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Privacy Policy

Black Box Research and Consultancy Ltd (Black Box) assist our clients by providing expert witness statements on individuals who are victims of modern slavery. We also use information for research and training purposes.

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Black Box Research and Consultancy Limited.

Registration details

Company registered in England No.12369104 and with the Information Commissioner’s Office No. ZB255703.

Post

St. Marys House, 19-21 Crewe Road, Alsager, STOKE-ON-TRENT, ST7 2EW 

Telephone: 0151 380 0278

Email: info@blackboxresearchandconsultancy.com 

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

  • Names and contact details
  • Company details
  • Addresses
  • Gender
  • Pronoun preferences
  • Occupation
  • Marital status
  • Transaction data (including details about payments to and from you and details of products and services you have purchased)
  • Usage data (including information about how you interact with and use our website, products and services)
  • Information relating to compliments or complaints
  • Records of meetings and decisions
  • Account access information
  • Website user information

We collect or use the following personal information for the operation of client or customer accounts:

  • Names and contact details
  • Company details
  • Addresses
  • Purchase or service history
  • Account information, including registration details
  • Marketing preferences
  • Technical data, including information about browser and operating systems

We collect or use the following personal information about our client’s clients for the delivery of expert witness services:

  • Name and contact details
  • Addresses
  • Gender
  • Pronoun preferences
  • Occupation
  • Marital status
  • Family members, friends, associates and other circumstances
  • Biographical, family, educational, employment.

We also collect or use the following information about our client’s clients for the delivery of expert witness services:

  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic information
  • Biometric information (where used to identify someone)
  • Health information
  • Sex life information
  • Sexual orientation information
  • Actual or alleged criminal offences and records.

We collect or use the following personal information for information updates or marketing purposes:

  • Names and contact details
  • Addresses
  • Marketing preferences
  • Purchase or account history
  • Website and app user journey information
  • IP addresses

We collect or use the following personal information for research, statistical or archiving purposes:

  • Name and contact details
  • Addresses
  • Gender
  • Pronoun preferences
  • Occupation
  • Marital status
  • Family members, friends, associates and other circumstances
  • Biographical, family, educational, employment.

We also collect or use the following information for research or archiving purposes:

  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic information
  • Biometric information (where used to identify someone)
  • Health information
  • Sex life information
  • Sexual orientation information

We collect or use the following personal information to comply with legal requirements and protect victim welfare:

  • Name
  • Contact information
  • Identification documents
  • Client account information
  • Any other personal information required to comply with legal obligations
  • Criminal offence data
  • Client case files
  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic information
  • Biometric information (where used to identify someone)
  • Health and wellbeing information
  • Sex life information
  • Sexual orientation information

We collect or use the following personal information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • National Insurance number
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Address
  • Account information
  • Purchase or service history
  • Witness statements and contact details
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Financial transaction information
  • Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
  • Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
  • Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
  • Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
  • Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
  • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month, however, in complex cases this can be extended to up to three months, but we will advise you why.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:- To allow us to keep sufficient information to manage our relationship with clients. All of our relationships are business to business.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for the delivery of expert witness services are:

  • Consent – we have permission from individuals via their client, after they have been given all relevant information. All data protection rights may apply, except the right to object. To be clear, individuals do have the right to withdraw consent at any time, however, for legal reasons personal data already processed may still need to be retained.
  • Contract – we have to collect or use personal information so we can enter into or carry out a contract. All of data protection rights may apply except the right to object.
  • Legal obligation – we must collect or use personal information so we can comply with the law. All data protection rights of individuals apply, except the right to erasure, the right to object and the right to data portability.
  • Vital interests – collecting or using personal information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter or in a safeguarding matter. All data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:- Keeping clients advised of our service offering.

Our lawful bases for collecting or using personal information for research or archiving purposes:

  • Consent – we have permission from individuals after they have been given all the relevant information. All data protection rights may apply, except the right to object. To be clear, individuals do have the right to withdraw consent at any time, however, for substantial public interest reasons personal data already processed may still need to be retained.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:- The research is required for substantial public interest reasons, specifically to predict when individuals may be at harm in the future, to protect victims, and influence decision makers and public policy.

– To utilise anonymised information in research and training scenarios with an aim to educate professionals and inform public debate, thus preventing abuse of potential future victims.

Our lawful bases for collecting or using personal information to comply with legal requirements:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Defend legal obligations – we have to retain certain information in relation to case files in order to support our witness statements in court, and if necessary to defend any legal claims.

Our lawful bases for collecting or using personal information to protect our client’s client welfare are:

  • Consent – we have permission from individuals after they have been given all the relevant information. All data protection rights may apply, except the right to object. To be clear, individuals do have the right to withdraw consent at any time, however, for substantial public interest reasons personal data already processed may still need to be retained.
  • Legal obligation – we have to collect or use personal information so we can comply with the law, for example, in safeguarding matters. All data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:- To allow us to manage unsolicited job enquiries.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:- To manage complaints and potentially to defend or commence a legal claim.

Where we get personal information from

  • Directly from you
  • Regulatory authorities
  • Legal bodies or professionals (such as courts or solicitors)
  • Publicly available sources
  • Third parties:
    – Clients (Solicitors)

How long we keep information

Where records are anonymised, in other words, where all information which can identify an individual is removed, data protection legislation does not apply, and information can be held indefinitely. We an individual is identifiable from that information, then the following retention schedule will apply.

 

Service

 

Retention Period

 

Provide and improve products and services for clients

7 years from enquiry or end of relationship.

Operation of client or customer accounts

7 years from creation date.

Delivery of expert witness services

to 7 years from conclusion of the case.

 

Information updates or marketing purposes

2 years after end of relationship.

Research, statistical or archiving purposes

Indefinitely.

Comply with legal requirements and protect victim welfare

Will depend on statute of limitation.

Queries, complaints or claims

7 years from enquiry or end of relationship.

Recruitment purposes

Unsuccessful candidates 6 months following appointment of candidate.

Successful candidates – for duration of employment plus 7

All information shall be kept secure whilst it is being stored.

Who we share information with

Data processors

Transcription services

This data processor does the following activities for us: Provide written transcript of verbal conversations.

Data hosting company

This data processor does the following activities for us: Stores company files and records.

Email broadcast company

This data processor does the following activities for us: Manages our email broadcast campaigns. Stores marketing information and records regarding historical campaigns and client interaction with digital communications.

Others we share personal information with

  • Professional or legal advisors
  • Emergency services
  • Regulatory authorities
  • External auditors
  • Organisations we’re legally obliged to share personal information with
  • Professional consultants
  • Third parties:- Witness statements are sent to client and court.

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Brevo

Category of recipient: Email Broadcast

Country the personal information is sent to: France

How the transfer complies with UK data protection law: Brevo is fully compliant with the EU’s GDPR laws. Using data tracking and log identification, Brevo has enacted a data traceability system across all of the data processing procedures on its platform.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Founded by Dr Grace Robinson in 2019.

OUR PRIMARY AIM IS TO SUPPORT VICTIMS AND INCREASE AWARENESS OF MODERN SLAVERY.