proper reason, eg:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will, where required by law, carry out an assessment when relying on legitimate interests to balance our interests against your privacy rights to make sure your rights are fully respected.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons | |
| Providing our products and services to you | To perform our contract with you or to take steps at your request before entering into a contract | |
| Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us | |
| Conducting checks to identify our customers and verify their identity
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator |
Depending on the circumstances:
—to comply with our legal and regulatory obligations —for our legitimate interests |
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| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
—to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
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| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations | |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures | |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price | |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances:
—for our legitimate interests, ie to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations |
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| Statistical analysis to help us manage our business, eg in relation to market and industry and analysis and trends and to improve our offerings in the financial service sector | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you | |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances:
—for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations |
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| Protecting the security of systems and data used to provide our services | To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
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| Updating and enhancing customer records and our lead data | Depending on the circumstances:
—to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, |
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| Statutory returns | To comply with our legal and regulatory obligations | |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances:
—to comply with our legal and regulatory obligations; —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
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| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
—to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
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| To undertake market research | Depending on the circumstances:
– with your consent – where it is in our legitimate interest or that of a third party to contact you regarding a survey |
More details about how we use your personal data and why are set out below:
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR | Relevant categories of personal data | |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, ie:
—the UK GDPR or Data Protection Act 2018; |
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number and company details;
—your account details (username) |
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| Addressing and sending communications to you as required by applicable law | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | – Your name, address and contact information | ||
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number and company details.
—your account details (username) |
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| Personal data associated with you when you fill in one of our surveys to undertake market research, and keeping your details within our CRM system | We analyse this data for market research purposes on our own behalf or on behalf of our third party partners in the financial services industry. | Consent – our surveys are completely optional
Legitimate Interests – we send survey requests on the basis of legitimate interests and store your details on our CRM following your survey activity, having given you an opportunity to opt out. Analysis – we analyse and share survey results on the basis of legitimate interests – please see More Information below. |
Name
Basic contact details (email) Place of work/industry Answers to the survey affiliated with your account. |
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| Social media data through our interactions | We keep records of emails, social media posts and other electronic messages sent and received between you and us so that we can properly communicate with you. | We believe it is appropriate to keep records of our communication with you as they may be required in the future for legal purposes. | Name
Social Media Handle Any data you choose to provide associated with your account |
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| Attending events | When you register for an event you will be asked to confirm that we can pass your contact details to the speakers on the day, so they can provide you with more information on their companies’ products and services. They may contact you directly and their use of your data will be governed by their own privacy policy. Events may attract additional sponsors after the date you have signed up to attend, but all sponsors will be identified on the event programme in advance. You are welcome to withdraw this consent at any time before the event. If you are unable to attend an event you are interested in we may contact you regarding future events in the same area or on the same theme. Please note if the event is a webinar and you watch a webinar on catch up post event you may also be contacted by speakers/sponsors of that webinar. | Consent | Name
Contact details (email, telephone number, LinkedIn) |
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| To compensate you for taking part in a survey (where reimbursement forms part of the survey request) | We will store your BACS details to be able to make payment to you, or sometimes your email details if you are due an e-voucher, or a postal address if you are due a voucher. | Performance of a contract
Legitimate interests |
Name
Account details Email address Postal address |
You may hear from us with a survey request, by email, phone or LinkedIn. This may contain further details on that particular survey and the data we collect. We do this sometimes for industry research purposes and sometimes for a specific research task on behalf of our financial services or other industry client. Our interest in performing such research projects and processing the information you provide us with is to generate valuable insights for our clients. Your responses may form part of future research projects, for example to see how people’s opinions change over time. If you attend a survey in person, for example in a focus group, you may be asked to sign an agreement related to your privacy rights. We do not share your personal data with our clients, rather we first anonymise the results and provide anonymised and/or aggregated data.
This is market research so is treated differently to ‘marketing’ under data protection laws, so we do not always need consent to contact you. We do this on the basis of legitimate interests, however our surveys are completely optional and you can opt out of hearing from us about survey requests at any time. Please note that any withdrawal of consent will not affect any survey responses previously given and used in accordance with this Privacy Policy.
Where you are due a payment or voucher for undertaking a survey we will also take your name and BACS details, and contact/delivery details to be able to make that payment or deliver a voucher to you. If we recompense you for the time taken to, for example, fill in one of our surveys, we will keep records of your name and contact details and confirmation that correct payment has been made. If you choose not to provide us with this information, we will not be able to recompense you.
Please note the terms set out on each individual survey invitation or introduction page. For example our policy will be to only recompense fully considered and completed surveys and only one response will be accepted per person. Only the person explicitly invited to the survey will also be recompensed. We do not accept responses from surveys that may have been forwarded on. Recompense will always be at our discretion and we do check each response for validity including monitoring of IP addresses should we believe multiple surveys have been taken by one person.
If a reimbursement remains unclaimed for more than 2 years Research in Finance reserve the right to reissue that reimbursement to another survey respondent.
If you do have a friend/colleague that also wishes to participate in a study you have been invited to please email their details to: [email protected] and we can send a link to them. By providing a third party’s email address to confirm that you have permission to share it and for us to contact that individual for the purposes of the survey.
You can see more about our market research here.
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
In the context of our surveys this includes certain special category like disability information which we collect as part of the surveys to perform market research.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by:
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
We routinely share personal data with:
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA.
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, in line with statutory limitation periods.
If you no longer have an account with us or we are no longer providing goods or services to you, we will usually delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data. When we anonymise your data, we may then retain it for a longer period for statistical purposes, service improvement and industry market research given you can no longer be identified from the information.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available), for example legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data | |
| Rectification | The right to require us to correct any mistakes in your personal data | |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations | |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data | |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations | |
| To object | The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims | |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you | |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO).
If you would like to exercise any of those rights, please:
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator). Please see www.ico.org.uk for more details.
We may change this privacy notice from time to time by updating this notice on our website. If you are a customer, any changes which significantly affect your rights will be shared via email.
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’. You can also update your personal data yourself via our website/portal where you are a customer.
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details for data protection queries |
| By email: [email protected]
By Post: FAO Data Protection, 80 Coleman Street, London EC2R 5B |
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
