Notice

Parker Review voluntary census 2024: privacy notice

Updated 24 September 2024

This notice sets out how we will process and use the personal data collected from the Parker’s Review voluntary census, and the rights of the individuals whose data is processed. It is provided in accordance with Article 13 of the UK General Data Protection Regulation (UK GDPR).

This voluntary census is being conducted by the Department for Business and Trade (DBT), as Independent Data Controller for purposes of processing the personal data from this census on behalf of the Parker Review.

Purpose

The Parker Review is an independent business-led, government-backed review which conducts an annual survey and report that tracks the number of ethnic minority directors who sit on boards of FTSE 350 companies and 50 large private companies in the UK. This review was initially commissioned by the department in view of the prevailing low representation of ethnic minorities on the boards of companies, which is not representative of the demographics of this country.

The government seeks to ensure that all have equal opportunity to make the most of their potential and are able to progress to the highest levels in their business careers.

Hence, the reason why the government is supporting the business-led Parker Review and supports its work towards meeting and maintaining the recommendations, namely that:

• each FTSE 100 Board has at least one director who identifies as a minority ethnic director in 2021 and subsequent years

• each FTSE 250 Board should have at least one director who identifies as a minority ethnic director by 2024 and subsequent years

• each of the 50 large privately-owned businesses should have at least one director who identifies as a minority ethnic director on its main Board (or equivalent) in 2027 and subsequent years

What personal and special category data we hold and why it is processed

Personal data is defined under the UK GDPR as ‘any information relating to an identifiable natural person who can be directly or indirectly identified by reference to an identifier.’

The personal data of company directors of FTSE 350 and 50 UK private companies will be processed to analyse the current state of ethnic minority representation in UK companies.

The information are as follows:

• full name – to avoid double counting of directors across companies in the FTSE 350 and the 50 large UK Private Companies

• function on Board – to understand the variety of roles across minority ethnic directors in the FTSE 350 and the 50 large UK Private Companies

• gender – to understand the gender breakdown of minority ethnic directors in the FTSE 350 and the 50 large UK Private Companies

• ethnicity – to conduct further analysis on ethnic minority representation and compare and analyse gender and board roles, which will support the work of the review

• nationality – to understand the nationality breakdown of minority ethnic directors in the FTSE 350 and the 50 large UK private companies

We will likewise process the personal information of the designated respondent who is assigned to complete the survey. These contacts may or may not be a director of the company. The collection is necessary to follow up their response or in some cases, non-response.

Data on ethnicity, as defined by the high-level Office for National Statistics categories, as used in the UK census.

These are:

• Asian
• Black
• Mixed / multiple ethnic groups
• Other minority ethnic
• White

The review will categorise directors in the Asian, Black, Mixed or Other categories as minority ethnic directors. For further information on what specific ethnic groups fall under these high-level classifications, please see Annex 1.

Additional data

The review will also be collecting data on members of the ‘Senior Management’ team working in the UK. There will also be the option in the survey for companies to provide their global Senior Management data if they so choose. This can be defined as members of the Executive Committee (or equivalent) and those senior managers who report directly to them.

For individuals in the Senior Management team, we will be collecting the following aggregated information:

• total number of individuals in the Senior Management team
• total number of individuals identifying as Asian, Black, Mixed/Multiple ethnic groups, or other ethnic group (that is, minority ethnic)
• of those who identify as a minority ethnic, the nationality and gender breakdown

Legal basis for processing

As a government department, DBT has the responsibility and task to uphold Public Sector Equality Duty under Section 149 1(b) of the Equality Act 2010, which states that, “a public authority must, in the exercise of its functions, have due regard to the need to”:

“(b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;”

​In upholding this duty enshrined in the statute, DBT is supporting the interest of UK businesses to grow in an equitable manner. In doing so, the department will undertake processing to perform task in the public interest in accordance with Article 6 (e) of UK GDPR.

The special category of personal data

In accordance with the lawful basis to process the personal information under Article 6 (e) the additional processing of the Special category of personal data relating to race or ethnic origin is processed under the condition provided under Article 9 (2) (g) of UK GDPR which allows processing of special category data “for reasons of substantial public interest”.

