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Privacy Policy

Sunderland CCG Privacy Information

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Tractivity Privacy Information

Last updated 1 May 2020

Overview

This privacy policy relates to this Engage 360 website provided by Tractivity Limited.

Tractivity Limited (“Tractivity”, or “we” or “us”) are committed to respecting our customers’ privacy and protecting their data. This privacy policy describes how we capture and use the data that we gather about users of this website. Please read the following carefully to understand our views and practices regarding data and how we will treat it.

Tractivity provides products and services which enable our customers to create and administer Surveys. We host our customers’ Surveys on our servers and collect the responses to those Surveys on their behalf. Our customers may also upload contact information of potential Survey respondents to invite them to participate in a survey. We refer to this contact information and responses as “Survey Data”. Our customers remain data controllers of this Survey Data and we process it solely in accordance with our agreement with our customers (for example, our Software License and Services Agreement).

We act as data processor in relation to all personal information. If you are a Survey respondent, the data controller of the Survey Data is our customer who invited you to participate in the survey.

If you have any questions, comments or complaints regarding our privacy policy or practices, please contact us using the below details:

Post:

Data Protection Officer (DPO),
Tractivity Limited,
Systems House,
Deepdale Business Park,
Bakewell,
Derbyshire,
DE45 1GT

Email:
dpo@tractivity.co.uk

Changes to our privacy policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will post a notice on the homepage of our website and the login screens for our services. We will also keep prior versions of this policy in an archive for your review.

Privacy Policy for Survey Respondents

In this section the words “you” and “your” refer to a survey respondent.

Tractivity’s products and services enable our customers to create and administer surveys. We host our customers’ surveys on our servers and store the responses to those surveys on their behalf. Our customers may also upload contact information of potential survey respondents to invite them to participate in a survey. We refer to this contact information and responses as “Survey Data”. Our customers remain Data Controllers of this Survey Data and we process it solely in accordance with our licence agreement with our customers. Aside from Survey Data, we are likely to process other information about you such as emails received and enquiries made.

Our customers have total discretion to determine how they design their surveys, what information they collect, who they invite to participate in a survey, whether they upload respondent information, what the Survey Data will be used for, whether it will be combined with other information and data, who it will be shared with and how long it will be stored. We strongly recommend you read the privacy notices and/or obtain privacy information from our customer who has invited you to participate in the survey to fully understand what information is stored and how your Survey Data will be used.

You should contact our customer if you have any questions about their survey, or to exercise your rights in relation to the Survey Data.

The information we collect about you

Survey Data: we collect your survey responses. Our customer may also have uploaded your contact information to enable them to invite you to participate in the survey and send reminder emails to you. As explained above, we process this Survey Data on our customer’s behalf and make no use of it ourselves.

How we use your information

We use the information that we hold about you in the following ways:

Survey Data – to provide our products and services: we hold, store and process your Survey Data solely to provide our products and services to our customers, in accordance with our agreement with them. We only use your Survey Data for our own purposes if required to do so by law.

We will not use any information that we hold about you for marketing purposes.

Who we share your information with

Survey Data: unless we are required to do so by law, we will not disclose your Survey Data to any third parties other than our customers and our sub-processors (such as our affiliates and our hosting providers) that have been authorised by our customer in our agreement with them.

Your contact information: where you contact us directly we may, if appropriate, refer your enquiry to our customer.

Your rights as a data subject

If you wish to access, correct, or delete your Survey Data, opt out of any use or disclosure of your Survey Data or exercise any of the other rights described within the GDPR in relation to your Survey Data, you will need to contact our customer directly. Where necessary, we will provide assistance to our customers to deal with your request.

You have the right to complain to a data protection authority about our Customers’ collection and use of your personal data. For more information, please contact your local data protection authority.

In the UK, this is the Information Commissioner’s Office:
https://ico.org.uk/

A list of EU Supervisory Authorities is available here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

How long we keep your information

Survey Data: our customers determine how long they store your Survey Data in our products and services, so if you have any questions about this please ask them directly.

Aside from Survey Data we are likely to hold other information about you such as emails received and enquiries made. We typically retain technical information for as long as we have a specific reason to retain it for example to comply with a legal requirement).

Security of your information

We take the security of your information extremely seriously and apply high standards of security to all information that we hold, in line with ISO/IEC 27001:2013 and PCI DSS, which aligns our information security policies and procedures to follow industry best practice.

All information that you provide to us is stored on secure servers. Our data centre providers are also ISO27001:2013 and PCI DSS certified, and our customers’ Survey Data is encrypted on the servers at rest and in transit across the internet.