PRIVACY POLICY

 

Policies just for the WordPress website causalmap.app

 

Policies for Causal Map app itself are given below.

 

 

What personal data we collect and why we collect it

 

Comments

 

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

 

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

 

Media

 

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

 

 

Contact forms

 

Cookies

 

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

 

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

 

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

 

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

 

 

Embedded content from other websites

 

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

 

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

 

 

Who we share your data with

 

We will not share your data with any third party without your consent.

 

 

How long we retain your data

 

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

 

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

 

 

What rights you have over your data

 

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

 

 

Where we send your data

 

Visitor comments may be checked through an automated spam detection service.

 

Policies for the Causal Map app

Date of revision 10/1/2022

 

  1. Introduction and definitions

Causal Map Ltd is committed to protecting the rights of individuals to privacy with regard to the processing of personal data. This Policy sets out Causal Map Ltd’s obligations regarding data protection and the rights of data subjects in respect of their personal data under the General Data Protection Regulation.

  • The Regulation defines ‘personal data’ as “any information relating to an identified or identifiable natural person. One who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.” Article 4(1) GDPR.

  • The Regulation defines ‘data processing’ as “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alterative, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.” Article 4(2) GDPR.

  • The Regulation defines the ‘data controller’ as the organisation which “alone or jointly with others, determines the purposes and means of the processing of personal data”; and the ‘data processor’ as the organisation which “processes personal data on behalf of the controller”.

  • Causal Map Ltd’s Data Protection Officer (DPO) is Steve Powell.

This Policy sets out the procedures that are to be followed by Causal Map Ltd clients as data controllers and Causal Map Ltd as a data processor when dealing with personal data. The procedures and principles set out herein shall be followed at all times by Causal Map Ltd, its employees, agents, contractors, or other parties working on behalf of Causal Map Ltd.

Causal Map Ltd is committed to and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom we deal

  1. The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data shall comply.

2.1 Lawful, fair, and transparent data processing

The Client as data controller is responsible for ensuring that any data supplied to Causal Map Ltd fulfils at least one of the following conditions:

  • The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  • Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

  • Processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Processing is necessary to protect the vital interests of the data subject or of another natural person.

  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

  • Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

2.2 Processed for specified, explicit, and legitimate purposes

Causal Map Ltd collects and processes the personal data set out in section 5 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and data received from third parties (a Client passes on personal data). Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

2.3 Adequate, relevant and limited data processing

Causal Map Ltd will not usually collect, store, host or process personal data of its clients’ research subjects. In the exceptional cases where this is necessary, it will occur only for and to the extent necessary for the specific purpose(s) informed to data subjects. Data will be pseudonymised at the point of data collection using “a unique identifier that is not connected to their real-world identity, using techniques such as coding or hashing” (Article 89, GDPR). All information which enables the reversal of psuedonymisation and thereby re-identification will only be held for a limited period (see 2.4), at which point all data will be fully anonymised by the destruction of all key lists.

 

2.4 Timely processing

Causal Map Ltd shall not keep personal data for any longer than is necessary for the purposes for which the personal data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it within one year of the project’s completion - having given the Client due warning that all identification data will be erased.

2.5 Secure processing

Causal Map Ltd shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in sections 6 and 7 of this Policy.

2.7 Accountability

Causal Map Ltd shall keep written internal records of all personal data collection, holding, and processing, in the form of a standard Data Protection Impact Assessment.

  1. Data Protection Impact Assessments

Causal Map Ltd shall carry out Data Protection Impact Assessments when and as required under the Regulation, they shall be overseen by the person responsible for data protection and shall incorporate the following information:

  • The name and details of the person with responsibility for data protection, and any applicable third-party data controllers.

  • The purposes for which Causal Map Ltd is processing personal data.

  • Details of the categories of personal data collected, held, and processed by Causal Map Ltd, and the categories of data subject to which that personal data relates.

  • Details (and categories) of any third parties that will receive personal data from Causal Map Ltd.

  • Details of any transfers of personal data outside of the UK including all mechanisms and security safeguards.

  • Details of how long personal data will be retained by Causal Map Ltd.

  • Detailed descriptions of all technical and organisational measures taken Causal Map Ltd to ensure the security of personal data.

  • The purpose for which personal data is being processed and the processing operations to be carried out on that data.

  • Details of the legitimate interests being pursued by Causal Map Ltd and the necessity and proportionality of the data processing with respect to the purpose for which it is being processed.

  • An assessment of the risks posed to individual data subjects.

  • Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.

Clients should be informed of their responsibilities when sending data to Causal Map Ltd, including hosting data at the Causal Map app:

  • If they are using personal data that were collected from a previous research project, they must provide details regarding the initial data collection, methodology and informed consent procedure. They must also confirm that they have permission from the owner/manager of the dataset(s) to use the data in your project.

