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PRIVACY NOTICE

Privacy Notice

Last updated: 12/10/2023

Here at Best Companies, we care about being transparent in how we use the
personal data we receive. Please read our privacy notice below to understand
what we do, and how we do it.

Who are Best Companies?‍

Hi, we are Best Companies, the workplace engagement people. We want to help make
the world a better workplace. We truly believe that people who are fully engaged
at work feel happier and more secure, which makes them more productive.

True employee engagement is a journey, not a destination. Guided by our five key
principles Care, Humility, Responsibility, Hunger and Discipline, we work with
organisations to provide them with the information they need to understand what
it is really like to work for them.  

Best Companies provides the standard for workplace accreditation. Accreditation
tells your clients, partners, investors, and employees that your organisation
understands the importance of workplace engagement and genuinely values its
people.

Best Companies is also the company that provides the research and data analysis,
for The Best Companies to Work for lists recognising the very best companies,
nationally, in sector and regionally.

The Best Companies Accreditation and Best Companies to Work for lists uses our
academically developed methodology. Our unique system looks for patterns,
connections and correlations between employee responses which we measure to
provide a Best Companies Index Score. Those that make one of our lists or
achieve a Best Companies Accreditation are truly worthy of being branded one of
the ‘Best Companies’ to work for.

Today we work with some of the world’s best-known organisations: measuring,
improving, and recognising great workplace engagement.  Please visit our website
at www.b.co.uk/about to find out more.‍‍

The below information outlines the processing we undertake.

The personal data we receive, directly from an organisation that we are
providing a service to, an individual completing a survey or an enquiry from.
Personal data will be used for the purposes outlined below.

‍We will never sell your personal data to anyone, ever.

‍Why and how do we collect information?‍

Majority of the personal data we process is to provide the organisation you work
for, the tools and expertise that will enable them to monitor engagement over
time and improve. The features, services, and websites we provide, offer an
accurate insight into the engagement levels within an organisation, assisting
employers to inform, meet and monitor their people strategy needs.

We also use the statistical data we collect for research purposes with the goal
of discovering new information, informing conclusions, and supporting
decision-making into better understanding of employee engagement.

Please watch the video in the link below to understand how we use the data we
receive.
https://www.b.co.uk/insighthub/how-we-keep-survey-responses-anonymous‍

‍We collect information through various ways. Below outlines, how we collect the
information we hold:

‍Completing a b-Heard survey: The b-Heard survey can be received three ways, a)
electronic survey (via email) b) paper survey c) login code (complete survey
online by inserting a code). Your employer will decide which type or combination
of survey, best suits your organisation. Each survey is allocated to a specific
individual. Best Companies needs to know who you are and where you sit in the
organisation structure, so we can create meaningful insightful reports for your
organisation. You will notice there is nowhere to write your name. This is
because we want you to be able to answer the b-Heard survey honestly, and for
your survey responses to remain anonymous to your employer. Therefore, we can
identify you, but your employer cannot. We will never identify you against your
responses to your employer.

We will ask you a range of questions about your employer, your manager, the
management team and in some cases information about you. This ensures we
accurately measure your organisations overall engagement and generate a
customised report for your workplace. It is important that you answer honestly,
so that your employer receives a true reflection of their employee engagement
stance. This means they get the information they need to improve. Data collected
through a b-Heard survey will become part of the Best Companies database which
holds over 5 million responses. Survey responses do not become part of your
employer's dataset, so we can ensure that your responses are protected and
remain anonymous. The Diversity survey we may be asked to include with the
b-Heard survey is to assist your employer with ensuring equality of opportunity
or treatment within your workplace.‍‍

‍Browsing our website: We will ask for your consent to receive cookie
information when it is not a required cookie, this is for recording the web page
you requested and to record information on our server logs from your browser,
including your IP address. This helps us ensure the integrity of the survey,
identify the countries we are covering and how people are using our Best
Companies websites for us to be able to make future improvements. For further
information in relation to how we use cookies, please view our cookie
policy https://www.b.co.uk/cookiepolicy.‍

Requesting further information: Where you request further information on our
services, you may be asked to provide your email address. In providing your
email address, you are allowing us to contact you in relation to your enquiry
and to receive information on related services we provide. You may opt-out of
these communications at any time..

