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Privacy Policy

(For Business)


The Grafton Suite Ltd trading as GRO Fieldwork

Effective Date:  7th May 2018

1             Contents

2             Introduction      

3             Purpose 

4             Application          

5             General Data Protection Regulation (GDPR)           

6             Rights of Individuals         

7             Handling personal information, lawfully, fairly and transparently    

  1. Consent for respondents 
  2. Consent for Marketing and Prospecting Purposes 
  3. Computer Equipment, Security and updates 
  4. Removable Media 
  5. PECR and cookies 
  6. Staff Training 
  7. Fair treatment 
  8. Minimum amount of personal data 
  9. Accurate and kept up-to-date 
  10. Subject Access Requests 

17           Requests for information from law enforcement agencies

18           Data security and reporting of breaches 

19           Outsourcing 

20           Restrictions on transferring information to non- EEA countries

21           Data loss

22           Data retention  

23           Destruction of Electronic Records

24           Secure disposal of records and computer equipment

25           Training 

26           Data Protection Officer 

27           Data Protection Impact Assessments      

28           Review  


2             Introduction

GRO Fieldwork is fully committed to compliance with the requirements of the Data Protection Act 2003 and the MRS Code of Conduct and the GDPR which will be introduced in May 2018.

GRO Fieldwork shall follow procedures which aim to ensure that all employees, recruiters, clients and any subcontracted parties who have access to any personal data held by themselves or by GRO Fieldwork are fully aware of and abide by their duties under the Data Protection Act 2003 and the GDPR and the MRS Code of Conduct. 

In order for GRO Fieldwork to operate efficiently, it is required to collect and use personal information from Clients and Respondents.

2.1         The General Data Protection Regulation (GDPR) is European wide data protection legislation that requires organisations working with individuals based in the European Economic Area to meet certain requirements regarding the collection, processing, security and destruction of personal information.

2.2         As we undertake research that collects or evaluates personal information about a living person who can be identified from the information they have provided we aim to ensure compliance with the General Data Protection Regulation.


3             Purpose

This policy sets out how GRO Fieldwork will seek to ensure compliance with all relevant legislation.


4             Application

This policy applies to GRO Fieldwork dealings with respondents, clients, suppliers and third parties that may be involved in processing personal information. It covers the way personal information will be obtained, used, shared, physically stored and destroyed.


5             General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) governs the processing (i.e. obtaining, holding, organising, recording, retrieval, use, disclosure, transmission, combination and destruction) of personal and sensitive data (i.e. information relating to a living individual – the data subject) and sets out the rights of individuals whose information is processed in manual or electronic form or held in a structured filing system. There are six principles that describe the legal obligations of organisations that handle personal information about individuals.


These Principles are:

  1. i) Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the individual.


The information we gather about an individual will be collected in a way where they are fully informed how we intend to use that information, for what purposes and how we will share it.


  1. ii) Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.


We will explain why we need the information we are collecting and not use it other than for those purposes.


iii)           Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


We will only collect the information we need to provide the services required.


  1. iv) Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.


The information we collect will be accurate and where necessary kept up to date. Inaccurate information will be removed or rectified as we become aware of the changes.


  1. v) Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.


We will not hold information for longer than is necessary.


  1. vi) Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.


We will make sure that the personal information we hold is held securely to ensure that it does not become inadvertently available to other organisations or individuals.


GRO Fieldwork fully supports these principles.


6             Rights of Individuals

The General Data Protection Regulation creates specific rights of individuals. These include:

o             The right to be informed

o             The right of access

o             The right to rectification

o             The right to erasure

o             The right to restrict processing

o             The right to data portability

o             The right to object

o             Rights in relation to automated decision making and profiling.

7             Handling personal information, lawfully, fairly and transparently

The first and second principles require GRO Fieldwork to acquire and process personal information lawfully, fairly and in a transparent way. GRO Fieldwork therefore is clear at the outset about the purpose for which information is obtained and processed. GRO Fieldwork aims to ensure that:

  1. Respondents and potential respondents are aware of the purpose or purposes for which the information is to be used and they have a choice as to whether to provide the information;
  2. A respondent is able to ask for confirmation of the source of their personal information;
  3. Personal information is not used in ways that would have adverse effects on individuals;
  4. Respondents are provided with easy to read and understand privacy notices when information is collected;
  5. Personal information will only be handled in ways that individuals would reasonably expect;
  6. The third-party providers we work with to provide potential respondents must comply with the requirements of the General Data Protection Regulation as well;
  7. We seek to uphold the individual’s rights with regard to their personal information.


