Updated Sept 2022
Westco Respondent Privacy Notice
About Westco
Westco is a wholly owned company of Westminster City Council, registered in England with the company number 6462674. Set up in 2003, the business was established to trade the very best of Westminster City Council services and skills with others in the public and private sector. Westco provides full-service strategy, communications, research and transformation consultancy and implementation to the public, private and third sector organisations in the UK.
About this notice
This notice explains what personal data we collect from you during our research and how we use this data. Participation in our research is voluntary and we will always seek your consent to take part in any research project. If you have taken part in research but no longer wish to be part of the research you are entitled to ask that part or all of your interview or input into the research project and/or any personal data be destroyed or deleted, we will then carry out this request.
How we collect information from you
We conduct market and social research on behalf of our clients, mainly public sector organisations. The research we carry out helps our clients to better understand how people feel about a certain subject or service area. This information is then collated into an anonymous or statistical format and used to inform decision making.
You may have been contacted to take part in a research project because:
You have been randomly selected to participate in a research project via telephone – for example when we run a telephone survey using Random Digit Dial (explained below[1]), face to face such as when we recruit participants for a focus group or workshop or via your address when we conducted a face to face survey in a local area. When we collect data in these ways, we have no prior personal information about you or your household.
You may already have a relationship with the client we are working with and they have provided your details to us – this may happen during a consultation for instance if you have opted into communication about a certain consultation or service area – this could be online, via post or telephone depending on how you indicated you would like to be contacted.
We also collect information through your use of and interaction with our website.
Information we collect
The personal information that we collect from you will vary depending on the project in question. We collect data via telephone, online, face to face or by paper/post. We only collect data that is relevant for the project in question. It may include, but is not limited to, the following:
name
demographic data such as your age, gender, working status, job title or socio-economic information.
contact data such as email address; home and/or work postal address, postcode; phone number;
image and/or voice captured through photography, filming, and/or audio recording;
information from queries and/or complaints registered with us. We may sometimes ask you to provide additional personal information, and sometime sensitive personal information, such as disability, sexuality , ethnicity and/or religion if this is necessary to provide the service we are delivering and relevant to our project.
You will always be asked for your consent to take part in research at the start of the research interview/survey/group and you will always be asked for your consent to answer any personal data questions. You can withdraw your consent at any time during the research or refuse to answer any question.
We sometimes record calls for quality purposes but we will always let you know at the outset of the call if this is the case.
How the information we collect is used
The information we collect is only used for the specific project or purpose it was collected for. For example, if we collect demographic data from you during a telephone interview, we will only use that data in relation to that survey or research piece. We use demographic analysis (of groups of more than 50) to look at trends and opinions among certain types of people – for example among those in a certain age groups, or those working full time. We do not use identifiable personal data – such as name or email address in any of our reporting. Our reports are always anonymised and we do not link findings from research projects to individuals.
Sub-contractors
We use trusted fieldwork suppliers to run some elements of our research projects – for instance telephone interviewers or face to face interviewers for a survey or recruitment agencies for a focus group. All our sub-contractors adhere to the requirements of data protection and other legislation and have processes in place to protect personal data. They do not keep any personal data for longer than is necessary for the research project in question and destroy personal data securely. They are accountable to us in relation to the way that they are able to use information you provide to them.
Sharing of personal data
The findings from surveys are collated and reported back to our clients in an aggregated way - so we are not reporting back on individual responses – but grouped responses.
When we share findings from qualitative research such as a focus group or depth interview – we anonymise the findings, to ensure no individual is identifiable in our reporting.
We will only share your personal data with our client, after consent has been gained from you to do this.
Please note, we do not share any of your data with any third parties for marketing purposes.
How we secure your data
Westco is committed to and adheres to Westminster City Council’s Data Protection Policy which includes Information Security, Handling and Awareness, as well as monitoring of third-parties and partners. These policies set out our approach to information security and training for staff that ensure we are adequately prepared to handle information securely, identify risks and report incidents promptly if they occur.
During a research project, only the Westco Research Team, our approved sub-contractor (if we have used one) and client in question have access to any personal data collected.
When we use a sub-contractor – for instance during a telephone survey, we have agreements in place with them to ensure the data collected will be kept secure, confidential and will not be used for any other purpose that the research project in question. Once our sub-contractors securely send the data to Westco, they are required to destroy the data from their systems.
Retention of personal data
We only keep personal data for a limited amount of time and as soon as our project has closed, we will securely destroy this data. This will happen within 3 months of the project closure date. Call recordings are kept for a maximum of 30 days after the call has taken place.
How we process personal data
The vast majority of our research data is stored and processed within the EEA. For online surveys, which make up a very small part of our research work, data is stored on our supplier's servers in the UK.Our supplier is Smart Survey, and it is registered with the with the ICO (registration number: Z1155070).
Your Rights
In certain circumstances you have various rights when it comes to collection and use of your personal data.
The right of access – you can request confirmation that your personal data is being processed, and request access to your personal data
The right to rectification – you can request that any inaccurate personal information be rectified, or completed if it is incomplete.
The right to erasure – you can request that your personal data be erased
The right to restrict processing – you can request that your personal data be restricted or suppressed from certain types of processing
The right to data portability – you can request to obtain your personal data to transfer to another organisation
The right to object – you can object to processing or withdraw your consent for us to use your personal data
Data Protection Contacts
If you have any questions about data protection or security please contact Jen Compton, jen@westcocomunications.com or;
The Data Protection Officer
City Hall
64 Victoria Street
London
SW1E 6QP
dataprotection@westminster.gov.uk
If you have any concerns about how your personal data has been collected or processed by Westco please let us know. Otherwise, you can make a complaint to the Information Commissioners Office (ICO) by visiting ico.org.uk/concerns or call their helpline on 0303 123 1113.