Businesses that use our Services: The services we supply to your employer
requires them to provide certain personal data to us about you, for us to
provide the services. Please read the information below to understand how we use
the data we are provided to provision the services.

Best Companies Accounts: Your employer will nominate personnel within the
organisation or an external consultant to manage the process, review and access
the reports, and provide additional information to allow Best Companies to
provide the purchased services. Those individuals provided with Best Companies
accounts may include your organisation project manager(s), managers and/or your
employers third party consultants. The employer will determine who receives
access to our website services such as The Dashboard, Workplace Insight Tool,
and MC³. In some of the websites, you may personalise your experience such as by
uploading your photo. Where you choose to add content to your Best Companies
account, this may be visible to others within your organisation where granted
access and Best Companies employees where they have a requirement to access your
account to provide the services. For data collected within our onsite
applications, Best Companies is the Data Controller. Applications Privacy
Notice‍

‍Feedback Surveys: We may contact individuals from time to time for feedback on
the services we are providing. These can include project managers, marketing
representatives and individuals using our services/applications or that have
attended a Best Companies event. This feedback may be requested within the
application, or we may at times use a third-party survey platform. These third
party platforms include LinkedIn InMail or for anonymous feedback we use
SmartSurvey. You may opt to identify yourself within the anonymous feedback
survey; this is for us to respond to you directly in relation to the experience
you have received. Best Companies is the Data Controller of these activities..

Publication and recognition in association with Best Companies. We may on
occasion have a requirement to share the contact details of a PR representative
and/ or Project Manager(s) to a third party. This is to outsource to external
writers for conducting interviews and writing editorial pieces. The names and
contact details of the appropriate organisation representative are provided by
the employer within the culture insight, which is completed during survey setup.
The information shared will be the minimum required for them to make contact
about your accreditation, list position or award. Best Companies is the Data
Controller of these activities.

‍Your Data, Your Rights: You have a right to be informed of personal data
processed by Best Companies, a right to request rectification/correction,
erasure and to object to the processing. You also have the right to request
access to your personal data. We can only adhere to a request if we hold
personal data about you and are able to identify you. Where your employer
provided the information to us, they are the Data Controller, and you will need
to send your request to them directly. We will forward all requests we receive
to the Data Controller. Due to the extent of the processing Best Companies
conducts, Best Companies also becomes a Data Controller in their own right,
separately to your employer. We recognise your employer as the main controller
of data they have shared with us. Therefore, we will only continue holding
personal data on their instruction in relation to the services, which we only
retain in the invested interest of the employer for the provision of the
services. The final decision on a request in relation to rectification,
objection, or deletion for any personal data that we store on behalf of your
employer is with your employer who requested the services. Whilst your employer
will consider a request, they may not be able to accept your request, where they
require us to retain the data in their legitimate interest for the provision of
the services. Where Best Companies has collected personal data directly from you
such as through the b-Heard survey, we are the Data Controller of this
information. You can register a complaint about the handling of your personal
data with the ICO, who are the supervisory authority for UK
GDPR. www.ico.org.uk/concerns‍‍‍

‍What information do we collect?

‍The b-Heard Survey Process‍

Where an employer or individual representing an entity has accepted our Terms of
Service Agreement to receive the purchased service.

For all survey types, we require the first name, last name, and a unique
number/payroll number of all your UK employees. This is to ensure data accuracy,
quality control and fair processing.

When surveying by Paper or Login Code by Post, we require the destination that
the survey needs to be delivered to (Survey Delivery Location) e.g., head
office, this will then be printed on the covering letter/Login Code by Post
survey to assist with distribution.

Where employers opt for electronic survey delivery, we will require the
employees email address. In line with best practice for security purposes, an
email delivery of a b-Heard survey (sent from survey@b.co.uk) will be
personalised to the employee, this is to assist in identifying a genuine email
from Best Companies. We have also found there is a higher response rate when
surveys are personally addressed.