  • Where the planned use of data is predicated on the ‘legitimate interests’ of the data controller, the nature and purpose of the dataset must be set out in detail, together with the safeguards (e.g. anonymisation or pseudonymisation techniques) that warrant its use in your project.

  1. The Rights of Data Subjects

The Regulation sets out the following rights applicable to data subjects.

4.1 The right to be informed:

Data subjects have the following rights when personal data is collected:

  • Details of Causal Map Ltd including, but not limited to, the identity of the person responsible for data collection.

  • The purpose for which the personal data is being collected and will be processed as detailed in the DPIA for the project.

  • Where applicable, the legitimate interests upon which the Client and Causal Map Ltd are justifying the collection and processing of the personal data.

  • Where the personal data is to be transferred to one or more third parties, details of those parties. [Note that in QuIP studies no identifiable personal data is ever passed on to third parties].

  • Where the personal data is to be transferred to a third party that is located outside of the United Kingdom (UK), details of that transfer, including but not limited to the safeguards in place (see section 8 of this Policy for further details concerning such third country data transfers).

  • Details of the data subject’s right to withdraw their consent to Causal Map Ltd processing of their personal data at any time.

The following rights are much harder to communicate in the context of QuIP studies and in the countries where QuIP studies are carried out (i.e. outside the UK). Causal Map Ltd will remain aware of these rights and ensure they can be exercised via contact with Causal Map Ltd where possible and applicable:

  • Details of the data subject’s rights under the Regulation.

  • Details of the data subject’s right to complain to the Information Commissioner’s Office

  • Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.

The information set out above shall be provided to the data subject at the time of collection. Where the personal data is not obtained from the data subject directly (i.e. from another party):

  • If the personal data is used to communicate with the data subject, at the time of the first communication.

  • If the personal data is to be disclosed to another party, before the personal data is disclosed.

 

4.2 Data Subject Access

A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which Causal Map Ltd holds about them. Causal Map Ltd is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension). All subject access requests received shall be forwarded to the person responsible for Data Protection.

Causal Map Ltd does not charge a fee for the handling of normal SARs. Causal Map Ltd reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

4.3 Rectification of Personal Data

If a data subject informs Causal Map Ltd that personal data held by Causal Map Ltd is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification. This shall be completed within one month of receipt the data subject’s notice this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.

4.4 Erasure of Personal Data

Data subjects may request that Causal Map Ltd erases the personal data it holds about them in the following circumstances:

  • It is no longer necessary for Causal Map Ltd to hold that personal data with respect to the purpose for which it was originally collected or processed.

  • The data subject wishes to withdraw their consent to Causal Map Ltd holding and processing their personal data.

  • The data subject objects to Causal Map Ltd holding and processing their personal data (and there is no overriding legitimate interest to allow Causal Map Ltd to continue doing so, see section 4 of this Policy for further details concerning data subjects’ rights to object.

  • The personal data has been processed unlawfully.

  • The personal data needs to be erased in order for Causal Map Ltd to comply with a particular legal obligation.

  • The personal data is being held and processed for the purpose of providing information society services to a child.

Unless Causal Map Ltd has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request, this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension.

In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure unless it is impossible or would require disproportionate effort to do so.

4.5 Restriction of Personal Data Processing

Data subjects may request that Causal Map Ltd ceases processing the personal data it holds about them. If a data subject makes such a request, Causal Map Ltd shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

4.6 Data Portability

Causal Map Ltd processes personal data using automated means. Where data subjects have given their consent to Causal Map Ltd to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between Causal Map Ltd and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).

To facilitate the right of data portability, Causal Map Ltd shall make available all applicable personal data to data subjects in the following format[s]:

  • Electronic

  • Paper form.

Where technically feasible, if requested by a data subject, personal data shall be sent directly to another data controller.

All requests for copies of personal data shall be complied with within one month of the data subject’s request, this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension.

4.7 Objections to Personal Data Processing

Data subjects have the right to object to Causal Map Ltd processing their personal data based on legitimate interests including profiling, direct marketing including profiling, and processing for scientific and/or historical research and statistics purposes.

Where a data subject objects to Causal Map Ltd processing their personal data based on its legitimate interests, Causal Map Ltd shall cease such processing, unless it can be demonstrated that Causal Map Ltd legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.

Where a data subject objects to Causal Map Ltd processing their personal data for direct marketing purposes, Causal Map Ltd shall cease such processing forthwith.

