Privacy Policy in Detail

Principle 1 – Accountability

Focal Research Consultants Limited is responsible for the personal information under its control and shall assign one or more individuals to be accountable for our organization¡¯s compliance. Responsibility for Focal Research Consultants Limited compliance rests with the assigned individual(s), even though other individuals within our organization may handle the day-to-day collection and processing of the information. Focal Research Consultants Limited is responsible to protect all personal information held by our organization including information transfer to third party for processing. Focal Research Consultants Limited shall use contractual or other means to provide comparable level of protection while the information is being processed by a third party. Focal Research Consultants Limited shall implement policies and practices to give effect to the principles, including:

• implementing procedures to protect personal information;
• establishing procedures to receive and respond to complaints and inquiries;
• training staff and communicating to staff information about the organization¡¯s policies and practices; and
• developing information to explain the organization¡¯s policies and procedures.

Principle 2 – Identifying Purposes for Collection of Personal Information

Focal Research Consultants Limited shall identify the purposes for which personal information is collected at or before the time the information is collected.

Focal Research Consultants Limited collects personal information from the public only for the following purposes:

• to conduct quantitative or qualitative marketing and social research;
• to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and
• to meet legal and regulatory requirements.

Focal Research Consultants Limited shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Focal Research Consultants Limited who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating.

Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, Focal Research Consultants Limited always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure.

A respondent is always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, Focal Research Consultants Limited shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.

Generally, Focal Research Consultants Limited shall seek consent to use and disclose personal information at the same time it collects the information. However, Focal Research Consultants Limited may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, Focal Research Consultants Limited shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for Focal Research Consultants Limited to collect, use and disclose personal information for the identified purposes.

Principle 4 – Limiting Collection of Personal Information

Focal Research Consultants Limited shall limit the collection of personal information to that which is necessary for the purposes identified by Focal Research Consultants Limited. Focal Research Consultants Limited shall collect personal information by fair and lawful means.

In conducting surveys, Focal Research Consultants Limited limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.

Focal Research Consultants Limited collects personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, Focal Research Consultants Limited will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information

Focal Research Consultants Limited shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Focal Research Consultants Limited may disclose a respondent’s personal information to:

• a client of Focal Research Consultants Limited where the respondent has consented to such disclosure;
• a third party engaged by Focal Research Consultants Limited to perform functions on its behalf;
• a public authority or agent of a public authority if, in the reasonable judgment of Focal Research Consultants Limited, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
• a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only Focal Research Consultants Limited’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

Focal Research Consultants Limited shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, Focal Research Consultants Limited shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Focal Research Consultants Limited shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 – Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Personal information used by Focal Research Consultants Limited shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

Focal Research Consultants Limited shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 – Security Safeguards

Focal Research Consultants Limited shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Focal Research Consultants Limited shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

Focal Research Consultants Limited shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of Focal Research Consultants Limited’s employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 – Openness Concerning Policies and Procedures

Focal Research Consultants Limited shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Focal Research Consultants Limited shall make information about its policies and procedures easy to understand, including:

• the title and address of the person or persons accountable for Focal Research Consultants Limited’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
• the means of gaining access to personal information held by Focal Research Consultants Limited;
• a description of the type of personal information held by Focal Research Consultants Limited, including a general account of its use; and
• a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, Focal Research Consultants Limited shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer (privacy@focalresearch.com), Focal Research Consultants Limited will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.

In certain situations, Focal Research Consultants Limited may not be able to provide access to all the personal information that it holds about a respondent. For example, Focal Research Consultants Limited may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Focal Research Consultants Limited may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit Focal Research Consultants Limited to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

Focal Research Consultants Limited shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Focal Research Consultants Limited shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting the Focal Research Consultants Limited Privacy Officer (privacy@focalresearch.com).

Principle 10 – Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Focal Research Consultants Limited’s compliance with the Focal Research Consultants Limited Privacy Policy.
Focal Research Consultants Limited shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding Focal Research Consultants Limited’s handling of personal information.

Focal Research Consultants Limited shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the Focal Research Consultants Limited Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

Focal Research Consultants Limited shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, Focal Research Consultants Limited shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The respondent shall be informed of the outcome of the investigation regarding his or her complaint.