Introduction

Welcome to Counterculture’s privacy statement, for circumstances when we are asked by one of our clients to collect information for one of their projects.

We value and respect your privacy and are committed to keeping your personal information safe. This privacy statement tells you how we look after your personal data, about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy statement

This privacy statement aims to give you information on how Counterculture collects and processes your personal data when you take part in a survey or other event or online form we organise on behalf of one of our clients.

This privacy statement supplements other notices and is not intended to override them.

About Counterculture

Counterculture Partnership LLP is a limited liability partnership registered in England and Wales with number OC370322, and is the data controller and responsible for your personal data (referred to as “Counterculture”, “we”, “us” or “our” in this privacy statement).

We have been asked to collect information by one of our clients. We will make it clear to you who that client is, and the arrangement we have with that client about sharing your information with them. In some cases, our client will also be a data controller.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

By email to legal@counterculturellp.com.

By post to:
The Data Privacy Manager
Counterculture Partnership LLP
Unit 115 Ducie House
Ducie Street
Manchester
M1 2JW

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ‘ICO’), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 03 March 2021. Historic versions can be obtained by contacting us. We reserve the right to make changes to this Privacy Statement from time to time. We will post any changes to this site and, where appropriate, notify you of any material changes by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party websites

We may use third-party websites to collect information from you. Clicking on those links may allow third parties to collect, store or share data about you. We have carefully selected those websites, after a review of their privacy statements, but we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

We may collect and process different types of personal data about you. We will always collect and store as much information as possible anonymously. Sometimes it will be necessary to collect and process your personal data. We have grouped these together as follows:

• Identity Data includes your title, first name, maiden name, last name, marital status, date of birth and gender.
• Contact Data includes your correspondence address, email address and phone numbers.
• Survey Data includes the information we are asked to collect by our client for the project you are involved in. The type of data will be different for each project, but we will inform you of the type of data we have been asked to collect.
• Correspondence Data includes information contained in any correspondence between us and correspondence sent to us by third parties that relates to you.
• Sensitive Data includes survey data about your race or ethnicity, religious beliefs, sexual orientation, as well as information about your health and any disability.

If you fail to provide personal data

Where we need to collect personal data, and you fail to provide that data when requested, we may not be able to correspond with you or allow you to take part in our client’s project.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Survey and Correspondence Data when we meet and by corresponding with us by post, phone, email, website or otherwise.
• Third parties. We may receive personal data about you from various third parties as set out below:
  • Identity, Contact, Survey and Correspondence Data when you use third-party services on our website. For example, our live chat services is currently provided by Tidio. Their privacy policy can be viewed by clicking here. We also use video conferencing services provided by Zoom. You can review their privacy policy by clicking here. We also collect information using online surveys provided by Typeform. You can review their privacy policy by clicking here.
  • Identity, Contact, Survey and Correspondence Data from our client.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• When we need to do so as part of the project you are involved with.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent at any time by contacting us.

Purposes for which we will use your personal data

We will normally process your personal data only for the project in which you are involved. We will make it clear whether that information will be shared with our client or not.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Marketing

You will not receive marketing communications from us due to taking part in a project.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website, such as our live chat facility, may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers acting as processors based in the EU who provide IT and system administration services, website development and hosting services and identity verification and fraud protection services.
• Our client acting as joint controllers.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators (including our regulator, the Solicitors Regulation Authority) and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfer

Some of our external third parties are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We 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

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Section 9 below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you can:

• 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.

If you wish to exercise any of the rights set out above, please contact our data privacy manager.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.