ROCKBRIDGE ASSOCIATES, INC.
Effective Date: October 2013
Last Updated: August 2016
COMMITMENT TO PRIVACY AND SURVEY RESEARCH ETHICAL STANDARDS
Rockbridge Associates is a full-service custom market research firm that conducts qualitative and quantitative studies with consumers and businesses. We are committed to respecting and protecting your privacy whether you are a research respondent who is participating in a study or an individual visiting our website to obtain information about our services. This policy explains how we collect, store, use and transfer data that we obtain via our own website or through surveys and other primary research methods used on behalf of our clients. We will explain this in a way that is easy to understand and we provide ways for you to seek additional information or clarification and a means of resolving issues or complaints.
We respect your right to refuse to participate in a study, to respond to specific questions, or to withdraw your permission to be contacted in the future. We are also a member of the Counsel of American Survey Research Organizations (CASRO) and we adhere to the CASRO code of ethics in the conduct of our research. http://www.casro.org/?page=TheCASROCode.
If you are visiting our website or are participating in one of our research studies from inside the United States and you have any concerns about the information we collect and store or how it is used, please contact Rockbridge Associates at: firstname.lastname@example.org, or write to us at:
Rockbridge Associates, Inc.
10130-G Colvin Run Road
Great Falls, VA 22066
If you are visiting our website or are participating in one of our research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. While the data protection and other laws of the U.S. might not be as comprehensive as those in your country, please be assured that we take steps to ensure that your privacy is protected. We participate in the United States Department of Commerce Privacy Shield and the US-Swiss Safe Harbor programs that help U.S. companies comply with European and Swiss privacy laws and rules concerning the transfer of personal data from the European Union (“EU”) and from Switzerland to the United States.
PROTECTED PERSONAL INFORMATION
Personal Information (or “PI”) is any type of information, including information transferred from the EU or Switzerland to the United States, that is recorded in any form, that is about or pertains to a specific individual (you) and can be identified specifically to you. It includes your full name, identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. It may include information about your personal opinions and preferences. PI generally does NOT include your business title, address, phone number, fax or email in your capacity as an employee. In some jurisdictions, it does not include any publicly available information. We may collect PI from you directly when you voluntarily provide it to us or we may obtain PI from clients who ask us to conduct research on their behalf. We may also obtain PI from list providers who have assured us that their lists are made up only of individuals who have given their permission to be included in the list. Finally, we may collect and use PI obtained from publicly available sources, where this is permitted by law.
“Sensitive Personal Information” means PI that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
PROTECTION OF INFORMATION PROVIDED IN A RESEARCH CONTEXT
Marketing research is a tool used by all sorts of organizations to obtain feedback from customers, members, potential customers and other stakeholders. The information collected in a research context may be used to plan new products or services, gauge customer/member satisfaction, measure awareness of products or services, or to test reaction to products, services or communications.
Most research surveys include demographic questions such as racial or ethnic origin, age, gender or income. We use these questions to help us make sure that the research reflects a representative sample of the population we are studying. We understand, however, if you are not comfortable answering certain questions.
We may occasionally collect information that is legally considered more sensitive, “Sensitive Personal Information” as described above. In such instances, we will fully comply with legal restrictions on the collection, storage, use and transfer of such information.
We will never ask you for certain information which, if stolen or misused, could give rise to economic crimes against you, such as bank account or credit card numbers, social security or other similar government-issued ID numbers.
We may also automatically collect a variety of publicly-available machine information for system administration, service improvement and data integrity purposes. This is described in greater detail below.
Even if certain information is not considered PI, we will protect the anonymity of your responses to questionnaires, in focus groups, on research websites or from any means of collecting feedback from you in a research context. If we obtain your contact information from a research panel or other third party, we will comply with the contact limitations and data protections that you agreed to when you signed up to participate in survey research or when you became a customer of a third party. We may occasionally re-contact you to validate your participation in a research study; we will identify ourselves and our purpose when we conduct such validation contacts.
PROTECTION OF INFORMATION PROVIDED BY USERS OF OUR WEBSITE
You may provide personal information to us when you contact us through our website seeking information about our services. We will treat this information as confidential PI. Rockbridge Associates may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
HOW WE USE INFORMATION YOU PROVIDE
- If you provide information to us in order to inquire about our services, we will only use that information to contact you about our services. We will not sell or provide your information to any third party for any other use. By submitting this PI through our website contact form, you are consenting to us sharing your personal information within Rockbridge Associates. For more information about Rockbridge Associates, please see the “Who We Are” section of our website: http://rockresearch.com/about/
- If we receive your contact information from a list or panel company, we will use it only in order to ask you to participate in marketing research, to conduct survey research with you, to validate answers you give, to respond to your requests to us or our client. We select panel companies that adhere to an opt-in process in obtaining panelists and have an adequate policy for protecting the privacy of panelists. We will also not use your information in any other way that is inconsistent with the research or other purpose for which you agreed to be contacted.
- We may share your PI with employees of our company for the purpose of analyzing survey responses.
