Privacy Policy

Thank you for showing interest in Emma Rose R&D, data protection and your privacy is important to us.

SCOPE

This privacy policy applies to the collection and use of research participant, client and Emma Rose R&D website visitors’ personal data by Emma Metcalfe R&D.

This page is intended to keep you informed about what we do with the personal data we process, your rights and how you can exercise them.

The use of the Internet pages of Emma Rose R&D is possible without any indication of personal data. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, company name, or e-mail address, of a data subject shall always be in line with the General Data Protection Regulation (GDPR). By means of this data protection declaration, We would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As a sole trader operating as the controller and processor of personal data we have implemented technical and organisational measures to ensure the most complete protection of personal data processed through this website. However Internet based data transmission may in principle have security gaps, so absolute protection may not be guaranteed. Emma Rose R&D is regulated by the General Data Protection Regulation (GDPR) and is registered with the Information Commissioners’ Office.

Any changes we may make to our privacy policy in the future will be posted on this page.

Updated on 21st January 2022—version 1

DEFINITIONS

The data protection declaration of Emma Rose R&D is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, among others the following terms:

a. Personal Data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b. Data Subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c. Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d. Restriction of Processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e. Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements

f. Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g. Controller or Controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h. Processor

Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i. Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j. Third Party

Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k. Consent

Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which she or he, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to her or him.

1. NAME AND ADDRESS OF THE CONTROLLER

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Emma Metcalfe

Trading as Emma Rose Research and Design (R&D)

emma (at) emmarose.cc

further described as “we.”

2. PERSONAL INFORMATION WE COLLECT, HOW WE COLLECT IT AND WHO FROM

a. Personal Information you provide when visiting our website

When you visit our website we collect some information about you to help us run the site.

Information is collected in three or four ways:

Automatically in our server logs, to help us keep the site reliable and secure. This includes your IP address and browser type, and which pages are visited.
If you give your consent, using Google Analytics to help us improve the content and design of the website. This also includes IP address, browser type and pages visited, along with some extra information about the technology you use. We don’t use it to gather demographic information.
We use cookies to record whether you consented to our use of analytics, and if you did consent then cookies are used to gather the data. The website is hosted by one.com and their data policy can be found here.(https://www.one.com/en/info/privacy-policy)
The website contains options that enable a quick electronic contact, as well as direct communication with us, which may also include a general e-mail address. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

b. Recruiters

Once decided what kinds of participants we need to do research with, we may present an independent recruiter with the criteria. They will then recruit people to our specifications via a range of methods including email, social media and sign up through their website. We will be sent this information about our respondents in the form of a password protected spreadsheet.

We always ensure the recruiters we work with uphold the same data standards that we do.

c. Research participants

We work internationally, conducting ethnographic research for our clients. We are conscious that the work we do gives us extremely privileged and up-close access to the people we work with. That is why we put respect for individuals, privacy, data protection at the core of our work. A participant first approach.

The primary way we collect research data is through face-to-face ethnographic fieldwork. When we conduct research, we do home visits and activities with respondents where we take photos, videos and notes. What we use this data for will always be clearly stipulated in consent forms it may for example also include presentations to clients, promotional material, process development and other internal uses.

Sensitive/special categories: from time-to-time, and dependent on the needs of particular projects, we collect data about research participants that we deem particularly sensitive. For example: Ethnicity, Religious views, Health information.

We only collect this data when we have participant consent. When we undertake a project likely to produce this kind of data we will always conduct an impact assessment dealing with the particular risks and precautions we will take over the course of that work.

We never allow clients to use research respondent data for any other purpose without the express permission of the respondents involved.

d. Clients

From potential and existing clients: we collect personal data from our clients to create and manage client relationships, and to carry out projects. This will usually include full names, email address, phone number, company address and job titles. Such personal data is stored in encrypted, cloud-based email platforms such as Google Mail.

Upon request from our clients, this data will be securely deleted after a project has been completed.

When we conduct research, we sometimes take photos, videos and audio recordings of clients who take part in fieldwork and home visits. Upon request, this data can be securely deleted after a project has been completed. Clients can do this by emailing Emma Metcalfe.

e. Suppliers

We collect contact details and payment information from suppliers and partners in order to work together. We always review suppliers’ privacy policies, and where appropriate we sign data sharing agreements.

3. WHO WE SHARE RESEARCH DATA WITH

In the practice of research projects participant data is likely to be used and shared with the following:

a. Clients

We’re enlisted by companies to conduct research, with voluntary participants to advise them on strategy. The research material we collect will be used in presentations and may be used in other internal communications such as videos and posters. These are often circulated company-wide. We also upon request may also share anonymised transcripts with our clients.

b. Delivery partners

To help deliver a project, we ocassionally work with third-party partners. For example, we may send audio of the research session to a transcriber or share video with a filmmaker. We review the privacy notices of the companies we use for this.

4. OUR LEGAL BASIS FOR COLLECTING DATA

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. We reassess our legal basis for collecting data with every project.

Our default justification beyond Art. 6(1) lit.a GDPR for data collection is Art. 6(1) lit.f GDPR ‘legitimate commercial interest’. We are a sole trader that provides recommendations to commercial clients based on human insights. This requires us to collect a range of data from consenting research participants.