Appropriate records will be maintained to demonstrate compliance with the above-mentioned requirements.

  1.  Consent for respondents

7.1         Consent will be required for certain types of information usage.


7.2         When consent is required, it must be freely given, specific, informed and unambiguous. Requests for consent will be separate from other terms, and be in clear and plain language. The individuals consent will be “explicit” where it relates to sensitive data. GRO Fieldwork is required to be able to demonstrate that consent was given. We therefore maintain records of clients consent to meet the accountability requirements for both the profession and the requirements of the General Data Protection Regulation.


  1. Consent for Marketing and Prospecting Purposes

8.1         Under the Privacy and Electronic Communication Regulations (PECR) there are specific requirements relating to unsolicited direct marketing communications. A solicited communication is one that is actively invited, either directly by the customer or via a third party. An unsolicited communication is one that the customer has not invited but they have indicated that they do not, for the time being, object to receiving it. If challenged, businesses would need to demonstrate that an individual has positively opted in to receiving further information from us.


8.2         GRO Fieldwork understands that it is unlawful to contact customers or organisations that have informed us that they do not wish to receive unsolicited marketing material. Therefore, GRO Fieldwork are aware of and comply with the following:


8.3         Telesales – GRO Fieldwork ensure that individuals and organisations they wish to contact are not registered on the Telephone Preference Service (TPS) or the Corporate Telephone Preference Service (CTPS) respectively. If they are registered or have directly notified [Insert Company Name] not to call, then unsolicited direct marketing calls will not be made to them.


8.4         Emails and text message – GRO Fieldwork will not contact individuals by email or via text message without obtaining prior consent unless the individual’s details have been obtained in the course of a sale or negotiations of a sale. Individuals will be given the opportunity to opt out of receiving further marketing emails or texts each time that such contact is made.


8.5         The Mailing Preference Service (MPS) is managed by the Direct Marketing Association to enable individuals to register their names and addresses to limit the amount of direct mail they receive. Unsolicited marketing material will not be sent by post to individuals that have informed GRO Fieldwork they do not wish to receive such information or they have registered with the MPS.


8.6         GRO Fieldwork maintains internal logs of individuals and organisations that have indicated that they do not wish to receive unsolicited marketing information and conduct checks against the TPS, CTPS, FPS, eMPS and MPS databases as appropriate.


8.7         When data is purchased from third parties for prospecting purposes, GRO Fieldwork ensures that the data has been acquired by the third party through fair and lawful means, the data can be used for the purposes of unsolicited marketing activities and that the data has been cross-checked by the third party against the appropriate preference service databases.


  1. Computer Equipment, Security and updates

    GRO Fieldwork shall protect all data by:


9.1         Storing all information on a secure server which is routinely and regularly backed-up to security protected encrypted hard-drives.  All primary records shall be retained for a minimum of 12 months and other final version of documents for 24 months.


9.2         Restricting access to this server to GRO Fieldwork permanent employees only.


9.3         Ensuring that all strictly confidential documentation is password protected on the server.


9.4         All data is presented to GRO Fieldwork pre encrypted with dual delivery of data and password.


9.5         All data sent to sub-contracted recruiter is pre-encrypted with dual delivery of data and pass word protected.


9.6         Where client lists and data are used for recruitment and sent to a recruiter then after the fieldwork is complete all sub-contractor recruiters destroy the data to DOD 5220.22-M standard. When deleted and destroyed they return a form confirming that the data has been deleted.


9.7         GRO Fieldwork use a firewalled network and the data never enters a DB


9.8         GRO Fieldwork destroy the data to DOD 5220.22-M standard on completion of projects.


9.9         We are aware of the vulnerability of laptops, phones and removable media and takes steps to ensure the security of these devices.