Review of our privacy policy
We review our privacy policy regularly and make updates to this page when needed. Our Privacy Policy was last updated on 6th September 2022. Any substantial changes will be notified to you where appropriate.
[1]This process involves the last few digits of known landline telephone numbers covering an area (provided from the telephone exchanges) being randomly generated. This is vitally important in ensuring we can gather a random sample of respondents to our surveys, as across the UK around half the population have registered with the Telephone Preference Service (TPS) through BT and other companies or have gone ex-directory.
Using your information: Westco Fair Processing Notice
Westco recognises that it has a duty to people whose information it holds to treat that information responsibly, keep it safe and secure, and process it correctly and proportionately. This Privacy Policy broadly explains what information we collect, the purpose for processing, categories of personal information and who we may share it with.
Identity and contact details
Westco, who are wholly owned by Westminster City Council, is a Data Controller. That means that we make decisions about how your information is used.
Our contact details are:
The Data Protection Officer
City Hall
64 Victoria Street
London
SW1E 6QP
dataprotection@westminster.gov.uk
How we collect your information
In order to deliver some of our services, we may collect information about individuals in a number of ways for example by letter, email, face to face, telephone, online or website forms and surveys and social media. More detailed information about how we may collect information and the kinds of information we collect can be found in our respondent privacy notice.
We also collect information through your use of and interaction with our website.
Purpose for processing your information
Collecting your personal information will always be for a specified purpose or set of related purposes. However if we intend to use it for any other new purposes we notify you first. For instance in some cases, we may wish to use your information for improving and developing our services. Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.
There may be times where we need to use your information for a different purpose without first notifying you, for example to prevent and detect crime and fraud, to safeguard others or to protect an individual's vital interests in the event of an emergency.
Our research work
When we conduct research on behalf of our clients, we may collect and use personal data about you where it is needed to provide a service, fulfil a legal obligation and/ or for monitoring equality. We will always explain to you why and how this information will be used. We will always demonstrate to you what our lawful basis is for processing this type of information and where appropriate seek your consent. Please see our respondent privacy notice for further information.
Use of our website and enquiries
We may collect personal information about customers and potential customers and other individuals through the use of our website, and where you contact us, for example, by email or telephone to enquire about our services.
We collect and process this information about you, so that we can carry out our commitments as a service provider, respond to your enquiries and to take steps to enter into a contract with you or manage the terms of that contract. Where we collect information through our website, this is in our legitimate business interests. For example to ensure that content from our site is presented in the most effective manner for you and for your computer; to report on page views and general content consumption of our website; and to manage the requests we receive and services we offer.
When we determine if we should process your personal data for a legitimate purpose we consider the impact on your privacy and data protection rights and we will not process your data for these purposes if your interests override our legitimate interests
What information do we collect?
Our research work
When undertaking research work we may ask you to provide information which covers basic details such as:
- name, address, telephone number, and age;
- personal and family details
- lifestyle and social circumstances
- employment and education details
- housing needs
- visual images, personal appearance and behaviour
We may also collect some sensitive information also known as special category data, such as health or disability data, sexual orientation, ethnicity or religious beliefs - but only where this is necessary for our specific circumstance and you provide us with consent. All information is provided voluntarily and you can withdraw your consent at any time.
Use of our website and enquiries
With regard to each of your visits to our site we may collect the following information:
− technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, operating system and platform; and
− information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site, information you viewed or searched for, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page− We also use cookies. Please read our Cookie policy [insert link].
How we may share your information
We will only share information where it is appropriate and legal to do so, for example when we have conducted research and gained consent from the respondent to share their data with the specified client – this data is anonymised and reported in an aggregated way. We do not share individual personal data. We may also share information, for example, if there is a risk of serious harm or threat to life, for the prevention and detection of fraud or crime, assessment of any tax or duty or if we are required to do so by any court or law. Where this is necessary, we are required to comply with all aspects of the data protection laws.
The vast majority of our data is stored and processed within the EEA. However, some data is stored on our supplier’s server in the USA. This supplier is HubSpot, and it is registered with the EU-US Privacy Shield framework, which means that your personal information is appropriately protected.
How long we keep your information
We will only retain your personal information 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.
We anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow our clients to effectively target and plan the provision of services.
Your rights and access to your information
You have the right to request a copy of the information that we hold about you.
The UK Data Protection Act 2018 also gives you additional rights that refer to how we hold and use your information.
Consequently, under certain circumstances, by law you have the right to:
withdraw consent and the right to object and restrict further processing of your data; however, where legally enforceable this may affect service delivery to you.
request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
request your data to be rectified if it is inaccurate or incomplete
have your data transferred or copied should you move to another provider
not be subject to automated decision-making including profiling
request access to your own personal data, along with a description of how that information is used
Use of IP addresses and cookies
Cookies enhance your experience using our website. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently, as well as to provide information to the owners of the site.
We use cookies to audit the use of our website and help us to customise the website for your visit. We do not store or transmit any personally identifiable data on these cookies. You can change your cookie setting at any time in the security settings in the browser you use to access the internet. Please note however, that rejecting all cookies may impact your enjoyment or use of this website.
We collect IP addresses* only for the purposes of system administration and to audit the use of our site. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.
* An IP address is a unique string of numbers that identifies each computer
If you have any concerns
You have a right to complain to us if you think we have not complied with our obligation for handling your personal information.
Complaints
If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO). You can report a concern by visiting the ICO website.
Changes to this notice
Any changes to how the council processes personal data will be posted on this page.
