Centre for Inclusive Money Fair Processing Notice – National Coalition for Workplace Savings employer case studies
This fair processing notice (‘notice’) provides you with information about how your personal data will be used in case study research for the National Coalition for Workplace Savings.
This should be read alongside Centre for Inclusive Money’s Privacy policy, which has more information about your data protection rights. We are required under Data Protection legislation to notify you of the information contained in this notice.
1. Who is processing your data
Centre for Inclusive Money at Nest and the Money and Pension Service (on this research project, acting as joint data controllers): we decide how your data is collected and processed for this research. Centre for Inclusive Money is a public-benefit research and innovation centre focused on identifying solutions to ensure people are financially secure today and in the future. The Money and Pension Service is an arms-length body, sponsored by the Department for Work and Pensions, with a commitment to ensure that people in the UK have access to the guidance and information they need to make effective financial decisions over their lifetime.
2. What personal data we are using and why
The National Coalition for Workplace Savings has been established to increase the number of working age adults who have emergency savings, in order to help them become more financially resilient. The Coalition is convened by the Money and Pension Service, Centre for Inclusive Money and TISA.
The Coalition aims to encourage more employers to implement and increase participation in workplace savings schemes.
This case study research, led by Centre for Inclusive Money and the Money and Pension Service, will communicate impact and learning to members and to employers interested in offering workplace savings.
Case studies will involve interviewing both senior staff responsible for delivering workplace saving schemes and employees with experience of saving via their employer.
To conduct these interviews, we may collect, store and use (process) the following personal data about you:
- first name and surname
- phone number
- email address
- job role
- audio and/or video recording (note: you will never be recorded without your prior consent).
Special category data
Special categories of data are more sensitive and have extra protection under Data Protection legislation. This includes data that could reveal, for example, your racial or ethnic origin, health data, or data concerning a person’s sexual orientation.
We do not intend to process any special categories of data for this project but if you share special categories of data information with us through your responses, we will either remove it from the dataset, where possible, or ask for your explicit consent for this data to be processed and used for the purpose of the research.
3. Why we are legally allowed to use your data
Our lawful basis for collecting or using personal information is Consent (Article 6(1)(a) of the UK General Data Protection Regulation (UK GDPR).
Our condition for collecting special category data on ethnicity is Explicit consent (Article 9(2)(a) of the UK General Data Protection Regulation (UK GDPR).
We will collect your consent before you can take part in these research activities.
If you do consent to participate, you may withdraw yourself from the research at any time, without giving a reason, by advising Centre for Inclusive Money via email, text or WhatsApp.
4. Sharing your data with third parties
We may use the following third-party processors to support the research:
- The online survey provider Microsoft Forms will host the sign-up and consent forms, their privacy policy can be viewed here.
- If you (are eligible and) provide your consent to participate in an interview, this will be audio and video recorded using Microsoft Teams (their privacy policy can be viewed here) or Zoom (their privacy policy can be viewed here).
- Centre for Inclusive Money and the Money and Pension Service will remain the joint controllers of your personal data.
5. Transfers outside of the UK or EU
Your personal data will generally be processed in the UK. However, some of the organisations that we share your personal information with to deliver our research activities may process it overseas. If any sharing means that your personal information will be transferred outside the UK, we will only make that transfer if:
- the country to which the personal information is to be transferred ensures an adequate level of protection for personal information
- we can put in place appropriate safeguards to protect your personal information, such as an appropriate contract (like the contract terms sometimes called Model Contract Clauses which includes the UK’s international data transfer agreement (ITDA) or the EU’s standard contractual clauses (EU SCCs) supplemented by the ITDA addendum; and
- the transfer is necessary for one of the reasons specified in data protection law.
In some situations, we may request your consent to the transfer to ensure this is lawful.
If we use any third-party service providers who are not based in the UK, we will carry out a risk assessment to determine whether appropriate safeguards are in place (taking into account the level of security, the volume of data, sensitivity of data) and seek to ensure that the necessary safeguards are in the contract.
6. Anonymising and storing your data
The personal information processed for the purpose of research will only be stored for as long as is necessary to complete the research analysis and publish the findings. Your personal data will be stored securely and only the research team will have access to it.
Any video or audio recordings will be deleted within one month after the transcription has been reviewed. Personal data collected to organise interviews will be deleted no later than the completion of the project.
Data collected during interviews will not be anonymised as quotes will be attributed to you in publications. We will collect consent for this, and it will be explained at the beginning of each interview.
As stated in the National Coalition of Workplace Savings Memorandum of Understanding, you will be provided with a draft of any external communications at least five business days prior to the intended publication date and should provide written approval or reasonable comments within five business days of receipt. External Communications will not be released or published without such prior written approval.
7. Complaints and more information
If you have any concerns or complaints about our use of your personal data, you can contact us using the details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also contact the Information Commissioner’s Office (ICO).