This policy was last updated on December 14, 2018.
By participating in our research and agreeing to this policy, you consent to our collection, use, and disclosure of information in accordance with the terms of this policy.
2. Information We Collect
Data that McKinley collects is used to further the mission, programs, operations and services of McKinley’s association and non-profit clients, and to provide the best possible experience for members and other stakeholders of these organizations.
There are two different types of data that can be collected: Personal Identifiable Information (PII) and Non- Personal Identifiable Information (Non-PII). PII is any information that can be used to distinguish or trace an individual’s identity, such as name, address, email, place of employment or other information that is linked or linkable to an individual. Non–PII data is anonymous to McKinley and cannot be used by McKinley to distinguish or trace an individual’s identity, such as responses to opinion questions on surveys that are not connected to PII.
Information we collect:
- Purchasing Data or Personal Characteristics – McKinley Advisors may have access to certain data or information regarding your participation with our client organization (association). Data may include contact information, such as your email or postal address, or telephone number; your participation on association committees, purchase or usage of client programs, products or services; and demographic characteristics collected and stored within our client’s database. This information is used by McKinley Advisors in connection with McKinley’s Research for research-purposes only in order to understand how your profile and past behaviors may correlate to your opinion, attitudes and future engagement with the association. This may include merging your personal information with data collected through telephone interviews, focus groups, surveys or other primary data collection. McKinley may also use any available contact information for the purposes of inviting you to participate in our primary research. Email addresses and contact information may be stored and validated through our partner, DataValidation, for the purposes of validating working versus non-working email addresses
- Primary Research Data – McKinley collects data and information from you directly when you participate in a telephone interview, focus group discussion, survey or other form of primary data collection that requires your direct, active participation in providing your thoughts, opinion, attitudes, past experience or personal information to McKinley. This information may or may not be collected through our secure survey platform, SurveyGizmo, stored on one of our secure analytical platforms, including MarketSight, Domo Inc., and/or Tableau, or warehoused for further analysis on McKinley’s computers or secure storage platform, Dropbox.
- Web Server Logs – This information may be collected through our survey platform, SurveyGizmo, should you participate in a survey or focus group through McKinley Advisors. Data collected include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring or exit pages, operating system, date/time stamp, and other auxiliary data that may be used to validate or understand data quality in our research surveys.
We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
Research participants can add, correct or update their personal information by contacting our data protection officer, Karli Susi, at email@example.com or +1-202-333-6250.
3. Providing Your Personal Data to Others
We may disclose your personal data to any member of our company. We may also disclose your personal data to suppliers or subcontractors insofar as reasonably necessary for the basis of validating data, conducting and/or reporting research analysis.
We may disclose your personal data to our client organization (association) for legitimate research purposes, or for other purposes which you consent as a participant in our Research.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International Transfers of Your Personal Data
McKinley’s sole headquarters office is located in Washington, DC, United States. Data transferred to the United States may be subject to government surveillance.
Personal data may be hosted by suppliers or subcontractors for the basis of collecting, analyzing, reporting or validating data. Suppliers and vendors are situated within the United States but may utilize storage in servers residing outside of the United States.
5. Retaining and Deleting Personal Data
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. As of May 2018, personal data that we collect through surveys and process for any purpose shall not be kept for longer than five years. Personal data collected through telephone interviews or focus groups may be maintained for up to as long as necessary for business purposes. Non-personal data (data not linkable to you) may be maintained indefinitely.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another person.
6. Policy Changes
We may update this policy from time to time by publishing a new version on our website. Check this page occasionally to ensure you accept any changes to this policy. We may notify you of changes to this policy by email or via website announcement on www.mckinley-advisors.com.
7. Your Rights
In this section, we have summarized the rights that citizens of the European Union have under data protection law and are extended by McKinley Advisors to all participants in our research regardless of their country of residence.
Your principal data protection rights are:
- The right to access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object to processing
- The right to data portability
- The right to complain to a supervisory authority (if data was provided from EU member state location)
- The right to withdraw consent
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access and request a copy of your personal data by emailing McKinley’s data protection officer, Karli Susi, at firstname.lastname@example.org.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If your personal information was collected from you while residing or located in an EU member state, and you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
You have the right to withdraw your consent for data processing at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to McKinley’s data protection officer, Karli Susi, at email@example.com or by phone at +1-202-333-6250.
8. Cookies Used by Our Service Providers
9. Our Details
Contact us at:
1227 25th St. NW
Washington, DC 20037
By telephone: +1-202-333-6250
By email: firstname.lastname@example.org
12. Data Protection Point of Contact
For any issues related to data protection or privacy, please email McKinley Advisors’ Data Protection Officer (DPO), Karli Susi, at email@example.com or call +1-202-333-6250.
This policy was last updated on Sept. 10, 2018.