Discover Uni user research: Privacy notice
Fluent Interaction are conducting user research on behalf of Office for Students (OfS) to test aspects of the Discover Uni website – discoveruni.gov.uk. The research will begin in 2020.
Fluent Interaction and the Office for Students (“OfS”) are joint data controllers for the research and are responsible for determining how personal data collected during the period will be treated. All research will be conducted within appropriate Market Research Society guidelines.
The OfS funds and regulates universities and colleges in England and also undertake projects on behalf of other funding bodies which will affect the UK as a whole. You can find more information about OfS on their website: www.officeforstudents.org.uk
For more details about the specific research session you may be taking part in, you can refer to the information sheet and consent form provided when you’re invited to take part in the research. This should also include contact details for the researcher in case you have any further questions.
Data we collect from you
When inviting you to take part
The personal data we collect from you at this stage could include: name, age, gender, ethnicity, disability, details of any condition that can affect your ability to use a computer, occupation, email address, phone number.
We may collect additional information, based on the specific topic being researched. For example, we might want to know whether you’ve used this service in the past.
During the research session
In most cases, we’ll collect personal data during the research session. This could be in the form of audio recordings, video recordings, screen recording, and written notes.
We sometimes use external organisations to book a venue for the research outside of our offices, and external tools to conduct remote research sessions. This means that a limited number of staff in other organisations may have access to your data. For example, when we use the recording equipment at an external venue.
If we do any of this, we will monitor and limit the access that people outside Fluent Interaction have to your data. The privacy policies of these external organisations will also apply.
Our legal basis for using your data
Under data protection legislation, we require a legal basis to be able to process your personal information for the purposes set out above.
We require an additional legal basis for processing special category data, such as ethnicity. Our additional legal basis is under Article 9(2)(a) of the GDPR, where the individual has given explicit consent to the processing.
Why we need your data
We need information about you when inviting you to take part to ensure that you meet the criteria for this piece of research, and that we are including a suitable range of people.
We need to collect data during the research session to ensure that we have an accurate record of what happened and what was said. This is important, because we then analyse this information and use it to draw conclusions about what we should do next.
What we do with your data
We will use the results of the user research to:
- Review and understand how well the Discover Uni website and related digital services meet the needs of users
- Design, develop and refine aspects of the Discover Uni website
- Design and create content that will help people effectively use the Discover Uni website
We will not:
- sell or rent any of your data to third parties
- share your data with third parties for marketing purposes
We will share your data if we’re required to do so by law. For example, by court order, or to prevent fraud or other crime. We will also share your data in the event of a serious safeguarding concern. For example, if we are concerned about the welfare of a child or vulnerable adult.
When using your responses in reports or presentations, we will make appropriate efforts to anonymise your data so that you’re not identifiable. Your name will never be used.
Only researchers working at Fluent Interaction and project team members at OfS will have access to the full original recordings, although we may share short audio or video clips with other colleagues for training, presentations and similar activities if we have your express permission to do so.
As your personal data will be stored on our IT systems it will also be shared with organisations that provide our email, document management and storage services (for example, Google).
How long we keep your data
The data collected when we invite you to take part will be held for a maximum of 24 months. After this point, we will delete this.
We will hold the data from research sessions, your name, and a record of consent for a maximum of 2 years. After this point, we will delete all personal data relating to you, but we might retain reports that contain your anonymised quotes and short audio or video clips with other colleagues for training, presentations and similar activities if we have your express permission to do so.
Where your data is processed and stored
Your personal data may be transferred outside the European Economic Area (EEA) while being processed by Fluent Interaction. If this happens, we’ll make sure you’re given the same level of technical and legal protection as you are within the EEA through Model Contract Clauses or US Privacy Shield.
Who we share your data with
Your personal data may be shared with a limited number of people in other organisations outside of Fluent Interaction or OfS, as described above.
Reports containing anonymised findings may be shared beyond the project. For example, with UK FE funding bodies or other organisations that we are working with.
How we protect your data and keep it secure
We are committed to doing all that we can to keep your data secure. We have set up systems and processes to prevent unauthorised access to or disclosure of the data we collect about you. For example, we protect your data using varying levels of encryption.
You have the right to withdraw consent to the processing of your personal data – for example original recordings and notes where you can be identified. If a report with anonymised quotes has been published (internally or externally) we will not be able to remove this as it does not constitute personal data.
You also have the right to request:
- information about how your personal data is processed
- a copy of that personal data
- that this copy be provided in a structured, commonly used and machine-readable format
- that anything inaccurate in your personal data is corrected without delay
- that your personal data is erased if there is no longer a justification for holding it
- that the processing of your personal data is restricted in certain circumstances (for example, where accuracy is contested)
If you have any of these requests, please contact us using the details in the information sheet provided to you, or the contact details listed below.
Questions and complaints
If you have questions about research that you’ve been invited to participate in, you can contact the researcher named on the information sheet provided to you.
Contact Fluent Interaction if you:
- have any questions about anything in this document
- think that your personal data has been misused or mishandled
- want to make a subject access request (SARS)
The data controller for your personal data is Fluent Interaction. The contact details for our Data Protection Officer are:
Data Protection Officer
Fluent Interaction Ltd
6a-7a Albemarle Way
London EC1V 4JB
You can also complain to the Information Commissioner, who is an independent regulator.
Information Commissioner’s Office
Contact form: ico.org.uk/global/contact-us/email
Telephone: 0303 123 1113
Textphone: 01625 545860