Business Skills Transfer Study · Privacy notice
Business Skills Transfer Study: Privacy Notice
1. Who is responsible for your information?
The study is operated by:
Sole Trader Courses Ltd, trading as GROW Formula
Company number: 16406138
12 Charmind Walk, Swindon, SN25 1QA
Email: support@growformula.org
The company is the data controller for the study.
GROW also provides commercial business education and support. Individual research answers are not used for sales prospecting or identifying potential GROW Coaches.
2. What information do we collect?
Research responses
We collect:
- Your eligibility confirmations and agreement to participate, with the wording version and date.
- Your questionnaire answers, including any optional written responses.
- Submission date, questionnaire version and a randomly generated response reference.
- A securely protected record of your withdrawal code.
The questionnaire does not ask for your name, email address, practice name or contact details. Answers to questions hidden by routing are not retained.
Combinations of answers or written comments could identify someone, so we treat responses as personal data.
Please do not include identifying details, client information or personal health information in written answers. Unnecessary identifying or sensitive information will be removed or redacted where practicable.
Research invitations
If we invite you directly, we may use your name, professional role and public professional contact details. These may come from a professional website, directory or networking platform.
Our invitation will explain where we obtained your details and provide access to this notice. Invitation records are not linked to questionnaire answers.
Optional email subscriptions
If you subscribe separately, we collect your email address, chosen categories, confirmation status and records of your choices and withdrawals.
We do not link subscriptions to research answers using response references, withdrawal codes, timestamps, browser identifiers or other methods.
Technical information and correspondence
Service providers may process IP addresses, browser information and security logs to operate and protect the website.
If you contact us, we process the information needed to answer your enquiry or handle your request.
3. Why do we use your information?
We use information to:
- Invite relevant practitioners and administer participation.
- Analyse responses and prepare research findings.
- Produce your personal snapshot and grouped comparisons.
- Identify invalid submissions and protect the service.
- Handle enquiries and withdrawal requests.
- Send separately requested emails.
- Respect communication preferences and meet legal obligations.
We do not sell personal information or create marketing profiles from research answers.
4. Our lawful bases
| Purpose | Lawful basis |
|---|---|
| Selecting and contacting potential research participants | Legitimate interests |
| Administering and analysing responses, producing snapshots and comparisons | Legitimate interests |
| Protecting the website and maintaining data quality | Legitimate interests |
| Sending optional subscription emails | Consent |
| Handling general enquiries and voluntary study-withdrawal requests | Legitimate interests |
| Meeting statutory data-protection duties | Legal obligation |
| Maintaining consent and suppression records | Legitimate interests and, where applicable, legal obligation |
Our legitimate interests are to conduct proportionate research into business support, provide useful participant feedback and administer a secure study.
We balance these interests against participants' privacy through limited collection, restricted access, separate subscriptions and safeguards on publication.
Your agreement to participate is an ethical requirement of the study. It is separate from the lawful basis for processing research data.
5. Participation and withdrawal
Participation is voluntary. Eligibility confirmations are required, but substantive questions may be skipped.
Questionnaire answers are not saved to the research database until submission. Leaving or refreshing the page may lose an unfinished response. Necessary security logs are separate.
After submission, you receive a private withdrawal code. Use the website's withdrawal form or email support@growformula.org to request removal.
We remove responses that can still be identified in our research records. Without your code, we may be unable to locate your response, although we will consider other information you can reasonably provide.
An individual contribution cannot be removed from effectively anonymised findings. Withdrawal will not normally lead to previously published aggregate reports being retracted. Removed responses are excluded from subsequent calculations.
These arrangements do not limit your statutory rights.
6. Who can access information?
Access is limited to:
- Authorised personnel administering the study.
- Service providers supporting hosting, storage, security and email delivery.
- Research collaborators where necessary and subject to appropriate agreements.
- Advisers or authorities where disclosure is legally necessary.
Individual responses are not supplied to employers, training providers, other practitioners or subscribers.
