Confidentiality and anonymity: what can you do for your satisfaction surveys?

Many Sharing-Data users ask us about the legislation governing the collection of personal data and the preservation of individual liberties. As a preamble, it's important to distinguish between data collection, which enables you to obtain valuable information about your customers or employees, and data processing, which consists of using the information gathered and analyzing it to improve performance.

Ethics and rules

What does the CNIL say about personal data processing?

The Commission Nationale de l'Informatique et des Libertés (CNIL) "is responsible for ensuring that information technology serves the citizen and does not infringe on human identity, human rights, privacy or individual or public freedoms. It carries out its missions in accordance with the French Data Protection Act of January 6, 1978, which designates it as an independent administrative authority".
The CNIL requires any organization processing nominative data to make a declaration on the nature of the file. By nominative data, we mean any information that directly or indirectly identifies an individual.

The CNIL 's Simplified Standard 48, however, has simplified "the obligation to declare the most common processing operations whose implementation is not likely to infringe privacy or liberties", notably in the context of normal customer management (orders, deliveries, invoices). For example, in the case of satisfaction surveys, which form part of customer relations follow-up, simplified standard 48 allows nominative action to be taken as part of the follow-up, but does not allow new commercial solicitations to be made.

What do ESOMAR and SYNTEC have to say?

ESOMAR (European Society for Opinion and Marketing Research)
The World Association of Social and Marketing Research Professionals with over 4900 members in more than 130 countries.

SYNTEC
Created on January 1, 1991, the Syntec Federation brings together more than 1,250 French groups and companies specializing in Engineering, Digital Services, Research and Consulting, Professional Training, Fairs, Shows, Conventions and Events in France.

Their opinion
Generally speaking, these two organizations recommend anonymity for statistical processing of results or global datamining whenever data is processed. Nominative data collection is authorized, but all personal data must be deleted or consolidated for processing and analysis.

The special case of satisfaction surveys

The "traditional" satisfaction survey

The traditional satisfaction survey (one-off, one-shot, annual) is a means of monitoring company performance and measuring customer perception of the company at a given point in time. The chosen target is generally a representative sample of all customers.

Objectives :

Measure customer perceptions of the company
Measure the performance of the company and its services/products
Measure progress and effectiveness of action plans
Meet the requirements of standards (ISO type)

How can I remain anonymous?
All personal data must be treated with the utmost confidentiality, and always in a global context. This data can be used for market research or global datamining purposes (it cannot be entered into a CRM or passed on to sales representatives, for example).
Once the data has been processed, it can no longer be used by name.
Please note that some business sectors require anonymity. We invite each company to check the legislation applicable to its sector (e.g. hospital sector, national education).
In this case, no specific declaration to the CNIL is required. The company may keep data such as geographical location, gender and age, but which do not allow the person to be identified by name.

Post-experience satisfaction survey

This is an on-the-spot, event-driven or ongoing survey that measures satisfaction after an experience (customer service call, complaint, post-purchase or service).
Purpose :

Measuring on-the-spot satisfaction Customer relations
Enrich marketing data to strengthen the one-to-one relationship between company and customer (CRM / database management)
Detect and deal with dissatisfied customers upstream

In this context, the CNIL authorizes the nominative management of the post-survey respondent, with a view to tracking the purchasing act.

The case of employee / internal customer surveys
Employee surveys must always be anonymous to preserve the integrity of the responses. For greater employee buy-in, we recommend that you also obtain the agreement of employee representative bodies.

SatisFactory's opinion: lifting anonymity
In all cases, and as a precaution, we recommend that you ask a question at the end of the questionnaire to lift anonymity, which will authorize the processing of nominative data on an individual basis.

It's also possible to ask a question, requesting the person's authorization to be recontacted by your services.

If you have any questions or require further information, please contact your company's CNIL correspondent.