To get the most out of the reporting and your employer’s investment in our
services we may also be provided by employers some demographics in advance; this
saves the individual time in completing the survey and ensures data accuracy for
the anonymous reports we create. These demographics may include Employment
Group, Manager Name, Job Grade, Date of Birth, Employment Start Date, Sex,
Contracted Weekly Hours, Salary Band.

All details provided to us by your employer will remain hidden, as we do not
need to request this information again from you. Information that we need you to
complete will be displayed for you to fill in.

Where we receive an employment start date and date of birth, this is converted
and saved as a banding as part of the processing. The individual date of birth
and start date entries are deleted from our systems on the release of the
reports to your employer.

There are some demographics that we will only collect directly from you, rather
than enabling your employer to provide in advance. These may include how many
hours you work in a typical week; how much time you spend working from
home/remotely; how many days you travel to the office/workplace; how you get to
work; how much time it takes you to get to work; whether you’ve taken a day of
sick leave in the past month; whether you’ve applied for a new job in another
organisation in the past six months and the composition of your household.

We may also measure your wellbeing through the World Health Organisation,
‘WHO-5’, where, in response to five statements,  we will ask you to tell us how
you’ve been feeling over the last two weeks.‍

‍Anonymity‍

Anonymity is the biggest concern individuals have when they complete a b-Heard
survey. For voices to be heard and actions to be taken, we require you to answer
your b-Heard survey truthfully. Incorrectly responding to a b-Heard survey, you
are rendering the survey as useless and therefore the result meaningless. Please
be assured your individual responses are never accessible by anyone associated
with you or at your workplace. Please be assured we will always keep your survey
responses confidential.‍

‍Diversity Monitoring‍

Where employers have a duty to monitor diversity levels, they may request that
we include a diversity questionnaire alongside the b-Heard survey. Where this
additional questionnaire has been requested, you may be asked to provide
responses to questions that are deemed to be more sensitive to you e.g., race,
religion, sexual identity, gender identity and disability. We will be the Data
Controller of this data as we are for your responses to the questions on the
b-Heard survey. Your individual survey responses will not form part of your
employer’s dataset.

Diversity reporting: Where the diversity questionnaire is used, we will provide
your employer with a report of the total counts of each diversity field. To
comply with the general equality duty, some organisations need to have an
adequate evidence base for their decision-making. By collecting and using the
equality information, we may work with organisations to create bespoke reporting
(on request) to better understand the needs of staff from different protected
groups and thereby improve the efficiency of the organisation.

Before you complete the diversity questionnaire, we will inform you the
information that we are about to collect is considered to be more sensitive and
is to assist your employer in monitoring diversity levels for the purpose of
equality of opportunity or treatment. Our research team will then use the
collated diversity data responses, with the goal of discovering useful
information, informing conclusions, and supporting decision-making into better
understanding of equality. Your individual responses will remain anonymous. This
processing is conducted under the lawful basis of Article 6(f); the lawful
condition of Article 9(2)(j) and in accordance with Article 89(1) of the GDPR.‍

‍Survey comment box

At the end of the survey, you will be provided the opportunity to give direct
feedback. Best Companies will review samples of responses and conduct comment
analysis, this is to ensure the integrity of our accolades. Depending on the
subscription service being provided, some employers will also receive your
comments as direct feedback. We will not specifically identify you with the
feedback, however, do take care not to identify yourself by describing something
personal, which would only apply to you.

‍Non-Survey Information

‍Our websites and cookies‍

Website usage data is collected by cookies (with your consent) to provide Best
Companies with analytics. Data is tracked at visitor level, to understand how
the site is used. The ability to attribute marketing leads from across multiple
campaigns, ads, and keywords. This gives us an insight on how a visitor arrived
at our website, what device is being used, such as a phone, tablet, or desktop,
including interactions whilst on our site, such as the option to phone Best
Companies. All of these analytics combined allow us to further develop our
websites, improve the experience of visitors and measure where our marketing
initiatives have been successful.

We use:

Web analytics tools which track website user activity. Tools like Google
Analytics allow us to track data to analyse our website performance and measure
the impact of our marketing campaigns on traffic and lead conversion metrics.

Attribution analytics tools cover web activity, but also break down the barrier
between marketing and sales by identifying which channels are driving revenue,
not just clicks and conversions.

