Applying behavioural insights to increase memory assessment service (MAS) referrals for people from South Asian groups across Cambridgeshire and Peterborough (C&P) for the C&P Integrated Care Service (ICS). Part of the Explore section of Phase 2 of this project will involve the completion of qualitative research with older adults and families/carers of older adults from South Asian groups living in Cambridgeshire and Peterborough to discuss potential barriers and facilitators to accessing MAS. This will inform solutions workshops for behaviourally informed messages for a potential future information campaign about MAS services. BIT will provide a report of findings to the ICS as the project deliverable. This privacy notice sets out how we collect and use your personal data if you are a participant in this research project.
Our research is being conducted in collaboration with Cambridge and Peterborough integrated care service (C&P ICS).
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. 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: Data Protection Officer, Behavioural Insights Ltd, 58 Victoria Embankment, London, EC4Y 0DS
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?
- Personal data: location (broad – C&P), demographics – age and gender
- Special category data: racial or ethnic background, potentially religious beliefs (if given as may be highly relevant to topic), data concerning health – dementia. Details that may lead to inference of the prior.
- Names, email addresses, contact details
What do we do with information we collect?
The purpose for which BIT is processing your personal data is to:
Analyse the data and integrate this information into a report for the client – C&P ICS, to help inform their communications with older adults, families and carers across their regions. To inform solutions – behaviourally informed messages to give information about dementia and the memory assessment services (MAS) in the area. To test the messages via the Predictiv platform to see which are the most acceptable or effective.
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:
LEGITIMATE INTERESTS: Our lawful basis for processing your personal data is legitimate interests (as per Article 6 (1) (f) of the GDPR) and we have considered that your interests and fundamental rights do not override those legitimate interests). It is necessary in BIT’s ‘legitimate interests’ to process the personal data identified above in order to conduct research commissioned by our client C&P ICS. The research project fulfils BIT’s core business aims including undertaking research, evaluation and information activities in sectors that will deliver social impact,
For special category data:
RESEARCH PURPOSES: we will process your special category personal data on the basis that such processing is necessary for scientific research purposes or statistical purposes. When we rely on this basis, we ensure that necessary safeguards are in place, including minimizing our use of personal data, pseudonymising that data where possible, and ensuring the research does not cause substantial damage or distress, and is not used in order to take specific decisions or measures impacting you.
EXPLICIT CONSENT: you have provided your explicit consent to the processing of special category personal data for the purposes set out in this privacy notice.
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 [e.g. cloud services to store data, SMS providers to send text messages]. 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.
BIT may also share your data with the client: C&P ICS.
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.
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.
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.
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.
Taking the above factors into consideration, deletion of your personal data will take place three months after the end of the project, estimated to be January 2024.
In some circumstances, we will retain an anonymised dataset (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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: firstname.lastname@example.org
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 contacting you directly.