BSNA MARKET RESEARCH AND SURVEYS PRIVACY STATEMENT

1. INTRODUCTION

1.1 British Specialist Nutrition Association Ltd (collectively “BSNA”, "we", "us", "our") may carry out or commission (via third party research providers) research surveys ("Research Surveys") for the purposes of market research and to promote our policy decisions. This Market Research and Surveys Privacy Statement ("Privacy Statement") sets out information about how your personal information will be collected and processed by us in connection with any such Research Surveys.

2. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

2.1 If you are an individual who has agreed to participate in a Research Survey, you may provide us with information about you ("your personal information"), including your responses to the Research Survey. This information may include your name and contact details; and your responses to (and the results of) our Research Surveys, which may relate to things such as your attitude to and experiences of: parenteral nutrition, infant nutrition, medical foods and IV solutions. Survey data might include, for example, your experience of information sharing about these topics, which areas you are interested in knowing more about, and (if you are a health care practitioner), your experience of informing or advising patients in relation to these topics. If you are a health care practitioner, we may also collect information about your medical speciality and sub-speciality, any associated hospitals, and your practice name. The personal information that you may provide in relation to a Research Survey will be made clear to you if you choose to participate in a Research Survey.

2.2 If you respond to a Research Service online, we may also collect certain information directly from your device. Specifically, the information that we may collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with the survey webpages, including the pages accessed and links clicked. Collecting this information enables us to better understand the behaviour of survey respondents and study participants, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes. If we use cookies to collect this information, we will let you know and will provide you with more information about this.

2.3 In some instances, BSNA may commission a third party research partner to carry out Research Surveys on our behalf. Where this happens, the research partner may act as a separate controller in relation to the personal information that you provide in response to the Research Survey. As such, we recommend that you familiarise yourself with the privacy notice of that research partner, before providing any responses. Where we use a research partner, the majority of the data we receive will be aggregated or statistical results from this partner about the responses collected for that Research Survey(i.e. rather than any information that could be directly attributed to you, or your response to the Research Survey, in a "real-world" sense). As above, the extent to which we will receive personal information about you (for example, whether we would receive responses that would be attributed to you by name or whether we could contact you to conduct a follow up telephone survey) in relation to each Research Survey will be made clear to you before you choose to participate in that Research Survey.

2.4 Your responses to the Research Surveys will be used the purposes of market research and to help us to develop or promote our policy decisions ("Research Purposes"). We will not typically refer to you (or your responses) by name when developing or promoting our policy decisions; however, if we want to do this, we will only do so where we have your consent.

3. HOW WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION

3.1 We may share your information with third parties when: (1) it is necessary to involve a third party service provider in order for us to carry out the Research Purposes; (2) we have a legitimate business purpose to share this information with members of our trade association, or with other similar trade associations or partners, for the purposes set out in this Privacy Statement or notified to you when we collect your personal information; (3) explicitly requested by you; or (4) required by a court order or any legal or regulatory requirement.

4. SENSITIVE PERSONAL INFORMATION

4.1 We do not typically collect sensitive personal information (including, but not limited to, health data) in relation to our Research Surveys. However, if you are asked to provide a response to a Research Survey that may contain (or may infer) sensitive personal information, this will be made clear to you at the time that you complete the Research Survey. We will only collect and use sensitive personal information where we have your explicit consent.

5. DATA RETENTION

5.1 We will not retain your personal information for longer than is necessary for our legitimate business purposes as described in this Privacy Statement, or for legal requirements (although you can request the deletion of your personal information at any time by contacting us via the contact details in paragraph 10 of this Privacy Statement).For example, where BSNA collect or receive non-anonymised data, BSNA will retain such data for a maximum of five years from collection. You can request details of BSNA's retention policy , by contacting us via the contact details in paragraph 10 of this Privacy Statement.

6. DATA SECURITY

6.1 We apply appropriate security measures to protect your personal information that is under our control, from unauthorised access, collection, use, disclosure, copying, modification or disposal. All personal information you provide to us is stored securely on our secure servers.