9.10       We ensure that all equipment used as part of our business processes is appropriately protected and secured. The equipment we use has up to date Malware and anti-virus software. When updates are notified because of a software patch, these are applied as they become available.


9.11       The laptops that are used for business purposes are encrypted and password protected to ensure that any personal information contained within them is appropriately secured.


  1. Removable Media

Any removable media used such as an external hard drive or USB pen drive are encrypted. GRO Fieldwork tries to avoid using any form of external devices to reduce the risk of data breaches.


  1. PECR and cookies

11.1       Under the PECR, as from 26 May 2018, businesses must seek consent before any cookie is set on an individual’s computer.


11.2       Cookies are small, often encrypted text files, located in browser directories. They are used by companies to help users navigate websites efficiently and perform certain functions. Cookies are also used to keep computer users logged in and their personal details private or for tracking their activity so that companies can improve the website. Cookies can be used by third parties to track information about individuals and spam them with adverts. By themselves, cookies pose no risk since they do not contain viruses.


11.3       Session cookies enable the website to track user movement from page to page so that the user does not get asked for the same information again. The most common example of this functionality is the shopping cart feature of an e-commerce website. Session cookies are never written on the hard drive and they do not collect any information from the user’s computer. Session cookies expire at the end of the user’s browser session.


11.4       Persistent cookies are stored on the user’s computer and are not deleted when the browser is closed. Such cookies can retain user identities and preferences, allowing those preferences to be used in future browsing sessions.


11.5       GRO Fieldwork are responsible for ensuring that the websites comply with the PECR and that, where necessary, appropriate information is disclosed to website users and consent is obtained from users before cookies are set.


11.6 By ensuring that each staff member, upon commencement of employment at GRO Fieldwork completes an internal training programme on data confidentiality and their responsibilities under the introduction of the GDPR in 2018.



12.1       By ensuring that each permanent employee, upon commencement of employment at GRO Fieldwork, be required to sign a confidentiality agreement.  GRO Also ensure that any subcontracted parties who provide any service for GRO Fieldwork also be required to sign this confidentiality agreement, pertaining to any information they may see or hear whilst completing their service

12.2       By ensuring that each staff member, upon commencement of employment at GRO Fieldwork completes an internal training programme on data confidentiality and their responsibilities under the introduction of the GDPR in 2018.


  1. Fair treatment

13.1       Fairness generally requires us to be transparent, i.e. clear at outset and open with individuals about why the information is being collected and how it will be used. Assessing whether information is being processed fairly depends partly on how it is obtained. In particular, if anyone is deceived or misled when the information is obtained, then this is unlikely to be fair. As such GRO Fieldwork will ensure:

  • that all personal data is collected with customers’ consent.
  • We will not use personal data for any purpose other than that for which consent was given, respecting customers’ wishes about the use of their data.
  • We will make sure that customers have access to their personal data that we hold, and that we tell them how we use it.
  • We will protect personal data and keep it secure and confidential.
  • We will ensure staff understand that personal data is just that – personal – and ensure that it is treated with respect.
  • We will ensure that the vulnerable and under-age are properly protected by the processes we use for data collection.
  • We will manage our data supply chain to the same ethical standards we expect from our partners and clients and any suppliers that we engage.
  • We will ensure that all staff who have access to personal data are properly trained in its use.
  • We will not use personal data if there is uncertainty as to whether the Fair Data Principles have been applied


13.2       GRO Fieldwork aim to ensure that, in all cases, consent and privacy statements will:

  • be clear, fair and not misleading;
  • explain the consequences of providing the required information;
  • explain how long the information will be kept for;
  • explain if the replies to questions are mandatory or voluntary;
  • explain if the information is to be anonymised and how;
  • explain if the information will be transferred overseas;
  • explain that if the information will be shared, who with and how they will use it;
  • explain how individuals may be contacted e.g. telephone, email, SMS, post;
  • explain the individual’s rights – e.g. they can obtain a copy of their personal information;
  • explain who to contact if they wish to know more information about how their information is held or to opt-out of receiving further information or if they need to complain


13.3       GRO Fieldwork is responsible for ensuring that the following details are communicated to respondents:

  • the identity of the business or if appropriate, its nominated representative;
  • the purpose(s) for which we intend to process the respondent’s personal information and if the information is to be shared or disclosed to other organisations. (so that the individual concerned can choose whether or not to enter into a relationship with the company sharing it);
  • the process for anonymising the information prior to it being shared with the commissioning organisation and
  • how customers can access the information held about them (as this may help them to spot inaccuracies or omissions in their records – see section below on Rights of Data Subjects).