Published findings are grouped. Small counts are protected under the study's comparison rules. Written comments are not displayed automatically; any proposed quotations are reviewed for identification risk.
7. Hosting and international transfers
The website uses Lovable Cloud, with its research database hosted in Ireland.
Website delivery, technical support and security operations may involve processing outside the UK and European Economic Area.
Optional subscriber emails use Mailchimp, provided by Intuit in the United States. We share the subscriber information needed to administer those emails, not research answers or withdrawal codes.
Where a restricted international transfer occurs, an applicable lawful mechanism is required, such as adequacy regulations or appropriate contractual safeguards. Information about the providers and safeguards applying to this study can be requested from support@growformula.org.
We do not use identifiable research answers to train AI models or submit them to general-purpose AI services.
8. How long do we keep information?
| Information | Retention |
|---|---|
| Research responses, response references and withdrawal-code records | Up to five years from submission, then deleted or effectively anonymised |
| Direct recruitment records | Normally no more than 12 months after the last contact |
| Requests not to receive further invitations | A minimal record for as long as needed to respect the request |
| Unconfirmed email subscriptions | Deleted after 30 days |
| Active email subscriptions | While active and needed for the chosen communications |
| Consent and withdrawal records | Normally 24 months after withdrawal, unless a documented compliance need justifies longer |
| Marketing suppression records | The minimum needed to prevent unwanted contact |
| Enquiries and rights-request records | Normally up to 24 months after resolution, unless a legal need justifies longer |
| Security logs | Normally up to 90 days, unless needed for an incident or legal requirement |
| Effectively anonymised findings | May be retained indefinitely |
Continuous recruitment does not restart the retention period for older responses.
Deleted information may remain temporarily in backups until the provider's backup rotation expires. Relevant deletion instructions will be reapplied if a backup is restored.
9. Optional emails
You can independently choose:
- Study findings and progress.
- Free GROW resources and learning opportunities.
- GROW courses, services and offers.
All choices start unticked. We confirm your email address before sending optional emails.
Study-only emails do not promote GROW's paid services. Free-resource emails promote GROW's expertise and may mention relevant services. General paid offers require the separate marketing choice.
Every optional email provides an unsubscribe link. You can remove individual categories or unsubscribe from all without creating an account.
Email permission does not authorise contact through LinkedIn or other channels. Taking part, accessing the resource or visiting GROW's website does not subscribe you.
Unsubscribing does not delete your research response. Research withdrawal follows the separate process above.
10. Your rights
Depending on the information and lawful basis, you may have rights to access, correct, erase, restrict or obtain a portable copy of your personal information.
You may object to processing based on legitimate interests. You have an absolute right to object to direct marketing.
You may withdraw consent for optional emails at any time without affecting the lawfulness of earlier processing.
Contact support@growformula.org. We normally respond within one month. If a lawful extension is needed, we will explain why. We may need proportionate information to locate a record or verify a request.
11. Security, cookies and automated processing
We use access restrictions, secure connections and other appropriate safeguards. No online service can guarantee absolute security.
Only technologies necessary for operation and security are enabled by default. Any optional technologies requiring consent will be explained and offered separately.
We do not use advertising pixels, retargeting or cross-site identity matching on the study website. Individual email-open and marketing-link tracking are disabled for study subscriptions.
Automated processing creates descriptive snapshots and grouped comparisons. It does not assess professional competence, generate sales scores or make decisions with legal or similarly significant effects.
12. Changes and complaints
The current notice and its date are displayed on the website. Material changes to data use will be explained before they take effect. Changes to this notice do not expand existing marketing permissions.
For questions or complaints, contact support@growformula.org.
You can also complain to the UK Information Commissioner's Office at ico.org.uk/make-a-complaint.
Withdraw a response
Enter the withdrawal code you received after submitting. Keep it private.
We will review your request and remove the response if we can locate it. Without your code, we may be unable to find your response. For help, email support@growformula.org.
We cannot remove an individual contribution from findings that have already been effectively anonymised. Your response will be excluded from subsequent calculations once removed.