We also collect data from our and potential clients, employees and people interested in working with us, and suppliers in order to carry out our business.

We have adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues including where deemed necessary new Data Protection Impact Assessments. (DPIA)

If you’d like to see our Legitimate Impact Assessment (LIA) please send an email to emma (at) emmarose.cc We’ll be happy to provide you with a copy.

5. HOW WE KEEP DATA SAFE AND CONFIDENTIAL

We take a number of measures to keep the data we collect secure and ensure we follow ICO training on data protection practices. We take measures to ensure that third party suppliers and research partners who we share confidential data with and who share data with us, comply with our data protection and privacy policies.

In the case of research participants, we only use participant’s real first names when arranging the research session and any follow-up activities. We use a pseudonym for participants in all the research material and in all file names. We anonymise to the extent at which this is possible transcripts, removing personally identifiable information mentioned during the course of the research such as names, where the participant lives, their place of work.

We encrypt all personally identifiable data. We receive and share all personally identifiable data through secure, encrypted cloud services and store it on password protected cloud services such as Google Drive.

We regularly review how we process confidential data. We regularly review the personally identifiable data we hold in order to check whether we still need it, and if not, we delete it using a secure deletion tool.

6. ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

We delete research participant information such as names and contact details, at the end of a project. We keep videos, audio, personally identifiable images and consent forms for up to 1 year after a project is completed so that we and our clients can use it in reference to the project. At the end of this retention period we delete them using a secure deletion tool.

If research participants have given explicit consent for their information to be used for marketing purposes we will keep videos, audio, personally identifiable images and consent forms for up to 5 years. At the end of this retention period we delete them securely.

We may keep anonymised transcripts, notes and images that are not personally identifiable indefinitely.

We keep contact information for clients, suppliers and partners indefinitely as we often work with them again. Clients, suppliers and partners can contact Emma Rose R&D if they would like to delete their information.

7. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

8. TRANSFERRING DATA OUTSIDE THE EEA

At times projects require us to transfer data outside of the European Economic Area, as our clients and research projects are global. We’ll always have an agreement in place with the extra party ensuring their policies live up to our legal obligations and high standards of data protection.

We also work in countries outside “adequate rated” areas. In these instances, we will conduct extra due diligence on the companies we work with. If we are not entirely convinced that they will be able to meet our standards for data protection we will not work with them.

Due diligence may include:

A phone call or face to face conversation to address any concerns we have
A rigorous assessment of that company’s previous work
A site visit to the company headquarters
Extra contractual obligations placed on the company

9. RIGHTS OF THE DATA SUBJECT

Each data subject shall have the right granted by the European legislator and the General Data Protection Regulation to obtain from the controller the confirmation as to whether or not personal data concerning her or him are being processed. If a data subject wishes to avail herself to himself of this right of confirmation, she or he may, at any time, contact any employee of the controller.

a. Right of confirmation

b. Right of Access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about her or his personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information for the purposes of the processing:

the categories of personal data concerned;

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail herself or himself of this right of access, he or she may, at any time, contact the controller.

c. Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning her or him. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, she or he may, at any time, contact any employee of the controller.

d. Right to erasure - the "right to be forgotten”

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning her or him without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Emma Rose R&D, she or he may, at any time, contact the controller. We shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

e. Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, she or he may at any time the controller.

f. Right to data portability (transfer of data)

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning her or him, which was provided to a controller, in a structured, commonly used and machine-readable format. She or he shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising her or his right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact Emma Rose R&D.

g. Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to her or his particular situation, at any time, to processing of personal data concerning her or him, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Emma Rose R&D shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

The data subject has the right, on grounds relating to her or his particular situation, to object to processing of personal data concerning her or him by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact us. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use her or his right to object by automated means using technical specifications.

h. Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw her or his consent to processing of her or his personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, she or he may, at any time, contact us.

10. THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to us.

A. Data protection provisions about the application and use of Google

In order to communicate with individuals externally and with client teams or internally, we use services (such as Gmail, Google Drive, and Google Sheets). Google INC is an American multinational technology company that specializes in Internet-related services and products, which include online advertising technologies, search engine, cloud computing, software, and hardware.

The operating company of Google is Google INC, 1600 Amphitheatre Parkway, Mountain View, CA, UNITED STATES.

The applicable data protection provisions of Google may be accessed under https://policies.google.com/privacy.

B. Data protection and provisions about the application and use of one.com

One.com is a Danish private company that provides software as a service for website building and hosting. We use this service to provide hosting and management of our website.

The applicable data protection provisions may be accessed under https://www.one.com/en/info/privacy-policy

11. AUTOMATED DECISION MAKING

As a responsible human insights practitioner, we do not use automatic decision-making or profiling

12. CHANGES TO THE DATA PRIVACY POLICY

If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. Changes and clarifications will take effect immediately upon their posting on the website.

Questions and contact information

Questions, comments and requests regarding this privacy policy are welcome. For more information contact: emma (at) emma rose.cc