Privacy policy

Last updated November 2025

Your privacy is important to us at Old Salt and this privacy notice provides you with details of how we collect and process your personal data.

Contact Details

Our full details are:

  • Full name of legal entity: Old Salt Ltd.
  • Email address: dpo@oldsalt.uk
  • Postal address: 30 High Street, Leighton Buzzard, England, LU7 1EA

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at dpo@oldsalt.uk

IF YOU ARE A RESEARCH PARTICIPANT

WHAT DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUNDS DO WE PROCESS IT?

Personal data means any information capable of identifying an individual. It does not include anonymised data.

If you are a research participant we may process the following information about you during the course of a market research study:

  • Full name
  • Phone number
  • Email address
  • Postal address
  • Potentially bank details (if your incentive is paid with BACS)
  • Other demographic information such as profession and age
  • Product information you may have with one of our clients
  • Your opinions
  • Photos of you, or photos that you share with us
  • Audio and video recordings of the market research sessions

We would typically request your consent to process this information but on occasion we may also rely on our client’s legitimate interests for processing customer information for market research purposes.

If there is a requirement to collect and process sensitive personal data (such as gender, ethnicity, political opinions, religious beliefs, trade union activities, physical or mental health or sexual life) we will obtain your explicit consent and provide a full description of how it will be used and where it will be located.

HOW DO WE COLLECT YOUR PERSONAL DATA?

Depending on the project, Old Salt will obtain contact details in a number of ways.  These include:

  • From one of our clients, who you are a customer of or have had contact with in the past
  • From a research panel that you have signed up to in the past and for which you have consented your personal information to be used for invitations to future market research studies
  • From one of our third parties who have previously made contact to invite you to conduct market research activities
  • From information that is publicly available.

Old Salt sometimes obtains contact details from its clients, usually where you have had some contact with them previously and they are seeking feedback on a service they provide to you.

If your contact details have been provided to us by one of our clients, you will either have agreed to this when you gave them your contact details (consent) or they should have informed you that your information may be passed to third party research company such as Old Salt. In this case the information provided to us is done so either under our client’s legitimate interests to conduct the research or where they are a public authority, and that it is necessary to share the information in order to conduct the research task in the public interest.

Our clients will sometimes give us additional information about you, along with your contact details, but this will only be information needed for conducting or reporting the research. We will not seek to pass back any information which could identify you without your explicit consent, unless you are otherwise informed during the course of the research.

We may have also received your information from a third party you have previously been in contact with and with whom you have actively agreed that they may pass your contact details on to market research companies like Old Salt.  If this is the case, we will let you know how and where your personal data will be used during and shortly after the research. We will then request consent to participate from you before the research starts.

We want to make sure that you are happy for us to use your information for market research purposes. If you think that your details should not have been passed to us, please inform us by dpo@oldsalt.uk so that we can raise the concern with the organisation that provided us with your contact details.

HOW WE USE YOUR PERSONAL DATA

Your personal data is used by us to assist in our market research activities. These activities include:

  • Contacting you to invite you to participate in a market research survey
  • Attendance checking and coordination activities during face-to-face research interview sessions
  • For internal quality control purposes
  • Recording your research responses as either audio / video files or as text files, depending on the research methodology used.
  • Sharing with carefully selected third party vendors to conduct additional processing activities relating only to the research survey you have participated in
  • Reviewing your research responses in combination with the responses obtained from others in order to identify trends and key messages
  • Feed back to our client via anonymised findings we believe to be of interest to them
  • Using carefully selected AI tools to extract insights from qualitative video and audio recordings

At the start of these activities you may be asked for consent to an audio / video recording of the session being made. The recording is simply to enable our researchers to more easily and accurately report on the findings of the session. These recordings are typically kept for 6 months after the end of the research study, or longer in certain circumstances (in which case you will be advised of the actual period during the interview or discussion group), but they will be deleted after this time.

In obtaining your cooperation, we will not mislead you about the nature of the research or the use that will be made of the findings.

We will not send you unsolicited email or pass on your email address(es) to others for this purpose. If we want to send you future email or contact you using other methods, we will ask your explicit permission for this.

WHERE YOUR PERSONAL INFORMATION GOES

It is our intention to be as transparent with you as possible with regards to who we may need to share your personal data with to fulfil our research. Before you start your research with us we will let you know who we will share your information with strictly for the purposes of conducting necessary and legitimate additional market research activities.