- If we receive your contact information from our client and you are a customer of that client, we will only use your contact information to ask you to participate in marketing research. We will not use this information to sell you any goods or services. We will protect your anonymity when communicating your research responses to clients unless you have explicitly given permission for your identity and contact information to be shared with our client or you have specifically asked us to give that information to our client so that they may resolve questions or complaints you may have.
- Whether we obtain your PI from a list company or from clients, we will not use this information to sell you any goods or services and we will not provide your contact information to any other party so that they may use that contact information for the purpose of directly selling you goods or services. We will share your PI with our clients only with your specific permission or at your request, or with restrictions as permitted by the CASRO Code of Standards and Ethics for Survey Research.
ADHERENCE TO EU-US PRIVACY SHIELD PRINCIPLES
Rockbridge Associates complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Rockbridge Associates has certified that it adheres to the seven Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. If there is any conflict between the policies in this and the E.U. or Swiss Principles, the Principles shall govern. More information Privacy Notice about the Privacy Shield program may be found at https://www.privacyshield.gov.
ADHERENCE TO US-SWISS SAFE HARBOR PRINCIPLES
Rockbridge Associates complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Rockbridge Associates has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement and liability. If there is any conflict between the policies in this Privacy Notice and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US- Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor.
E.U. AND SWISS PRINCIPLES
When we collect PI from you, we will notify you of the purpose for which we are collecting and using your PI and the type of non-agent third parties to which we disclose or may disclose that information. You will be provided with the choice and means for limiting the use and disclosure of your PI. This Notice will be provided in clear and conspicuous language when you are first asked to provide PI, or as soon as practicable thereafter, and in any event before we use or disclose the information for a purpose other than for which it was originally collected.
As stated above, you have the opportunity to choose (opt out) whether your PI is to be disclosed to a third party or used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. We will treat Sensitive Personal Information received from you the same way you would treat and identify it as Sensitive Personal Information.
Accountability for Onward Transfers
Before we disclose your PI to a third party, we will notify you of this disclosure and allow you the choice to opt out of such a disclosure. We will ensure that any third party to which PI may be disclosed subscribes to the Principles or is subject to law providing the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection. Pursuant to the Privacy Shield Principles, Rockbridge Associates may face potential liability in cases of improper transfers of Privacy Shield data to third parties.
We describe in detail above the types of information we collect and how we will use it. In some circumstances, in order to gain your participation in Internet-based, telephone or in-person survey research, we may transfer your name and email address or your name and telephone number to a marketing research field service facility, to a professional interviewer located in your home country, or to a company that operates Internet based research platforms such as ConfirmIt, Qualtrics, Medallia. Before doing so we will ensure that the third party provides and agrees in writing to provide an adequate level of protection and will not use it for any other purpose. In some circumstances, with your permission and where it is legal to do so, we may transfer your name and email address to a fulfillment company in order to send you an e-gift card as a thankyou incentive for participating in survey research. Before doing so we will ensure that the fulfillment company provides and agrees in writing to provide an adequate level of protection for your personal information and will not use it for any other purpose. If you provide personal information in a survey or other research instrument to which you are responding, we will anonymize your response and will not supply any information that could personally identify you to any other entity, including our clients, without your permission.
We take reasonable steps to protect your PI from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure your PI from loss, misuse, unauthorized access or disclosure, alteration or destruction, but we cannot guarantee the security of information on or transmitted via the internet.
Data Integrity and Purpose Limitation
We will only process PI in a way that is compatible with and relevant to the purpose for which it was collected or authorized by you. To the extent necessary for those purposes, we will take reasonable steps to ensure that your PI is accurate, complete, current and reliable for its intended use. We will limit use of your PI to the use we disclosed to you when we collected it. Prior to using any PI for another purpose we will notify you and obtain your permission.
We will allow you to access your PI and to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where the rights of persons other than you would be violated.
Recourse, Enforcement and Liability
In compliance with the EU-US Privacy Shield Principles US-Swiss Safe Harbor Principles, Rockbridge Associates commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals or Swiss citizens with inquiries or complaints regarding this Privacy Notice should first contact Rockbridge Associates at: email@example.com
Or write to us at:
Rockbridge Associates, Inc.
10130-G Colvin Run Road
Great Falls, VA 22066
Further Recourse for European Individuals:
Rockbridge Associates has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This dispute resolution process will be free of charge to you.
Pursuant to the EU-US Privacy Shield Principles, Rockbridge Associates is liable for the improper onward transfer of data to third parties, and to investigation and enforcement of European privacy regulations through the U.S. Federal Trade Commission. Under certain limited conditions, an individual may invoke “last resort” binding arbitration. The Privacy Shield also provides that a company may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Further Recourse for Swiss Citizens:
Rockbridge has also committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint. This dispute resolution process will be free of charge to you.
Our general website does not direct any services to children. If we gain actual knowledge that a child under the age of 13 has provided any personal information to us without the parent’s or guardian’s consent, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information.
If our general website or any survey we conduct links you to other sites, those sites do not operate under this Privacy Notice. We recommend you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be amended from time to time consistent with the requirements of the EU-US Privacy Shield and US-Swiss Safe Harbor. We will post any revised policy on our website or notify you as described below. We will notify you about material changes to this Privacy Notice by sending a notice to the email address you provided to us or by placing a prominent notice on our website or on our surveys.