  1. Minimum amount of personal data

Under the principles of GDPR, GRO Fieldwork identify the minimum amount of personal data we need to properly fulfil our purpose. We ensure that we hold that much information, but nothing further. If we need to hold particular information about certain individuals, we only collect the information for those individuals and nothing more. GRO Fieldwork Ltd does not hold personal data on the off-chance that it might be useful in the future.


  1. Accurate and kept up-to-date

GRO Fieldwork will:

  • take reasonable steps to ensure the accuracy of any personal information they obtain;
  • ensure that the source of any personal information is clear;
  • establish if the individual has challenged the accuracy of the information, this is evaluated and recorded carefully; and
  • consider whether it is necessary to update the information, particularly if the purpose relies on the information being current.


  1. Subject Access Requests

16.1       An individual has the right to see the information that GRO Fieldwork holds about them and can make a request to access this information. Requests must be responded to within 30 days of receipt.

In line with the GDPR, GRO Fieldwork will request certain information before responding to a request:

16.2       enough information to judge whether the person making the request is the individual to whom the personal information relates to avoid personal information about one individual being sent to another, accidentally or as a result of deception.

16.2       Sufficient information that would reasonably be required to find the personal    information amongst the records held by the company and covered by the request.

16.3       In the event of an individual making a subject access request via a third party, GRO Fieldwork  will request written consent from the individual to confirm that the third party can request and receive information on the individual’s behalf.

16.4       An individual who makes a request is entitled to be:

  • told whether any personal information is held and being used;
  • given a description of the personal information, the reasons it is being processed, and whether it will be shared with any other organisations or individuals;
  • given a copy of the information; and
  • given details of the source of the information (where this is available).


17           Requests for information from law enforcement agencies

The General Data Protection Regulation includes exemptions, which allow personal information to be disclosed to law enforcement agencies without the consent of the individual who is the subject of the information, and regardless of the purpose for which the information was originally gathered GRO Fieldwork Ltd will release personal information to law enforcement agencies if required to do so.


18           Data security and reporting of breaches

18.1       GRO Fieldwork Ltd has appropriate security measures to prevent personal information held being accidentally or deliberately compromised. In particular, GRO Fieldwork Ltd:


  • have designed and organised security to fit the nature of the personal information held and the harm that may result from a security breach;
  • are clear about everyone’s responsibility for ensuring information security;
  • make sure that the correct physical and technical security is in place, backed up by robust processes and procedures and reliable, well-trained staff; and
  • are ready to respond to any breach of security swiftly and effectively.


18.2       GRO Fieldwork recognise that information security breaches may cause real harm and distress to the individuals if their personal information is lost or abused (this is sometimes linked to identity fraud). GRO fieldwork have protocols in place which outlines the procedure to detect, investigate and report a breach to the Data Protection Commissioner and any relevant clients. It will assess if there is any potential risk of harm to the individual and will inform them as necessary.


18.3       GRO Fieldwork use a firewalled network 


19           Outsourcing

19.1       GRO Fieldwork have procedures in place if we use third parties to process information to ensure that we:

  • only choose a data processor that provides sufficient guarantees about its security measures to protect the information and the processing it will carry out;
  • take reasonable steps to check that those security measures are working effectively in practice; and
  • put in place a written contract setting out what the data processor is allowed to do with the personal information or business information.
  • Notify any data controllers with whom we are working, who the proposed data processor will be.


19.2       GRO Fieldwork requires third parties that it works with to ensure that there are adequate security measures in place to secure the information that is being held and that they will be compliant with GDPR.


20           Restrictions on transferring information to non- EEA countries


20.1       There are no restrictions on moving personal information within EEA countries, provided adequate consent has been obtained.


