About Culture Bulb
Culture Bulb is a research and insight consultancy specialising in the museums, heritage, cultural and creative sectors, and is the trading name of Meriel Royal, the sole proprietor. Culture Bulb is registered at 7 Parker Close, Eynesbury, St Neots, PE19 2HH.
Culture Bulb is registered with the Information Commissioner’s Office (ICO), registration no. ZB335536.
What this privacy policy covers
- Our data privacy principles;
- The personal data we collect, and from whom;
- How and why we use personal data;
- How long we will keep your data;
- How your personal information will be protected;
- Where your data is stored and processed;
- Who your data will be shared with;
- The legal bases upon which we process your data;
- Your rights when it comes to ownership of your personal data.
If you have any questions about our approach to data privacy, or how we use your data, please contact us.
Our approach to privacy
As an insight consultancy working with research data we are dedicated to using your information ethically and responsibly, and to keep your personal data safe. Our approach to data privacy is based on the following principles:
- Collecting the least personal data possible;
- Storing personal data safely and securely;
- Providing transparency over how your personal data is used;
- Retaining personal data for no longer than is necessary in order to provide our products or services, or in order to comply with HMRC or another legal entity;
- Not sharing your personal data with any third parties, unless they are required to process your data in order for me to deliver a service to you - e.g. using your name and email address with my email provider in order to communicate with you by email;
- Processing Subject Access Requests promptly once we have verified the subject’s identity;
- Promptly notifying the ICO of any data breaches as soon as we become aware of them.
What data do we collect and how will it be used?
We use your personal information under the following circumstances:
- To provide services to our clients and customers;
- To contact research participants about research such as surveys, polls or interviews;
- To notify you if you win a prize draw or to provide you with an incentive;
- To analyse research data from surveys, interviews and focus groups for analysis and other research purposes;To contact you about our services via email;
- To contact you about our services via email;
- To enable us to supply you with services and information which you have requested;
- To deal with any complaints, queries or problems you may have;
- For any other purpose consistent with the nature of our consultancy business.
The following table outlines in detail what data we will collect about customers, research participants or website users, depending on how they engage with Culture Bulb. It also explains how your data will be used, and for what purpose we collect it.
Activity
Data collected
Business activities
We store the names, email addresses, job titles and telephone numbers of clients, customers, industry contacts, sector organisations, suppliers, funding bodies and other freelancers.
This data is collected in order to conduct our day-to-day business, communicate with clients, organise projects, conduct research and promote our services, and deal with any complaints, queries or problems you experience. This personal information is either supplied by individuals through emails, networking or readily available publicly online.
As a research and insight consultancy, we conduct quantitative market and audience research for clients, which involves collecting personal data from research participants in the form of surveys. Depending on the nature of the research project, we may collect:
· Personally identifiable data such as name and date of birth.
· Contact details such as phone number, email address, address and postcode.
· Demographic data such as your age, gender, and general economic and household information.
· Information about your opinions, attitudes, motivations and behaviours relating to your participation in cultural, heritage and creative activities.
· Special category (sensitive) data such as whether or not you have a disability, racial or ethnic origin, and sexual orientation.
· Your image / voice captured through photography, filming (either in-person or the recording of video calls), or audio recording
Quantitative and qualitative research
· We may collect contact details for the purpose of sending invitations to participate in research activities such as surveys, polls or recruitment for qualitative research; to send research materials by post; to notify you if you win a prize draw or to enable us to issue incentives, payments or vouchers to you as a thank you for participating in our research.
· We may record your image or voice for the purpose of referring back to research interviews, note taking, transcription and analysis.
· We may collect demographic, opinion and special category data in order to conduct audience research into a variety of topics for clients in the creative, cultural and heritage sectors, and to anonymise, analyse and report on that data in order to provide insight.
· We may take photos of events such as training and conferences for the purpose of promoting our services on our website and social media.
Website
When you use our website, we collect information through cookies to ensure our website functions as it should. Cookies are files with small amounts of data including an anonymous unique identifier that a website sends to your computer’s hard drive when you are viewing the website. Just like other websites, we automatically collect some non-personally identifiable information including but not limited to your IP address, geographic location, language preference, date and time of visitors
We may use cookies for various reasons such as optimizing and personalizing your browsing experience, checking our website analytics or saving your preferences and settings for future use. This information is only collected to better serve and understand your user experience on the website. You have the option of turning off cookies on your computer should you wish to do so. If you choose to do that, you may not be able to view all the features and content of this website.
Analysis of client-owned data
Culture Bulb may act as a data processor for third party data provided by clients. In this case, the client acts as the data controller, and makes their own decisions over the purposes and ways in which their own data may be processed, but Culture Bulb may act as the data processor insofar as we analyse third party data for the purposes of extracting audience insight from that data.
Examples of this may include:
• Aggregated and anonymised survey or other research data
• Anonymised ticketing data
• Anonymised CRM data
• Google Analytics data
• Backend social media data
We will analyse aggregated and/or anonymised data from clients in order to provide insight to them about their audience.
For example, this may take the form of:
• Analysing ticket and/or purchase behaviours/patterns through transaction data analysis
• Providing insights about an organisation’s audience through analysis of their existing survey or research data (collected either by the organisation themselves, or another third party)
• Analysing CRM data for the purpose of providing insight about an organisation’s customer base, their transaction history, email campaign engagement and marketing segmentation.
• Analysing Google Analytics data for the purpose of providing insight about how an organisation’s website users behave.
