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Research Project Privacy Notice

DCMS media literacy research

Introduction 

This privacy notice sets out how DCMS will collect and use your personal data if you are a participant in this research project, for example because you participate in a focus group, or an interview on behalf of an organisation that delivers local- or community-level educational initiatives. 

Contact details 

DCMS is the controller and is responsible for your personal data collected in connection with this project. Behavioural Insights Ltd (the legal name of Behavioural Insights Team (BIT)) is the processor of your data on behalf of DCMS. This notice applies to the personal data DCMS or BIT collect directly from you and personal data collected by third parties on behalf of DCMS.. Where DCMS or BIT collect personal data from you directly, please make sure that any personal details you provide are accurate and up to date, and let DCMS know about any changes as soon as possible. 

DCMS’ Data Protection Officer (DPO) 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: DPO, Department for Digital, Culture, Media & Sport, 100 Parliament Street, London, SW1A 2BQ

Email: dpo@dcms.gov.uk

DCMS’ standards regarding holding or using people’s personal information can be found here: https://www.gov.uk/government/organisations/department-for-digital-culture-media-sport/about/personal-information-charter

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). DCMS 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?

For all participants, BIT may collect your name and contact details (e.g., email and/or phone number) on behalf of DCMS. 

For provider interview participants, we may also collect your place of employment and job title. 

For focus group participants, we may also collect demographic information (which may include names, email addresses, demographic information (gender, age, income, education, employment, social grade, and/or deprivation), location, and health information. 

BIT will take best efforts to anonymise all data collected prior to sharing it with DCMS for retention. If respondents divulge personal information as part of their response in the focus group or interview, this may be shared with DCMS. 

What do we do with information we collect?

BIT is processing your personal data on behalf of DCMS for the purpose of: 

  • contacting you to take part in interviews or focus groups.
  • identifying demographic, location or health characteristics which may make some individuals ‘hard to reach’ with respect to media literacy initiatives. 

Anonymised, and therefore non-personal data, may be used for future academic research at the discretion of DCMS. 

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, DCMS is relying on the lawful basis of PUBLIC TASK. Our lawful basis for processing your personal data is public task (as per Article 6 (1) (e) of the GDPR). 

DCMS will collect and process your special category personal data on the basis that such processing is necessary for scientific research purposes or statistical purposes (as per Article 9 (2) (j) of the GDPR). When we rely on this basis, we ensure that necessary safeguards are in place, including minimising 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. 

Who has access to your information?

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

DCMS and 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:

  • 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 DCMS and BIT (e.g., academic advisors, cloud services to store data, transcription 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
  • other companies in BIT’s group that are based within the United Kingdom;
  • any third party to whom we are proposing to sell or transfer some or all of our business or assets.

DCMS and BIT 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

DCMS and BIT 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.

DCMS and BIT 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.

DCMS and BIT 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 

BIT will delete the data associated with the project upon completion of the project in May 2023. BIT will take best efforts to anonymise all data shared with DCMS, including by removing contact details and other obviously identifying information. However if respondents choose to divulge personal information as part of their responses to the focus group or interview (whichever you are participating in), this may be shared with DCMS. DCMS will treat any such data carefully and in accordance with UK GDPR and the Data Protection Act (2018).

As far as possible, DCMS will only store anonymised (and therefore non-personal) data, as shared with them by BIT. DCMS will retain the data in line with their data retention policy. If you have questions about this you can get in contact with DCMS at medialiteracy@dcms.gov.uk 

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 DCMS’ Data Protection Officer with your specific request by email to: dpo@dcms.gov.uk

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.