These analytics, collected with your consent, include page viewed, links
clicked, activities, behaviour and interactions, which are tracked via your IP
address. The cookies that we would like to use are further outlined within our
Cookie policy.

‍Best Companies Live‍

The world’s largest employee engagement event, Best Companies Live.

Organisations can invite their staff to join online through their company
dashboard. Only a first name and email address will be used for this processing.
Individuals can choose to add additional content on the platform.

Individual subscribers can also join us by registering to join our online
events. Please read the privacy notice and visit the site for more information
and to register for the event. https://www.bestcompanies.live‍

‍Great Manager‍

If you are an individual who has made a nomination or been nominated to be
recognised as a Great Manager, this is a separate initiative not covered by this
privacy notice, please read the privacy notice for this initiative
at https://www.greatmanager.co.uk‍

‍2Q Instant Insight Service‍

If you are an individual or your employer has registered for the 2Q Instant
Insight, this is a separate service not covered by this privacy notice, please
read the privacy notice for this service at https://2q.b.co.uk‍

‍Recruitment‍

We're looking for awesome people...

You can apply directly for positions through our website https://careers.b.co.uk
or send your CV with a cover letter to careers@b.co.uk

Where applying online you are required to upload your CV, for us to assess your
application. We will also ask for you to supply your name and email address. If
your application meets the job’s requirements, then one of the team will be in
touch soon to discuss the next steps.

We may retain recruitment information and details of applicants for up to 12
months. If you have been referred via a recruitment agency, they are a separate
controller you should read their privacy notice for details of their processing.

‍Third-party sites‍

We also display links and content to other websites that are not owned or
controlled by Best Companies such as Vimeo Privacy Notice and YouTube Privacy
Notice. Please be aware that we are not responsible for the privacy practices of
such other websites or third parties. We encourage you to be aware of when you
leave our websites and to read the privacy notices of each website that collects
personal information.‍

Third party, Google Analytics, applied with your consent as part of the cookie
banner. This software conducts tracking, location and page hits that assist us
in the improvement and optimisation of the analysis of data supplied via the
Best Companies platform for content enrichment, our marketing activities and
lead generation purposes, including Google location API and any necessary
notices or consents for the collection and sharing of the data with Google.
Please view the Google privacy notice to view any necessary notices or consents
for the collection and sharing of the data with Google.‍

‍Website registration and web forms‍

When you register to the website, you may be asked for personal information
about yourself to register and/or download content. This information may
include, but is not limited to, your name, the company you work for, your e-mail
address and telephone number. By providing this information, you are consenting
to us contacting you in relation to your request or enquiry. We will only
collect information from you that is necessary for us to provide you with any
services or assistance connected with your enquiry. If you would like more
information on our services, do get in touch by completing our online enquiry
form at https://www.b.co.uk/contact. You may withdraw your consent at any time.‍

‍Billing

Best Companies uses WorldPay a third-party service provider for managing credit
card processing. WorldPay does not store, retain, or use billing information
except for the purpose of credit card processing on Best Companies behalf.‍

‍Awards Evening‍

At the Awards evening we will take images of winners of the awards and attendees
at the event. These images will be released into the public domain and used to
promote the Awards evenings and The Best Companies to Work for lists by both
Best Companies and publishing partners, they may also be used by organisations
for them to promote their achievement. We may also collect from you on the night
of your Awards Evening, with your consent, your name, organisation name, and
email address. This is to provide you with the images taken of you and your
colleagues at the photo booth. The contact data collected on the Photo
Nomination Voucher(s) will be retained by the photographer (the data processor),
for a period of 3 months, to assist us with any enquiries and by Best Companies
(the Data Controller) for a period of 12 months. You may withdraw your consent
and ask us to remove your personal data from our systems at any time.

‍Data Protection by design and default‍

Best Companies is dedicated to protecting all personal data we receive in line
with industry standards and best practise. All data is only accessible by
authorised personnel and Best Companies employees who are all contractually
subject to confidentiality. We take all reasonable steps to protect information
we receive from you from loss, misuse or unauthorised access, disclosure,
alteration, and/or destruction. We have put in place appropriate physical,
technical, and administrative measures to safeguard and secure your information,
and make use of privacy-enhancing technologies such as encryption. An external
auditor conducts an annual vulnerability assessment and penetration test on our
systems. We also continually monitor our security posture as part of our ongoing
risk management strategy.