During the course of a research programme your personal information may be shared with the following types of organisation:

  • Recruiters (who will invite you to participate in research on our behalf)
  • Fieldwork agencies (who may conduct interviews on our behalf)
  • Research viewing facilities (who provide rooms, recording facilities and coordination services for our interviews)
  • Online platforms (which we use to host online research activities)
  • Video streaming partners (if we conduct any live streaming of any face-to-face interviews)
  • Our clients – Your full name / email address will only be known to our client if you are a customer and / or we have told you upfront it will be shared with them. Video recordings of research may be shared with our clients, and they may view research sessions remotely
  • Transcribers (who may transcribe recordings)
  • Videographers and video editors (who may perform editing activities on our behalf)
  • Law enforcement (only if required to do so).

Old Salt utilises a carefully selected network of third-party vendors for market research related data processing and analysis. These organisations are contractually obliged to solely use your information for research and statistical purposes and safeguard your information from unauthorised disclosure or modification.  They are also contractually obliged to delete your information in line with an agreed retention period.

Old Salt may need to transfer your data outside of the UK / EU in order to complete research activities or fulfil our contractual requirements. We will always make sure we do the following if this is required:

  • We’ll ask for your consent to do this before you start your research session with us
  • We’ll ensure there are acceptable cross border transfer mechanisms in place (e.g. UK-US Data Privacy Framework for US companies, or EU standard contractual clauses for transfers to other organisations outside the EU)
  • We’ll ensure adequate security mechanisms are in place to protect your information.

We will never sell or rent your information to third parties.

We will never share your information with third parties for additional marketing purposes.

HOW LONG WE KEEP YOUR PERSONAL DATA FOR

Unless a longer retention period is required by our client, or by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted.

Most personal information held about you by us in order to conduct our market research activities will be retained for 6 months after the completion of the work. This is to ensure we can respond to any validation requests from our clients or otherwise complete the provision of our services to our clients.

All information is securely deleted as soon as the retention period has been met.

We need to keep any signatures you provide against the receipt of monetary incentives for seven years to meet statutory requirements.

IF YOU ARE A WEBSITE VISITOR, CLIENT, OR OTHER CONTACT

If you are a visitor to the website and / or a client we may also process the following types of personal data:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details and purchase details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide and develop our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us to stop sending you marketing messages at any time by emailing us at dpo@oldsalt.uk  at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, requesting a quotation etc. 

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in section 2:

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Countries outside the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the UK, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK and European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the UK and European Commission which give personal data the same protection it has in UK or Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the UK-US Data Bridge, or equivalent, which requires them to provide similar protection to personal data shared between the UK and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

At Old Salt we make best efforts to ensure your personal data is protected at rest and in transit throughout its lifecycle (from creation, processing, sharing, through to deletion).

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Your personal contact data is saved in files that are permanently password protected using Government grade AES encryption.

All video and audio footage is kept on encrypted hard drives.  If we need to share audio or video footage with a third party we use carefully selected file transfer services that provide end-to-end encryption.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We typically retain your data for 6 months after the completion of the work. We will inform you if this time period differs.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at dpo@oldsalt.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

USE OF COOKIES

Cookies are text files used on this website to allow the integrity of the registration process and to personalize the website for Old Salt. Cookies are placed on your hard disk to enable recalling of your specific information whenever you make visits back to the website. By having cookies recall your information it provides you with a good experience when you browse. Cookies cannot be used to run programs on your computer or advise you about viruses. This site uses cookies to ease site navigation, to deliver related content, and may collect information for statistical use, like how many visitors our site receives. You are able to accept or decline cookies at any time, along with erasing cookies from your operating system at any time. Please note that when you decline or remove cookies, it may prevent you from experiencing all the features this website provides.

CHANGES TO OUR PRIVACY POLICY

Old Salt may modify or update this Policy when necessary, to reflect customer feedback and changes in our services. Please review it regularly. When we update this Policy, we will revise the ‘Last Update’ date at the top of the Policy. If there are material changes to the Policy or in how we use your personal data, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Policy to learn more how we use and protect your information.

COMMENTS ON OUR PRIVACY STATEMENT

We welcome any comments you may have regarding this privacy statement. If at any time you believe we have not adhered to this privacy statement, please contact us electronically and we will use commercially reasonable efforts to promptly determine and remedy the problem.