Code Of Conduct
Preamble:
Definitions:
Definition of data collection
The data collected by Need Insights is based on the presence of consumer devices (e.g. smart phones) in and around a retail shop or special place of interest. The presence is detected through sensors installed in the store (e.g. WiFi or Bluetooth enabled devices). The unique identifiers transmitted by devices are pseudonymised and then aggregated and used to generate analytics data.
Definition of data storage
The base data stored by Need Insights refers to a database or other form of digital storing of collected data.
Definition of data processing
The data processing in the scope of the code-of-conduct is defined as processing the base data to statistical data. The statistical data that does not feature any individual identifiers but is in form like “108 devices have been seen at location ‘location #54’ on March 12th 2018”. The statistical data can then further be refined to business critical data to answer questions such as:
– Which shopping window design is most attractive to consumers and converts passers-by to store visitors?
– What store layout is most suited to the preferences visitors show by spending time in different areas of a store?
– What staff level is ideal to keep wait times and queues short?
Privacy principles:
• To safeguard the privacy, base data is stored securely and access shall be restricted to as few people as possible.
In order to safeguard the principles outlined above, Need Insights has set itself and its members a Code of Conduct whose rules each member subscribes to abide by.
Code of Conduct for the Use of Wireless Tracking:
The clauses applicable to data collection:
1. Contract
All data-collection activities shall be based on a contract, which requests Need Insights to perform the data collection.
2. Signalling to consumers
Even though no personal information is being tracked, we believe in transparency and consider the shopper whose presence is being captured as a key stakeholder in our businesses. In order to promote transparency to all parties involved, Need Insights advises it’s customer to inform with signatory material such as stickers. These are designated to be deployed in store and at store entrances or other physical places to signal to the shopper that Visitor Intelligence is being practised around this location.
3. Pseudonymisation the unique data
Need Insights pseudonymises the unique data portion as soon as technically possible after receiving it.
4. Limited data collection
Need Insights collects only the minimal data that is necessary for retail analytics.
5. Secured data transfer
The data transfer between sensor and storage using a secured data connection.
6. Access to sensor
Remote and local (via Ethernet, USB, Wi-Fi etc.) access to sensors shall be restricted.
The clauses applicable to base data storage
7. Contract
Need Insights has a data processing agreement with all it’s customers specifying the roles of the different parties.
8. Consumer Choice/ Opt out
Need Insights provides an opt-out page where individuals can opt out by entering their unique MAC address. Need Insights agrees to discard any information received from a MAC address that has opted out and not use it for any kind of data analytics.
9. Security
The IT architecture of Need Insights is designed with security in mind to prevent theft and misuse of collected data.
10. Limited storage of base data
As part of their Visitor Intelligence product, Need Insights has the capability to identify a device as recurring. This allows to analyse visitor loyalty over time which is very valuable for example a store owner to understand as it signifies quality of service. This analysis necessitates Need Insights to save unique user IDs in its databases. Need Insights shall not to store base data longer than necessary for the business case.
The clauses applicable to base data processing
11. Minimum sample size of statistical data
The statistical data created must have sufficient sample size disallowing reverse engineering of personal data.
12. Limitation of use: No employee tracking without consent
The purpose of Visitor Intelligence is to understand shopping/moving patterns of consumers. Need Insightss acknowledges the privacy of employees who may be tracked at work. The purpose of Visitor Intelligence is not to control employees in shops. Need Insights will not specifically separately identify employees without their explicit consent.
General clauses:
13. Exclusions
There shall be certain exclusions from this code of conduct where personalised information might be collected and used. Specifically and exclusively this shall apply to:
– The use of data by a request of a governmental or regulatory body (including court orders)
– Data gathered with the consent of the user
– Data which is collected to facilitate the network management or the administration and development of systems