Best Companies has achieved ISO 27001 the information security standard and the
ISO 9001 quality standard. We are also registered with the Information
Commissioners Office. Our internal Data Protection Officer monitors our ongoing
processing operations to ensure they are lawful and compliant with data
protection laws and regulations, such as the UK Data Protection Act 2018, the
General Data Protection Regulation (GDPR) and the Privacy and Electronic
Communications Regulation (PECR). We view our compliance, as GDPR aligned. We
continue to focus on ongoing GDPR requirements, such as evaluating the data
protection impact of new products and services on our users’ personal data and
training employees about protecting the privacy of personal information. We have
documented procedures for Incident Management and Data Subject Requests and have
implemented appropriate company policies to protect the data we hold.

To provide the purchased services we use a select number of trusted external
service providers. These service providers are carefully selected and meet with
high data protection and security standards. We only transfer information that
is required for the services offered and we contractually bind them to keep any
information we share with them as confidential and to process personal data only
according to our instructions. These service providers are also known as data
processors, who we use for the provision of our services.  Personal data is
stored within the United Kingdom and European Economic Area (European Region).
Personal data is not transferred outside of these areas.

Best Companies data processors:

Microsoft Azure and SQL database: (Location: United Kingdom, Netherlands)
Required to host our live websites and to store and process the site files and
data.

Barracuda Networks: (Location: United Kingdom) Data from our on-premise server
cluster, is replicated securely to the Barracuda data centre to provide our
offsite cloud backup.

Mailgun Technologies: (Location: Germany) Required to manage our transactional
email delivery to clients.

Salesforce: (Location: European Economic Area) Used by Best Companies to
maintain business operations, customer relationship management.

FreshWorks and FreshService: (Location: European Economic Area) Used by Best
Companies to maintain business operations, and IT service management.

As part of the service provision some of the data processors may transfer the
data to a different country than stated above e.g., for Geo-redundancy. For the
avoidance of doubt the transfer will only be within the European region.

Zivver: (Location: European Economic Area) A secure way to transfer large files
or confidential information to and from Best Companies, which we may also use to
transfer data at your request securely to an individual or organisation.

As part of the service provision some of the data processors may transfer the
data to a different country than stated above e.g., for Geo-redundancy. For the
avoidance of doubt the transfer will only be within the European region.

‍International transfers of personal data‍

On the 28th of June 2021, the EU approved an adequacy decision after determining
that the UK had an “essentially equivalent” level of data protection to the EU,
meaning that data can continue to flow between the EU and UK as it did before,
in most circumstances. This decision is expected to last until the 27th of June
2025; however, the European Commission must monitor developments in the UK on an
ongoing basis.

Best Companies is located in the UK and our data processors that are assisting
us in processing personal data, are located within the UK and the EEA. No
personal data will be transferred outside of the UK/European Region. As part of
the service provision some of the data processors may transfer the data to a
different country for Geo-redundancy. For the avoidance of doubt the transfer
will only be within the European region.

As part of our considerations, Best Companies has instructed Ametros Group as
our EU Representative in accordance with Article 27 of the GDPR for EU
supervisory authorities and EU citizens. Individuals situated in the EU wishing
to request their individual rights may either contact Best Companies directly or
Ametros Group.

Where an international data transfer agreement is required, please contact
privacy@b.co.uk.‍

‍Lawful basis for the processing

‍Purchased services‍

The processing between Best Companies and your employer for the survey and
organisation reporting is completed under the legal basis found in Article
6(1)(f) of the GDPR, the processing is necessary for the organisation’s
legitimate interests. The employer has legitimate interests in sharing the data,
for Best Companies to process, to measure employee engagement in the
organisation; to inform the people strategy; and to improve engagement in the
workplace. Processing is required to ensure that the organisation is a good
employer; who are looking after their employees; being recognised as a ‘Best
Company’ on gaining an Accreditation or place on the lists; for the positive
national PR; and retention and attraction of top talent. Best Companies and your
employer share personal data between our companies on the legal basis of
legitimate interest.

