Research Project Privacy Notice

Get Greener

Introduction

The ‘Get Greener’ tool (the “Tool”) encourages users to adopt more environmentally friendly life-style options in the face of climate change, and suggests ways that someone can do so based on their current lifestyle. It is intended to provide advice to individuals only, and should not be used for other purposes such as direct marketing. We do not endorse any particular supplier of services or products.

This privacy notice sets out how we collect and use your personal data when you make use of the Tool.

Contact details

Behavioural Insights Ltd (the legal name of Behavioural Insights Team (BIT)) is the controller and is responsible for your personal data collected in connection with this project and your use of the Tool. This notice applies to the personal data we collect directly from you and personal data which is provided to us by third parties. Where we collect personal data from you directly, please make sure that any personal details you provide are accurate and up to date, and let us know about any changes as soon as possible. We have appointed a Data Protection Officer (DPO) 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 in relation to your personal data, please contact the DPO:

Post: Behavioural Insights Ltd, 4 Matthew Parker Street, London, SW1H 9NP

Email: dpo@bi.team.

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 us in the first instance.

What personal data will we collect?

The Tool makes use of address, postcode and email/social media data in order to provide personalised advice, streamline the user experience and allow the optional sharing of results. When you submit address and postcode data, it is used to request information from third party databases through the use of APIs, as described below.

What do we do with information we collect?

The purposes for which BIT is processing your personal data are as follows:

● Address/postcode data is used to provide personalised advice by retrieving an Energy Performance Certificate (“EPC certificate”) for a property. It is subject to copyright and all intellectual property rights are owned by the Royal Mail Group Limited1, and is used in line with the exemption: “Promotion and better understanding of the current energy efficiency of buildings and potential improvement in the building sale or rental markets and/or by building occupiers or users”.

● Postcode data will also be inputted into the National Chargepoint Registry to retrieve information on the nearest electrical vehicle charging stations to a given postcode.

● Email/social media data can optionally be inputted by you if you wish to share your results after using the Tool.

None of the above data is retained by the Tool after use and can be removed from your browser by clearing the cache.

If you wish to share feedback on the Tool, using the feedback form, you will be asked to provide your name and email address along with the feedback, which we may use to contact you later.

Some aggregated or otherwise anonymised data concerning the usage of the Tool is retained, such as time spent on the site, click through rates, which action links have been clicked on and the results for ‘was this content helpful’ questions. Anonymised data is also collected on the number of users, kind of vehicle owned (if any), distance driven per year, kind of property (detached, semi-detached, terrace, flat, apartments), amount of meat eaten per year, number of long flights per year. This is used to track e.g., how many of the Tool’s users answer that they have petrol cars, which may form the basis of a published analysis. It will not be possible to link this information with a given individual.

What is our lawful basis for processing your personal data?

Data protection laws require us to meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a lawful basis for the processing.

For all information collected:

BIT is relying on the lawful basis of the performance of a contract between us and you, in the form of the Terms of Use you enter into when you use the Tool. Those Terms of Use can be found here: Tool Terms of Use.

Who has access to your information?

Your information will be accessed by a limited number of researchers and advisors in BIT’s project team working on this project.

BIT may disclose your information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include:

● other companies in BIT’s group that are based within the United Kingdom;

● regulators, law enforcement bodies and the courts, in order to comply with applicable laws and regulations, assist with regulatory enquiries, and cooperate with court mandated processes, including the conduct of litigation;

● suppliers, research assistants and sub-contractors who may process information on behalf of BIT such as the hosting service for the tool, Amazon Web Services. These third parties are known as data processors and when we use them we have contractual terms and policies and procedures in place to ensure that your personal data is protected. This does not always mean that they will have access to information that will directly identify you as we will share anonymised or pseudonymised data only wherever possible. We remain responsible for your personal information as the controller; and

● any third party to whom we are proposing to sell or transfer some or all of our business or assets.

We may also disclose your personal information if required 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 organisations.

International Transfers

Your personal information will not be transferred outside of the European Economic Area (“EEA”). References in this notice to the EEA include the UK, even where the UK is no longer a member of the European Union / European Economic Area.

Security

We take reasonable steps to protect your personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of your information.

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing.

We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, are trained and informed of their rights and responsibilities when processing personal data. We provide such access on a need-to-know basis, and have measures in place which are designed to remove that access once it is no longer required.

Physical personal devices used by BIT are encrypted to protect your data, and confidential hard copy data (including special category data) is kept in locked rooms or cabinets.

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 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. When it is no longer necessary to retain your 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.

The personal data submitted to the Tool is not retained by the Tool, and so is effectively deleted for our purposes when you cease using the Tool. Data retained locally in your browser may be cleared by emptying the browser cache.

We will retain an anonymised dataset (which cannot be associated with you) for the purposes of monitoring the Tool usage, research and statistical purposes. We may use this information indefinitely without further notice to you.

Personal data provided for the purposes of feedback will be retained for a maximum period of six months.

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.

● Request correction of your personal data: 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.

● Object to processing of your personal data: for example, 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.

● Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data.

● Data portability: Where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine- readable format, or transmit it to a third party data controller, where technically feasible.

● Right to withdraw consent to the processing of your personal data: This applies where we have relied on consent to process personal data. Please note that withdrawal of consent will not affect the lawfulness of any processing carried out before withdrawing your consent.

● Right not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you. Please note that BIT does not engage in automated decision making without manual intervention in its research projects.

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer with your specific request by email to: dpo@bi.team

It is important to understand that the extent to which these rights apply to research will vary and that in some circumstances your rights may be restricted.

Ordinarily, 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.

Please also note that we can only comply with a request to exercise your rights during the period for which we hold personal information that directly identifies you. If we have only collected pseudonymised information (e.g. where we have not collected any names or contact details) or personal data has been irreversibly anonymised and has become part of the research data set, it will not be possible for us to comply.

Changes to this Notice

We may change this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear by placing a notification of an update on the Tool website.