Date last reviewed: September 2026
1. Purpose
Shift Learning is committed to protecting the privacy, confidentiality and security of personal data entrusted to us. We comply with UK GDPR, the Data Protection Act 2018 and PECR.
2. About Shift Learning
Shift Learning is the trading name of Shift Learning Associates Ltd and is owned and operated by Caroline Wheeler. As a sole proprietor-led consultancy, Shift Learning does not employ staff but may engage specialist associates and suppliers under appropriate contractual safeguards.
3. GDPR compliance
Shift Learning follows the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality, and accountability. Shift Learning is registered with the ICO and maintains appropriate records of processing activities. ICO Registration Number: ZC222499
Depending on the project, Shift Learning may act as either a Data Controller or a Data Processor. Where acting as a Data Processor, data is processed only in accordance with client instructions.
The lawful bases relied upon by Shift Learning may include consent, legitimate interests, contractual necessity and legal obligations, depending upon the specific nature of the research activity.
4. Research participant confidentiality
Protecting participant confidentiality is a fundamental principle of market research.
Shift Learning will obtain informed consent where appropriate, clearly explain the purpose of research, separate identifying information from research findings wherever possible, anonymise or pseudonymise data before reporting, and never disclose participant identities without explicit permission.
Participants will not be re-contacted for unrelated purposes without their knowledge or consent.
Where research involves children or young people, additional safeguards will be implemented in accordance with MRS guidance.
5. Compliance with the MRS Code of Conduct
Caroline Wheeler is a member of the Market Research Society and is committed to complying with the MRS Code of Conduct and MRS Quality Commitment. Shift Learning does not undertake direct marketing, sales promotion, fundraising or push polling under the guise of market research.
6. Data storage and security
Appropriate technical and organisational measures are used to safeguard data, including secure cloud storage via Microsoft 365, password protection, multi-factor authentication where available, restricted access controls, secure transfer methods and secure deletion procedures.
7. Data retention
Participant identifying information is typically deleted or anonymised within three months of project completion unless legal, contractual or project-specific requirements apply. Anonymised research data may be retained for auditing, methodological review and benchmarking purposes. Please refer to our separate data retention policy for further details.
8. International transfers
Personal data is primarily processed within the UK. Where international transfers are required, appropriate safeguards including adequacy regulations, IDTAs or Standard Contractual Clauses will be used.
9. Individual rights
Individuals have the right to access, rectify, erase, restrict or object to processing of their personal data, request data portability and lodge complaints.
10. Data breaches
Any actual or suspected personal data breach will be investigated promptly and reported where required to affected parties and the ICO.
11. Third-party providers
Where third-party suppliers support research delivery, appropriate contracts and data processing agreements will be in place.
12. Contact
Caroline Wheeler
caroline.wheeler@shift-learning.co.uk
Requests regarding data rights may be submitted using this email address. Individuals may also complain to the Information Commissioner’s Office at www.ico.org.uk.