The UK Information Commissioners Office acknowledges that companies may have a
“…legitimate interest in processing data as long as the processing does not have
a disproportionate impact on the individual.” On balance, the legal basis of
legitimate interest against the individual impact: the services are reasonable,
the company’s interests in the services appear compelling, and with there being
little impact on the individual. The services are not considered high risk
processing.

‍Best Companies processing for research purposes‍

Best Companies conducts additional research on the survey responses and
demographical data under the lawful basis of Legitimate Interest as sole Data
Controller, under the GDPR historical, scientific and statistical research is
deemed compatible processing. This processing is required for:

 1. the statistical research, which is required to assist employers with
    understanding how employee engagement impacts their organisation in
    comparison to other organisations
 2. production of best practise content
 3. the ability to provide comparative historical research
 4. new learning for the benefit of the wider society in the form of white
    papers, case studies and articles

To the extent possible all data provided to our Research and Data Insight teams
for the above research purposes is pseudo-anonymised.

‍Information regarding our MC³ Product‍

MC³ is intended as a development tool for organisations to reflect on what they
are getting from their managers and their relationship with their team. MC³
should be used and considered as a resource, and when reviewing data, the
organisation should consider the wider context of the team. The purpose for MC³
is to help focus managers on those areas that will make them great
people-managers.

The UK Data Protection Act 2018, which includes the General Data Protection
Regulation, advises that you can carry out this type of decision-making when it
is necessary for the lawful basis of performance of a contract. Therefore, where
your organisation purchases the MC³ product, the lawful basis of this product is
Article 6(1)(b), where processing is necessary for the performance of a
contract, to which the data subject (employee) is party. Your organisation will
have a contract of employment with the employee that MC³ is reporting on, which
will include clauses, or can reasonably refer to one or more of the following:

 1. managing a team
 2. completing the job function to a certain standard
 3. personal development

On balance, we have reasonably determined that MC³ benefits the individual by
identifying where the individual is doing well and areas where they can focus to
improve. This level of insight will not only benefit the organisation for
meaningful conversations, but it can also really help the manager with their own
personal development and becoming a better manager.

Your project manager within the organisation, to ensure individuals are aligned
correctly to the reporting manager, will have reviewed the organisation
hierarchy provided by the organisation for accuracy. Managers will be asked to
verify their reporting structure at the end of the survey. MC³ is an automated
decision-making process, should an individual disagree with the results, we are
able to review manually. We recommend that organisations actively inform their
managers that they have purchased the MC³ product and how to make best use of
the learning outcomes.

We require a minimum number of survey responses, to provide MC³ reporting to
ensure anonymity.

‍MC³ Manager Accreditation‍

The Best Companies MC³ Accreditation Mark serves as an endorsement of your
professional integrity and recognition of your commitment to great leadership.
The design reflects the year you were accredited, and your achievement having
been recognised as either a One to Watch, 1 star, 2 star or 3 star rating. In
order to publicise your MC³ accreditation you will be asked to accept our MC³
Terms of use and code of conduct, you will be asked to consent to Best Companies
retaining your personal data for future verification purposes. We may contact
accredited managers from time to time in relation to their achieved
Accreditation.

‍Promoting your MC³ Accreditation

The MC³ Accreditation Mark indicates that you have gone through the Best
Companies MC³ process and have been recognised as either a One to Watch, 1 star,
2 star or 3 star Accredited Manager. To ensure that the use of the Mark is
reserved for individuals who have achieved the necessary standard we require
that the MC³ Accreditation Mark is only used in accordance with our MC³ Code of
Conduct and Terms of Use (available on request). These must be accepted prior to
use. Once accepted, you may use your Accreditation Mark in a wide variety of
places such as in your marketing literature, in advertising and on websites, at
exhibitions and social media as well as on business premises. Please contact
Best Companies if you have any queries regarding use of the Accreditation Mark.
You must not use the Mark in such a way that it implies that a particular
service or product is certified or has been tested by Best Companies nor should
the Accreditation be used on product certificates or in any way that may
misrepresent the MC³ Accreditation.

