DATA MANAGEMENT POLICY

Common law of confidentiality in association with scientific & statistical data research operations is employed to secure data that is to be co-mingled publicly to secure access to public and private commercial parties of interest.

Research conducted is only used to support legitimate research activities considered to be in the public’s specific requests and best interests.

POA’s (Power of Attorney’s) are maintained in accordance with the public interest in data research and statistical probabilities of success with each client.

Freewill requests are accepted and initiated on behalf of “the People” with unlimited powers to contract with specific data analysis execution algorithms exchanged on the public forums commonly accessible on/offline.

Our organizational assurances are in addition and combination to the controls research participants have in the use of their personal data through the normal data research consent process.

Our DPOs (Data Privacy Officers) ensure that the policies and procedures in place in our organization are appropriate to manage the risks posed to all data subjects (including research participants a.k.a. public clientele).

We feel informed, voluntary and fair consent is the cornerstone of ethical research and data analysis involving people. It is a mechanism, to ensure the rights of individual participants can be respected. It is through the consent process that data research participants can understand what taking part in a specific study will mean for them, so they can make an informed choice and feel able to express their wishes with us.

Data protection law requires us to be fair and transparent in how we process personal data. In other words, we must be open and honest with research participants about how we intend to use personal data, and the types of data we will be using with their privacy file. The consent process, whilst not being the only way, aids us in transparency and fairness for our research participants clientele. That is why we choose to have a confidential open and transparent consultation with all our participants.

Common law is no less important than statute (i.e. law that is written down in Acts, Regulations, etc.). You should be aware that our respect for the duty of confidence when accessing or sharing confidential information with our clients while undergoing research, will not change.

Your information is considered confidential in law if:

• It can be related to an identifiable individual (similar definition of identifiable as used for personal data, but personal data can only relate to a living person, confidential information can relate to the living or deceased), and

• It is not in the public domain (no such limit is placed on the definition of personal data), and

• It is given with the expectation that it will be kept confidential. Individuals do not have to be explicit about their expectations, when entrusting others with their information: this expectation is often implicit, given the relationship the individual has with us.

When an individual entrusts our research team with personal & confidential information, our team will handle the data in line with ‘reasonable expectations’.

Robustly anonymised information can be shared without having to consider reasonable expectations (Information has to be identifiable to be subject to the common law of confidentiality). Like with new privacy files used by research participants.

There are specific times when we may wish to share confidential information, for example to prevent a crime from being committed and/or where there are safeguarding concerns. In such cases, disclosing the information rather than keeping it confidential, best serves the public interest. The common law does allow disclosure when it is in the overwhelming public interest, even if the person involved might not expect this.

Putting it all together

Consent to participate in data research is at the heart of ethical research. Discussions about participation, and the information provided during the consent process, can help ensure that data is transparently held and used for ongoing research. Informed consent helps us act fairly and transparently, as required by data protection law. Consent helps us manage expectations in terms of who has access to confidential information (common law) as we process your data.