LE BLOG BY SATISFACTORY
Confidentiality and anonymity: your options for your customer satisfaction surveys
Many Sharing-Data users ask us about the legislative framework in place as regards the collection of personal data and the preservation of civil liberties. First, a distinction needs to made between collecting data and processing data - the former provides precious information about customers and employees, whereas the latter means using the information collected for analysis in order to improve performances.
I. Conduct and ethics
a) What does CNIL say about processing personal data ?
The Commission Nationale de l’Informatique et des Libertés, the French data protection authority, states that it is responsible for ensuring that information technology remains at the service of citizens, and that it doesn’t infringe on personal identity, human rights, privacy or civil liberties. It operates in accordance with the French data protection legislation of 6th January, 1978, which qualifies it as an independent administrative body.
The CNIL has made it mandatory for organisations which processes personal data to make a declaration as to the nature of the file. Personal data is considered as any information which could potentially lead to the identification of a natural person, either directly or indirectly.
The CNIL’s Norme simplifiée 48 (Only available in french http://www.cnil.fr/documentation/deliberations/deliberation/delib/184/) is a standard simplifying the mandatory declaration of the most common processing operations which aren’t likely to infringe on privacy or civil liberties, particularly when it comes to standard customerrelated activities (such as orders, shipments and invoices). Thus, for customer satisfaction surveys used as part of a CRM process, Norme simplifiée 48 (Simplified Standard N° 48) can be used for personal data to follow up on existing customers, but it can’t be used for further commercial offers.
b) What do ESOMAR and SYNTEC say?
Who are they ?
ESOMAR (European Society for Opinion and Marketing Research)
This association of professionals from the world of Opinion and Marketing Research is composed of more than 4900 members from more than 130 countries.
Created in 1991, Fédération Syntec is a trade association whose members include French organisations and companies specialising in the fields of engineering (SYNTEC Ingénierie), digital technologies (SYNTEC Numérique), research and consulting (SYNTEC Etudes et Conseil), professional training (FFP Fédération de la Formation Professionnelle), exhibitions, trade fairs, conferences and events (Fédération des Foires Salons Congrès et Evénements de France, now UNIMEV since 2013).
Generally speaking, in the scope of the statistical analysis of results and data mining, these two organisations recommend anonymity when it comes to processing data. The collection of personal data is authorised, however, all personal information must be deleted or consolidated for processing and analysing.
II. The specificities of customer satisfaction surveys
a) The “traditional” satisfaction survey
The traditional customer satisfaction survey (event driven, one shot, annual) is a way of monitoring a company’s performance and of measuring customers’ perceptions of the company at a given time (t). The target audience is generally a representative sample of the company’s customer base.
- To measure customers’ perceptions of the company
- To measure the performance of the company and its products or services
- To measure the evolution and efficiency of action plans
- To ensure compliance with standards (ISO for example)
How to preserve anonymity ?
All personal data must be processed in a completely confidential manner, and always in a global context. The data can only be used for market research or global data mining (it can’t be logged into CRM systems or communicated to salespeople, for example).
Once processed, the nominative personal data can no longer be used.
Note: anonymity is mandatory in some sectors. We encourage each company to check the relevant legislation in force in their specific sector (healthcare, education, etc.).
For this purpose, no specific declaration to the CNIL is required. The company may keep data pertaining to geographical information, gender and age, but this data must not potentially lead to the identification of a natural person, either directly or indirectly.
b) Postexperience satisfaction survey
A postexperience satisfaction survey is an eventdriven or continuous survey used to measure customer satisfaction after a given experience (phone call to customer services, complaint, followup regarding purchases or services).
- To measure customer satisfaction soon after a specific event
- To supplement marketing data in order to strengthen one to one relations between the company and its customer (CRM / database management)
- To identify dissatisfied customers early on, and take action
In this scope, the CNIL authorises the use of the personal data of respondents to the postexperience satisfaction survey with the intention of following up with customers after a purchase.
Internal satisfaction surveys for employees/customers
Satisfaction surveys for employees must always remain anonymous in order to preserve the integrity of the answers. For better compliance from staff, we also recommend obtaining the permission of the employees’ representative advisory body.
SatisFactory’s opinion: the lifting of anonymity
In all cases, and as a backup precaution, we recommend asking respondents, at the end of the survey, to waive their anonymity in order to authorise the processing of individual personal data.
It is also possible to ask a respondent for authorisation to be contacted directly by your company.
If you have any questions or need further information, please contact the person in charge of data protection within your company.
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