• Providing insights about an organisation’s social media audience, through analysis of data from their social channels.
If you are invited to take part in any research by Culture Bulb, or by a client that Culture Bulb is providing services for, you will be provided with a full explanation of the purpose of the research, how your data will be stored, and will be asked to acknowledge these terms before you grant your consent for your data to be used in this way.
If you are attending a training workshop where Culture Bulb is taking photography, you will be asked for your permission before we use any photos in marketing materials, and will have the option to opt out of this at any time.
How long will you keep my data?
We only keep your data for as long as necessary. This will vary depending on the type of data you have supplied and why you have supplied it, but as a whole our retention periods are as short as possible.
We will hold personal data only as long as it’s necessary to provide research services to our clients, or for other essential purposes such as complying with legal obligations or resolving complaints.
In the case of survey or other research data, our standard retention period is 3 months / 12 weeks from the end of the research project, or until the final deliverables have been provided to the client.
When analysing third party data provided by a client, in our role as data processor, data will be deleted as soon as the research project has concluded and insight has been provided to the client.
How will my personal information be protected?
The security of your personal data is of utmost importance to us, and we take utmost precaution to protect it. We protect your data by:
- Anonymising as much data as possible (e.g. for the purposes of surveys or other research) and only collecting sensitive personal information where absolutely necessary;
- Minimising the number of devices and/or networks your personal data is stored on;
- Vetting and using survey and research providers which have high standards of data security;
- Password-protecting any spreadsheets or other files that contain personal data;
- Using file sharing solutions that use secure protocols such when sharing personal data.
Despite taking these precautions, no data transmission over the internet can ever be guaranteed to be 100% secure. We strive to protect your personal information to the best of our ability, but we cannot guarantee the security of any of the information that you supply to us, and by supplying us with your data you understand that you do so at your own risk.
Where is my data stored and processed?
Culture Bulb is located in the United Kingdom, and as such we store and process yourinformation in the European Economic Area (EEA).
Will my data be shared with anyone else?
As a general rule, we do not disclose your personal information to third parties without your consent with the exception of the following circumstances:
- If you are taking part in research conducted by Culture Bulb on behalf of a client (for example, a museum), then we may share your personal data with our client as part of the research outputs (e.g. your voice/image if we share a recording of a focus group). In this case, Culture Bulb and the client (museum) are joint data controllers, and both parties will be named as the data controller in the data privacy notice provided to research participants at the beginning of the research project, so they can provide informed consent.
- We may disclose your information to trusted suppliers such as our website supplier, email marketing provider, survey and data analysis programmes, transcription suppliers or other suppliers or subsidiaries we rely upon to provide services to our clients.
- In exceptional circumstances, we may disclose your information in order to comply with any legal requirements.
Your data is only shared to third parties in these particular circumstances, we will never share your contact details with any other business, company or supplier for the purposes of marketing, promotion or to profit either financially or otherwise from sharing your data.
What are the legal bases we use for processing your information?
The UK GDPR requires all companies to have at least one lawful bases in order to process personal data about customers or the general public.
Culture Bulb generally relies upon the basis of consent to process your personal information. This includes but is not limited to consenting to participate in qualitative or quantitative research, signing up to our mailing list, entering into contact with us (e.g. by sending an enquiry through our website) or by accepting the cookies on our website.
Culture Bulb may collect special category data such as ethnic origin or sexual orientation only with the explicit consent of data subjects, under Article 9a of the UK GDPR. We will collect this anonymously data only for the purposes of equality monitoring and analysing research data. The purpose and nature of the research will be set out explicitly for participants before they choose whether they consent to participate, and they are free to withdraw their consent at any time. Survey participants will always be required to read a specific data protection clause before taking a survey, and qualitative research participants (e.g. interviews, focus groups) will always be asked to sign a consent form which lays out the purpose of the research and how their data will be used.
Where there is legitimate interest in us processing your personal information, we may do so if it is reasonably necessary to achieve our clients’ legitimate interests (as long as that processing is fair, balanced, and does not unduly impact your rights). Legitimate interests refers to our clients’ interests in conducting market research and audience insight. For example, they might have an interest in making sure their organisations, products or programmes appeal to people like you, or that you are a satisfied customer.
We may also process your data (primarily by emailing you) where there is a legitimate interest in Culture Bulb doing so for commercial interests or the purpose of promoting our business, if it is reasonably fair, and does not outbalance your rights and interests.
Whenever Culture Bulbs process your personal information for either our own or our clients’ legitimate interests, we ensure that the impact on you is considered, and we balance our own rights against yours under data protection legislation. We won’t use your personal data for activities where our clients’ interests cause harm or are overridden by the impact on you (unless we have a different legal basis for processing your data, e.g. by gaining consent).
If you have any concerns about the legal means by which we process your data, you have the right to object to any processing that is based on our legitimate interests.
How can you access your information?
Under the Data Protection Act 2018 you have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent. request to see any personal information we hold about you. Any data access requests should be made in writing.
If you believe the information we hold about you is incorrect, you have the right to correct that information. We will retain your personal data only for as long as is necessary in order to provide our services, or to comply with tax and legal authorities.
If you have a concern about the way we are collecting or using your personal data, if we do not address your request, or fail to provide you with a valid reason why we have been unable to do so, you have the right to contact the Information Commissioner’s Office to make a complaint. They can be contacted via their website https://ico.org.uk/concerns/ or by telephone on 0303 123 1113.
