Privacy Policy

Last Updated 10 June 2018

 

  1. Who are we?

Trilateral Research Ltd (“we” or “us”) is a UK limited liability Company. We are registered in England and Wales under company number 0869869 and have our registered office at Crown House, 72 Hammersmith Road, London, W14 8TH. We are registered for VAT and our registration number is GB1191652 22.

In 2017, Trilateral Research opened an office in the Republic of Ireland as a wholly-owned Limited Company, registered under company number 616396, with registered offices in FDW House, Blackthorn Business park, Coes Road, Dundalk, Co. Louth, A91 RW26, Ireland. We are registered for VAT and our registration number is IE 3530641 CH.

This Privacy Policy applies to both our UK and Irish entities.

 

  1. Scope of this Privacy Policy

This privacy policy aims at informing website visitors, our business and research partners, and other stakeholders about how we process personal data. Therefore, we aim at addressing all our personal data processing activities, and to confirm our commitment to process data responsibly, securely, and proportionally throughout our business.

 

  1. How do we collect personal data?

We may obtain personal data both directly and indirectly.

  • Directly. We obtain personal data directly from individuals in a variety of ways, including but not limited to obtaining personal data from individuals who complete our online forms, subscribe to our newsletters and preference centre, register and attend meetings or events we host, visit our offices or apply for open vacancies. We may also obtain personal data directly when, for example, we are establishing a business relationship or when we are performing professional services through a contract.

 

  • Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services, research partners, and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
    • Public sources— Personal data may be obtained from public registers (such as Companies House), news articles, open data sources and Internet searches.
    • Social and professional networking sites–  Our services and platforms do not require registration (while some may require subscription of our newsletter or other services) and you will not be required to log in at any time. Therefore, you will not register or log in using social media clients and we do not obtain data through social media. Personal data obtained on social media, such as the email address you may decide to make available to all your LinkedIn contacts, does not fall in this category.
    • Business clients— Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pension services. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies; in this latter case, the service will clearly draw your attention to the separate, dedicated privacy policy.
    • Recruitment services. We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.

 

  1. What categories of personal data do we collect?

We may obtain the following categories of personal data about individuals.

  • General personal data. Here is a list of personal data we commonly collect to conduct our business activities. While this list aims at being as complete as possible, it may happen that we collect additional categories of data from time to time.
    • Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
    • Professional details (e.g., job and career history, educational background and professional memberships, published articles).
    • Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
    • Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details).
  • Special categories of personal data. We typically do not collect special categories of personal data (formerly known as ‘sensitive data’). When we do need to process this kind of personal data, it will be done with the explicit consent of the individual or based on the very strict criteria outlined by Article 9 GDPR. Examples of such personal data that we may obtain include:
    • Dietary restrictions or access requirements when registering for in-person events that reveal religious beliefs or physical health.
    • Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
    • Expense receipts submitted for internal reimbursement that reveal affiliations with trade unions or political opinions.
    • Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
    • Other data provided to us by our clients in the course of a professional engagement.
  • Child data. Although we do not intentionally collect information from minors, we may have access to data concerning underage natural persons while we carry out our activities in research and consultancy.
  • Location-based data. We may process geographical locations you enter when seeking an office near you.

 

  1. On what lawful bases do we process personal data?

We may rely on the following lawful bases for processing personal data to operate our business and provide our products and services:

  • Consent– We may rely on your freely given consent at the time you provided your personal data to us.
  • Contract– We may process personal data in order to perform our contractual obligations with you.
  • Legal obligations and public interests– We may process personal data in order to meet regulatory and public interest obligations or mandates.
  • Legitimate interests– We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
    • Delivering services to our clients– To deliver the services our clients have engaged us to provide.
    • Direct marketing– To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.

 

  1. Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:

  • Providing professional advice and delivering reports. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
  • Promoting our professional services, products and capabilities to existing and prospective business clients.
  • Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
  • Personalising online landing pages and communications we think would be of interest based on interactions with us.
  • Administering, maintaining and ensuring the security of our information systems, applications and websites.
  • Authenticating registered users to certain areas of our sites.
  • Seeking qualified candidates, and forwarding candidate career inquiries to our Human resource team which may be governed by different privacy terms and policies.
  • Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
  • Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
  • Complying with legal and regulatory obligations relating to money laundering, terrorist, fraud and other forms of crime.

 

  1. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. When we do so, we ensure that recipients are contractually bound to safeguard the data we entrust to them before we actually share the data. We may engage with several or all of the following categories of recipients:

    • Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
    • Our professional advisers, including lawyers, auditors and insurers.
    • Payment services providers.
    • Marketing services providers.
    • Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
    • Recruitment services providers.

 

  1. Do we transfer your personal data outside the European Economic Area?

We store personal data on servers located in the European Economic Area (EEA) and outside of the European Economic Area (EEA). We may transfer personal data to reputable third-party organisations situated inside or outside the EEA when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.

 

  1. Do we use cookies?

Our websites does use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our cookie policy.

 

  1. What are your data protection rights? 

Your data protection rights are highlighted here. To submit a data request please feel free to contact us at the email address indicated below.

  • Right of access– You can ask us to verify whether we are processing personal data about you, and if so, to have access to a copy of such data for you to inspect.
  • Right to rectification– You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
  • Right to erasure (so-called ‘right to be forgotten’)– You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
  • Right to restriction of processing– You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
  • Right to data portability– In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company, if is technically feasible.
  • Right to Object – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
  • Automated Individual Decision-making– You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
  • Right to Withdraw Consent– You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

 

  1. What about personal data security?

We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.

 

  1. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business needs or specific legal, regulatory, or contractual requirements, we retain personal data for a period of 5 years. Typical examples of different time frames include but are not limited to those relating to our obligation to retain data concerning European Union research projects (H2020, Action Grants, FP7, etc.) for up to 10 years after the end of the project (unless further retention is requested by auditors), and the retention period of HMRC-related data, which is 7 years. Where the records and documentation containing personal data have been collected within the delivery of an EC project, the Commission/Agency will process it in compliance with Regulation No 45/2001 (archived for at least 5 years after the balance is paid unless there are ongoing procedures such as audits, investigations or litigations, in which case the evidence must be kept until these end, even if this is longer than five years). After the expiry of the retention period, and unless further legitimate grounds for retention arose, we will dispose of personal data in a secure manner.

 

  1. Do we link to other websites?

Our websites may contain links to other sites, including sites maintained by Trilateral Research that are not governed by this Privacy Policy. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.

 

  1. Do we change this privacy policy?

We regularly review this Privacy Policy and will post any updates to it on this webpage. This Privacy Policy was last updated 10 June 2018.

 

  1. Contacts

If you have any concerns as to how your data is processed, you can contact us per email or per post:

Data Protection Officer Team

Trilateral Research Ltd.
Crown House, 72 Hammersmith Road
London W14 8TH
United Kingdom

dpo@trilateralresearch.com.

Usually, we provide a response within 30 days from the date we receive privacy-related communications.

You may contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.