Privacy notice: Lincoln’s Inn EDI survey
Introduction
The Honourable Society of Lincoln’s Inn has commissioned the Institute for Employment Studies (IES) to undertake a survey of members’ experience of and views on equality, diversity and inclusion issues at the Inn.
This privacy notice sets out how IES will collect and use data collected through the survey.
If you have any questions about this privacy notice, including any requests to exercise your legal rights in relation to your personal data, please contact IES in the first instance.
IES
Post: Institute for Employment Studies, City Gate, 185 Dyke Road, Brighton, BN3 1TL
Email: suzanne.anderson@employment-studies.co.uk
You also 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 IES in the first instance.
We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it and let you know of any material changes to this notice.
What kind of information do we collect, and what do we do with it?
When you complete the online survey, we will collect information that you provide us with about yourself in terms of personal and membership characteristics, and information about any experiences of bullying and harassment, and views on equality, diversity and inclusion issues at Lincoln’s Inn.
We will not ask you for any personally identifiable information such as name or date of birth.
As the survey does not collect personally identifiable information, responses would not be considered ‘personal data’ under the Data Protection Act/GDPR as it would not be possible to link responses to an identifiable living individual. However, we have set out the reasons for collecting the data and what will be done with the data as if they were personal data to demonstrate our best practice approaches to data processing.
IES will analyse the survey responses and provide aggregated findings to Lincoln’s Inn in the form of a research report. The report may include quotes from open text questions
What is the lawful basis for processing your personal data?
IES acts as a data processor to The Honourable Society of Lincoln’s Inn.
Lincoln’s Inn’s lawful basis for processing data for the survey is ‘legitimate interests’. The aim of the research is to provide Lincoln’s Inn with an understanding of equality, diversity and inclusion issues among the membership and is therefore in its legitimate interest, that processing personal information is necessary for the purposes of the research.
Who else has access to your information?
Survey responses are collected by IES. These responses will include information you give us about your personal and membership characteristics, and any experiences of bullying, harassment or discrimination.
Responses will be truly anonymous as they do not collect any personally identifiable information and it will not be possible to link survey responses to any individuals.
The anonymised survey responses will be provided to Lincoln’s Inn at the end of the research project for archiving. Before this, IES will review open text responses to ensure that it would not be possible to identify any respondents (eg if someone gives their chamber and position it may be possible to identify them) and make any necessary redactions to ensure anonymity.
IES will not disclose information collected in the survey to any other organisations unless required to by law, or to protect or defend ourselves or others against illegal or harmful activities, or as part of a reorganisation or restructuring of our organisation.
International Transfers
Your personal information will not be transferred outside of the EEA.
Security
We take all reasonable steps to protect your personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of your information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We only retain 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. When it is no longer necessary to retain personal data, it will be securely deleted.
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.
As the survey does not collect personally identifiable information, and following a review of open text responses at the end of the project to ensure individuals cannot be inadvertently identified through these responses, the responses would not be considered to be personal data under the Data Protection Act. IES will keep these anonymised responses for as long as required by the Inn.
Please note that, under Data Protection legislation, and in compliance with the relevant data processing conditions, personal data can be kept for longer periods of time when processed purely for archiving purposes in the public interest, scientific or historical research, and statistical purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including rights:
■ To request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it
■ To request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected
■ To 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
■ To object to processing of your personal data: you can object 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
■ To request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data
■ To request transfer of your personal data
■ To object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics
■ Not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you
While we consider it the case that responses will not be personal data as they will not be able to be linked to any identifiable living individual, if you do wish to exercise any of the rights set out above in connection with this research project, please contact Suzanne.anderson@employment-studies.co.uk
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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Company details for the Research Team
The Institute for Employment Studies is a charitable company limited by guarantee registered in England.
■ Registration number: 931547
■ Charity registration number: 258930
■ Registered office: Institute for Employment Studies, City Gate, 185 Dyke Road, Brighton, BN3 1 TL