Return Research respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data if you are:
a respondent to any poll, survey or questionnaire we carry out;
a client or a representative of a client;
a supplier, or professional or business contact of Return Research;
a visitor to our website (www.returnresearch.co.uk),
and otherwise when we interact with you.
1) ABOUT US
Return Research (collectively referred to as "Return Research", "we", "us" or "our" in this privacy notice) is the trading name of Return Marketing Limited. We are a company incorporated in England with company number 08271538. Our registered address is Unit Lg07 22 Highbury Grove, London, England, N5 2EF.
We are registered with the Information Commissioner's Office – registration reference Z3436483.
We have appointed a Data Protection Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Manager as follows:
Address: Unit Lg07 22 Highbury Grove, London, England, N5 2EF
Email address: firstname.lastname@example.org
2) WHAT DOES RETURN RESEARCH DO?
Return Research conducts telephone opinion polling, voter identification, omnibus surveys and other telephone campaign services, mainly to political parties or other organisations.
In most cases, when performing our services, we act as a processor. This means that we collect personal data from respondents for and on behalf of our clients. In these cases, our client is the controller and the person responsible for deciding how and when a respondent’s personal data is collected and used. We are legally required to follow the instructions of our client.
Our client’s privacy notice will set out how a respondent’s data is used, and for how long it is stored.
We maintain a record of respondents who we have called, and we will act as a controller of those records. We are also a controller when we collect information from suppliers and other third parties who interact with us.
3) THE PURPOSE OF THIS PRIVACY NOTICE
The purpose of the remainder of this privacy notice is to set out how we use your personal data when we act as a controller.
4) THE DATA WE COLLECT AND HOW WE COLLECT IT
The data we collect
Depending on your relationship with us (for instance, whether you are a respondent to one of our telephone surveys, or a supplier), we collect, use, store and transfer some or all of the following data:
Identity and Contact Data: personal and identity data, including your name, postal address, email address and telephone numbers;
Transaction Data: details of services you provide to us or we provide to you;
Call Data: Where we make a telephone call to you, we retain a record of the fact we called you, including your name, contact address and contact number and the outcome of the call, for example that you have participated in a survey. We do not keep a record of your call responses;
Financial Data: bank account details which you provide to us as a supplier;
Technical Data: information we collect automatically when you visit our website, including your IP address, browser details, and device details;
Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
Can you withhold your data?
You can withhold your data from us if you wish, but where we need this to supply services to you as a client or engage you as a supplier, we may not be able to do so.
Where you are a call respondent, we will have been provided with your details from our client or a third party source, and will continue to hold the details to show that we have contacted you.
Where we collect your data from
We may collect your data from different sources:
We collect all of the types data listed above directly from you when you interact with us.
We collect your name, address and contact details from our client and/or a third party suppliers of contact database information, and/or publicly available databases.
We collect Technical Data automatically when you interact with our website, by using cookies and other similar technologies.
5) HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Where we collect your data on behalf of our client as a processor, we may transfer that data to our client. Our client is responsible for how that data is used. This privacy notice only concerns data we collect or maintain for our own purposes as a controller.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law.
We will not use your personal data which we hold for our own purposes, for marketing purposes.
Cookies when using our website
When you click through to other websites from our site, those websites may place cookies on your device or collect data from you. We are not responsible for the activities of the provider of any third party website.
6) DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above:
Service providers based within the UK or wider EEA who provide IT and system administration services, or who store documents on our behalf, or our sub-contractors/
Our professional advisers including lawyers, bankers, auditors and insurers based in the UK or EEA who provide consultancy, banking, legal, insurance and accounting services.
The Information Commissioner’s Office (ICO), and other authorities based in the UK who require reporting of our processing activities in certain circumstances.
Company administrators and liquidators;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7) INTERNATIONAL TRANSFERS
We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government or the ICO; or
using specific contracts approved by the ICO which give personal data the same protection it has in the UK.
8) DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For more details of our specific retention periods, please contact our Data Protection Manager.
9) YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Protection Manager.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Complaint to the ICO
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your legal rights
Your legal rights are as follows:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances.
Request the transfer of your personal data to you or to a third party.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Version 2.0 January 2024