CLOSE-UP’S PRIVACY POLICY
Close-Up Research is a UK-registered limited company specialising in ethnographic research and insight-led storytelling. That means we research and document people’s lived experiences.
Close-Up adheres to the Market Research Society’s Code of Conduct 2023 (bit.ly/mrscodeofconduct), and complies with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 (gov.uk/data-protection).
That means that everyone participating in our research / filming has the right to be informed about the collection and use of their personal data. Below we explain how your personal data might be used if you choose to take part in our research / filming.
(For information on our approach to safeguarding and consent, see “Close-Up Research’s Safeguarding Policy” and “Close-Up Research’s Consent Policy”.)
What is personal data?
Personal data means any information that relates to an identified or identifiable individual – for example, your name and contact details, and also your image, voice, and information about your lived experiences.
The collection and use of your personal data is known as ‘processing’, which means that Close-Up Research is usually the ‘data processor’. As Close-Up Research is typically commissioned by an end-client who decides the purpose of the data collection, the client is usually the ‘data controller’.
What if I do not wish to participate?
Taking part is your choice. You may decline, pause or end a visit or recording at any time without giving a reason. We’ll stop the visit or recording when you ask.
We make an effort to check how people are feeling throughout our visits, to gauge ongoing consent and comfort around participation.
You may also ask us not to use your contribution or data after you’ve already participated, whether before or after publication, and we’ll act to remove your contribution and data.
Just ask Close-Up or the project contact named on your consent form. We’ll act on what is within our control and promptly involve the data controller where their decision or action is needed.
What happens with my data if I do participate?
– Close-Up Research team members promise to be sensitive with participant recordings, and only to use contributions for each specified project as outlined in the corresponding participant consent form. We won’t share participant surnames, addresses or contact information with the public or any third parties.
– Whilst most people are happy to appear on screen with their first name, we can use a pseudonym or anonymise a participant’s appearance if preferred. Participants are also free to end participation at any time, without needing to give any reason.
– We may need to share relevant information if we have a safeguarding concern, believe someone is at risk of serious harm, or are legally required to disclose it. We share only what is necessary, with an appropriate person or authority, and record the decision
– Raw recordings, transcripts and field notes are kept in approved, access-controlled project storage. Access is limited to authorised Close-Up team members and, where agreed for the project, authorised people working for the commissioning agency or end client. Participants have the right to request access to their personal data, and to request that any inaccuracies be corrected.
– Close-Up Research’s equipment is stored in a locked space, with CCTV in operation, password-protected computers with anti-malware protection, and password-protected WPA2 secure internet connection. Only Close-Up Research employees have a key to access the office, and the passwords to access the computers. All project data is backed on up secure additional hard drives, in separate project folders.
– All Close-Up team members agree: not to share project data with anyone else outside of the project; to securely back up their work; to keep the data in separate dedicated project folders; and to take proportionate steps to secure both project files and their computer (eg. by using up-to-date malware protection, having password-protection for computers, using secure internet access, and by keeping equipment/materials in a securely locked space).
– If data is transferred, it’s either transferred physically, from one hard drive directly to another, or remotely using a secure encrypted file-sharing service. Individual files may also be further password-protected where appropriate.
– All personal data, with the exception of published materials, consent forms and safeguarding records, will be destroyed 2 years after the end of the project, unless a participant requests their personal information be destroyed before this point.
– Data processed by Close-Up Research, its employees, and the end-client will only ever be used for the purposes outlined, and obtained with informed and ongoing consent from those being recorded.
What rights do I have in respect of my personal data?
Depending on the circumstances, data protection law gives you the right to:
- ask for access to the personal information held about you;
- ask for inaccurate or incomplete information to be corrected;
- ask for your personal information to be deleted;
- ask for the use of your personal information to be restricted;
- object to the use of your personal information;
- withdraw your consent, where consent is being relied on to use your personal information; and
- ask to receive certain personal information in a portable format, or have it transferred to another organisation.
Some of these rights apply only in particular circumstances. You can make a request by contacting Close-Up Research or the data controller named in your project-specific information. Where the request requires action or a decision from the data controller, Close-Up will pass it on promptly and help the controller respond.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Review and Updates
This policy will be reviewed annually or sooner if legislation or best practice changes.