‍Retention‍

Employers have an invested interest for us to retain personal data for up to
three years following the lapse of the subscription term. Should an employer go
through an organisation restructure or require further insight from the data, we
can restructure the personal data held from the previous year(s) participation,
to correlate the reports from the newest b-Heard survey. Following an
organisation restructure, employers have a real need to understand the impact it
has made on their employees. The ability to be able to alter the reporting to
reflect the new organisation structure provides organisations with valuable data
that reflects the true position of the organisation against those previous years
surveyed.

We only continue to retain the personal data after the provision of services for
the benefit of the employer. An employer can make a written request, at any time
after the provision of services for us to delete the personal data we are
holding on their behalf, should they no longer require us to retain the personal
data. We delete personal data through an anonymisation process. We retain
demographics and employee responses indefinitely to continue our research into
employee engagement. To ensure fairness and transparency to the employee, we
would not accept a request to extend the max retention period.

We use a process of anonymisation at the end of the retention period or earlier
upon written request from the employer. Anonymisation means we delete the
personal identifiers, therefore anonymising the remaining statistical data for
our continued research. This is in line with the Information Commissioners
Office (ICO) anonymisation code of practice. The employee responses, which are
attached to employee demographical data, are not removed; this would result in
the inability to perform any future engagement reporting. This would also
similarly affect benchmark data and where organisations are being assessed for
Accreditation and a position on our lists. The Data Protection Act and General
Data Protection Regulation (GDPR) does not apply to data rendered anonymous in
such a way that the data subject is no longer identifiable.

We retain the statistical data for our continued research with the goal of
discovering useful information, informing conclusions, and supporting
decision-making into better understanding of employee engagement. Once
anonymisation has been completed, we are unable to reverse this process.

‍Billing‍

Best Companies uses a third-party service provider for managing credit card
processing. The service provider does not store, retain, or use billing
information except for the purpose of credit card processing on the Company’s
behalf. Best Companies is PCi DSS certified.

‍Compelled Disclosure‍

Best Companies reserves the right to use or disclose information provided if
required by law or if the Company reasonably believes that use or disclosure is
necessary to protect the Company’s rights and/or to comply with a judicial
proceeding, court order, or legal process. We will ensure the confidentiality of
all survey responses unless we are required to reveal them in exceptional
circumstances (in which case we will maintain as high a level of confidentiality
as possible in those circumstances) or as required by law.

‍Privacy Notice Changes‍

Best Companies may make changes to this privacy notice to align with our
operations and evolving laws. If we make changes to this privacy notice, we will
post those changes on our website, Privacy Notice and in other appropriate
places. We reserve the right to modify this privacy notice at any time, so
please review it regularly. If we make significant changes, we will notify you
here, or by other reasonable means. This privacy notice is currently only
available in English. In the event non-English translations of this privacy
notice are provided, it is done so for convenience only. In the event of any
ambiguity or conflict between translations, the English version shall always
take precedence.

‍Contact

If you have a question regarding our processing, you can email or write to us
your request to our Data Protection Office (contact details below).

Email: privacy@b.co.uk

Post: Best Companies Ltd, Hamilton House, Rackery Lane, Llay, Wrexham, United
Kingdom, LL12 0PB

To individuals situated in the EU, please may contact us directly as above,
regarding requesting your individual rights. Alternatively Best Companies has
instructed Ametros Group as our EU Representative in accordance with Article 27
of the GDPR for EU supervisory authorities and EU citizens (contact details
below).

Email: gdpr@ametrosgroup.com

Post: Ametros Ltd, Unit 3D, North Point House, North Point Business Park, New
Mallow Road, Cork, Ireland

‍Recording of Calls

When contacting Best Companies, some calls and Teams meetings will be recorded
for quality control and training purposes and retained for up to a month.

Where a Teams Video Meeting is selected to be recorded, this will be shown in
the ribbon on screen. These calls can be made accessible to those on the call
and may be reviewed for quality control and training purposes. Teams meeting
where selected to record will be retained for up to 6 months (audio and video).

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