20.2       As GRO Fieldwork uses cloud services, we know that personal information will be held within the EEA / transferred outside the EEA.  We are open and transparent with our clients and potential clients about where their information is processed and accessed. 


20.3       GRO Fieldwork considers the following factors when deciding whether or not to transfer information overseas:

  • the nature of the personal information being transferred;
  • the circumstances of how the information was obtained i.e consent
  • how the information will be used and for how long; and
  • the laws and practices of the country where information is being transferred to,


20.4       We also consider additional factors such as:

  • the extent to which the country has adopted data protection standards in its law;
  • whether there is a way to make sure the standards are achieved in practice; and
  • whether there is an effective procedure for individuals to enforce their rights or get compensation if things go wrong.


21           Data loss

21.1.      If personal information is accidentally lost, altered or destroyed, attempts to recover it will be made promptly to prevent any damage or distress to the individuals concerned. In this regard GRO Fieldwork Ltd consider the following:


  • Containment and recovery – the response to the incident includes a recovery plan and, where necessary, procedures for damage limitation.
  • Assessing the risks – assess any risks and adverse consequences associated with the breach, as these are likely to affect how the breach needs to be contained.
  • Notification of breaches – informing the Information Commissioner’s Office or other relevant Supervising Authority as necessary (within 72 hours under GDPR), law enforcement agencies, data controllers on whose behalf we are working and individuals (whose personal information is affected) about the security breach is an important part of managing the incident.
  • Evaluation and response – it is important to investigate the causes of the breach, as well as, the effectiveness of controls to prevent future occurrence of similar incidents.
  • Additionally, GRO Fieldwork would also look to ensure that any weaknesses highlighted by the information breach are rectified as soon as possible to prevent a recurrence of the incident.


22           Data retention

22.1       To comply with information retention best practice, GRO Fieldwork  establish standard retention periods for different categories of information, keeping in mind any professional rules or regulatory requirements that apply and ensuring that those retention periods are being applied in practice. Under the ISO 20252 standard, Primary records should be held for a period of 12 months and all other final version documents for a period of 24 months. Any personal information that is no longer required will either be archived or deleted in a secure manner.


22.2       GRO Fieldwork retention periods for different categories of personal information are based on individual business needs and contractual obligations.


22.3       GRO Fieldwork understands the difference between permanently deleting a record and archiving it. If a record is archived or stored offline, it will reduce its availability and the risk of misuse or mistake. If it is appropriate to delete a record from a live system, GRO Fieldwork will also delete the record from any back-up of the information on that system, unless there are business reasons to retain back-ups or compensating controls in place.


23           Destruction of Electronic Records

All electronic files are destroyed by deletion and then the use of an electronic file shredder. This ensures that all electronic information is deleted permanently and cannot be recovered.

24           Secure disposal of records and computer equipment

24.1       Once the retention period expires or, if appropriate, the customer or business information is no longer required; paper records should be disposed of in a secure manner. All paper records containing customer or business information are disposed of by shredding. This includes all archived records.


24.2       All used computers, fax machines, printers and any other electronic equipment that may contain or that will have stored customer or corporate information in electronic format must be disposed of in an appropriate manner after the information has been completely wiped off. The IT company that GRO employs will ensure that the memory on the devices is completely clean of information before the item is disposed of.

25           Training

GRO Fieldwork takes its responsibilities with regards to ensuring training is undertaken seriously. We know that having policies and procedures in place provides a solid base for our training programme and we aim to undertake training in accordance with the role and seek specialist advice as and when required. All training is documented and reviewed regularly.

26           Data Protection Officer

GRO Fieldwork Ltd does not at this time meet the requirements for a dedicated Data Protection Officer but this is kept under review as the type of work and range of clients/respondent’s changes. We are committed to meeting the needs of the General Data Protection Regulation and if our business requires a DPO, we will seek to appoint one.

27           Data Protection Impact Assessments

Data Protection Impact Assessments will be used to identity and mitigate any data protection related risks arising from a new project, which may affect our business and the individuals or companies that we engage with. Performing DPIA will be mandatory for any new or high risk projects.


28           Review

This policy will be reviewed periodically considering changing business priorities and practices and to consider any changes in legislation.





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