Where a data subject objects to Causal Map Ltd processing their personal data for scientific and/or historical research and statistics purposes, the data subject shall, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. Causal Map Ltd is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

4.8 Automated Decision-Making

In the event that Causal Map Ltd uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Causal Map Ltd.

The right described does not apply in the following circumstances:

  • The decision is necessary for the entry into, or performance of, a contract between Causal Map Ltd and the data subject.

  • The decision is authorised by law.

  • The data subject has given their explicit consent.

 

  1. Personal Data

The personal data which may be collected, held, and processed by Causal Map Ltd will be located in the DPIA for each QuIP study, including a brief description of the reason that the data is collected, held, and processed. This may include personal data Clients received directly from data subjects in previous monitoring data collection carried out for their own purposes.

Causal Map Ltd typically only requires sufficient contact information for a respondent to be located. This can include, in ascending order of sensitivity:

  • Name

  • Address

  • Telephone number

  • Father’s name - if a surname is common in that location

  • ID card number - if a surname is common in that location

Information lower down this list should be avoided if possible. Any additional information not required will be deleted immediately.

  1. Data Protection Measures

Causal Map Ltd shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:

  • All emails containing personal data shall be encrypted at rest and transit.

  • Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely.

  • Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances.

  • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;

  • Where Personal data is to be sent by fax machine the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data.

  • Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient (or sent using a secure delivery service).

  • No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of Causal Map Ltd requires access to any personal data that they do not already have access to, such access should be formally requested to the person responsible for Data Protection.

  • All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar.

  • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of Causal Map Ltd or not, without the authorisation of person responsible for Data Protection.

  • Personal data shall be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time.

  • If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user shall lock the computer and screen before leaving it.

  • No personal data should be on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to Causal Map Ltd or otherwise without the formal written approval of the person responsible for Data protection. and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.

  • No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of Causal Map Ltd where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation which may include demonstrating to Causal Map Ltd that all suitable technical and organisational measures have been taken.

  • All electronic copies of personal data should be stored securely using passwords and data encryption.

  • All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords shall contain a combination of uppercase and lowercase letters, numbers, and symbols.

  • Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of Causal Map Ltd, irrespective of seniority or department. If a password is forgotten, it shall be reset using the applicable method.

  1. Organisational Measures

Causal Map Ltd shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

  • All employees, agents, contractors, or other parties working on behalf of Causal Map Ltd shall be made fully aware of both their individual responsibilities and Causal Map Ltd responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy.

  • Only employees, agents, sub-contractors, or other parties working on behalf of Causal Map Ltd that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by Causal Map Ltd.

  • All employees, agents, contractors, or other parties working on behalf of Causal Map Ltd handling personal data will be appropriately trained to do so.

  • All employees, agents, contractors, or other parties working on behalf of Causal Map Ltd handling personal data will be appropriately supervised.

  • Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed.

  • The performance of those employees, agents, contractors, or other parties working on behalf of Causal Map Ltd handling personal data shall be regularly evaluated and reviewed.

  • All employees, agents, contractors, or other parties working on behalf of Causal Map Ltd handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract.

  • All agents, contractors, or other parties working on behalf of Causal Map Ltd handling personal data shall ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of Causal Map Ltd arising out of this Policy and the Regulation.

 

  1. Transferring Personal Data to a Country Outside the UK

Causal Map Ltd regularly needs to transfer (‘transfer’ includes making available remotely) personal data to countries outside of the UK The transfer of personal data to a country outside of the UK can take place only if one or more of the following applies:

  • The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the Information Commissioner’s Office (ICO) has determined ensures an adequate level of protection for personal data;

  • The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the ICO; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

  • The transfer is made with the informed consent of the relevant data subjects.

  • The transfer is necessary for the performance of a contract between the data subject and Causal Map Ltd or for pre-contractual steps taken at the request of the data subject).

  • The transfer is necessary for important public interest reasons.

  • The transfer is necessary for the conduct of legal claims.

  • The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent.

  • The transfer is made from a register that, under UK law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

 

  1. Data Breach Notification

All personal data breaches shall be reported immediately to Causal Map Ltd’s person responsible for Data Protection. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the person responsible for data protection shall ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under section 9) to the rights and freedoms of data subjects, the person responsible for data protection shall ensure that all affected data subjects are informed of the breach directly and without undue delay.

Data breach notifications shall include the following information:

 

  • The categories and approximate number of data subjects concerned.

  • The categories and approximate number of personal data records concerned.

  • The name and contact details of the person responsible for data protection at Causal Map Ltd

  • The likely consequences of the breach.

  • Details of the measures taken, or proposed to be taken, by Causal Map Ltd to address the breach including, where appropriate, measures to mitigate its possible adverse effects.