6.2 If your personal information is transferred overseas, BSNA will ensure that adequate steps are taken to ensure the security and confidentiality of your personal information as required by applicable data protection law.

7. TRANSFERS OVER THE INTERNET

7.1 As described in paragraph 3, we may transfer your personal information to our service providers who help us carry out our Research Purposes. These service providers are typically based in the UK. However, if we need to transfer your personal information to a country that may have less legal protection than the UK (or the country in which you reside), we will ensure that we do so in accordance with data protection law; and that we will continue to use your personal information securely, lawfully and in the manner we describe here.

8. YOUR RIGHTS

8.1 Consent – If BSNA collects and uses your personal information in relation to Research Surveys on the basis of consent, this will be made clear to you at the time that you are asked to participate in the Research Survey. If this applies, you have the right to decline to provide your consent; and/or (if you do choose to provide your consent), you can withdraw your consent at any time.

8.2 Legal basis of processing – As above, unless we have informed you that we are processing your personal information on the basis of consent, we will typically process your personal information on the basis of our legitimate interests, so we can better understand market attitudes in relation to our research topics and to inform and develop our policy decisions (which may include publishing aggregate results). We may also process your personal information if we have a legal obligation to do so.

8.3 Right to rectification – BSNA will use all reasonable endeavours to ensure the accuracy of personal information. It is your responsibility to ensure that you submit true, accurate and complete information when you respond to the Research Surveys. You have the right to request that any inaccurate personal information held by or on behalf of BSNA is corrected, by contacting us via the contact details in paragraph 10 of this Privacy Statement.

8.4 Access In accordance with local laws, you may have the right to access the personal information held by BSNA. Please note that before we are able to respond to your request we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond within an appropriate timeframe and, in any event, within the timescales required by law. For further information, please contact us via the contact details in paragraph 10 of this Privacy Statement.

8.5 Right to Data Portability – You may have the right to receive your personal information in a format that would enable you to transmit such personal information to another company. You can request such personal information by contacting us via the contact details in paragraph 10 of this Privacy Statement.

8.6 Right to erasure – You may have the right to request that BSNA delete all of the personal information that we hold about you. If you would like BSNA to erase the personal information that we hold about you, please contact us via the contact details in paragraph 10 of this Privacy Statement.

8.7 Right to object – in certain circumstances, you may have the right to object to our processing of your personal information. If you would like to object to BSNA's processing of your information, please contact us via the contact details in paragraph 10 of this Privacy Statement.

8.8 Right to restrict processing – You have the right to restrict BSNA from processing your personal information, by contacting us at the details provided in paragraph 10, where: (1) you believe that the personal information held by us about you is not accurate, until we can verify the accuracy of such personal information; (2) you believe that the processing of your personal information is unlawful; (3) you believe that we have no longer have any reason to process your personal information, except for the purposes of establishing, exercising or defending legal claims; and (4) you object to the processing, unless and until BSNA can establish that we have legitimate grounds to continue processing your personal information. If you would like to exercise this right, please contact us via the contact details in paragraph 10 of this Privacy Statement.

9. CHANGES TO THIS PRIVACY STATEMENT

9.1 This Privacy Statement was last updated on 14 August 2020. We may update this Privacy Statement from time to time in response to changing legal, technical or business developments. When we update our Privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Statement changes if and where this is required by applicable data protection laws.

10. QUESTIONS ABOUT THIS PRIVACY STATEMENT

10.1 The Privacy Statement is maintained by BSNA. If you have a question, concern or complaint about this Privacy Statement or our handling of your personal information, you can contact Declan O’ Brien at BSNA:

Email – info@bsna.co.uk

Post – British Specialist Nutrition Association, 10 Bloomsbury Way, London, WC1A 2SL.

11. RIGHTS TO COMPLAIN TO THE DATA PROTECTION AUTHORITY

11.1 If you have a complaint or concerns about how we are processing your personal information then we will endeavor to address such concerns. However, if you would like to direct your complaint/concerns to a Data Protection Authority, you can contact the UK Information Commissioner's Office at: Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Tel. +44 03031231113 e-mail: casework@ico.org.uk Website: https://ico.org.uk