The substantial public interest is supported by specific special category condition under Schedule 1, Part 2, Par 8 (1) (b), Equality of opportunity or treatment; which states that the condition is met, if the processing:

“1 (b) is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified in relation to that category with a view to enabling such equality to be promoted or maintained.”

Who will have access to your data

Data may be shared with:

• individuals on the Parker Review team, some of whom are external to DBT. Details of the members in the Parker Review team can be found in Annex 2.
• Domestic and General (D&G) who supports the review by conducting the data analysis on a voluntary basis. D&G will be acting as processor for purposes of Data Protection Legislation and corresponding processing agreement will be in place before sharing of personal information can take effect.

In addition, an aggregated analysis of data collected may be shared with the other government departments, agencies, and public bodies, outside of the Parker Review team.

At the end of this reporting period, the Parker Review intends to publish a final report and press release on the progress towards the targets.

Storage and security

As your personal data will be stored on our IT infrastructure, by default it will also be shared with our data processors Microsoft and Amazon Web Services.

However, the data will only be accessible by a limited number of DBT researchers and policy colleagues working on this project. This will also include Domestic and General, our third-party data processors.

This data will be shared through a secure Microsoft platform. We will be using this data for research purposes only.

When conducting the survey, we will be using a survey software programme called Qualtrics Experience Management Platform. Qualtrics Experience Management Platform is ISO27001 certified and fully compliant with the internationally recognised standard for the information security management system (ISMS). Certification to ISO27001 ensures that all our information is kept secure.

Retention

Your personal data will be kept by us for as long we need it for the purpose(s) of the review. The Parker Review will continue until at least 31 March 2025.

If further work is to be carried out following the review’s conclusion and we need to contact you about this, we will update this privacy notice further. D&G will hold the data until 31 March 2025, after which all the data will be deleted. 

Your rights

Under the UK GDPR, in relation to personal information you provide as part of this project, you have the right:

• to request information on how your data has been processed
• to request a copy of that personal data
• for us to rectify any inaccuracies in that data without delay
• for incomplete personal data to be completed, including by means of a supplementary statement
• for your data to be erased if there is no longer justification for processing
• to object to or restrict processing (in certain circumstances)
• to object to personal data being processed for direct marketing purposes
• to object to the processing of your personal data where your data is being processed for public task (as described above)

If you would like to object, please contact parker@businessandtrade.gov.uk.

International transfers

As your personal data is stored on our IT infrastructure and shared with our data processors Microsoft and Amazon Web Services, it may be transferred and stored securely in the UK and European Economic Area.

Where it is the case that your personal data is stored outside the UK and EEA it will be subject to equivalent legal protection in accordance with Article 46 of UK GDPR.

How to Contact Us

Identity and contact details

Our contact details are: 

Data Protection Officer

Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Email data.protection@businessandtrade.gov.uk

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information. You can contact Our Data Protection Officer using the same contact details.

If you are not satisfied with the DBT response, you have a right to complain to the Information Commissioner’s Office (ICO). You can report a concern by visiting the ICO website.   
   
For more information about your rights under the Data Protection Act or to request a copy of any data held about you please contact data.protection@businessandtrade.gov.uk   

Contacting the Information Commissioner’s Office 

You can also make a complaint to the Information Commissioner, who is an independent regulator. 

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email casework@ico.org.uk

Telephone 0303 123 1113

Textphone 01625 545860

Monday to Friday 9am to 4:30pm

Changes to this privacy notice  

We reserve the right to update this privacy notice at any time. We will amend the privacy notice if we make any substantial changes to the way we process your personal data.  

Confidentiality  

If you wish the information you provide to be treated as confidential, please be aware that, in accordance with the Freedom of Information Act (FOIA), public authorities are required to comply with the FOIA.     

In view of this, it would be helpful if you have reasons for confidentially, if you could explain to us why you wish that information to be treated confidentially.

If we receive a request for disclosure of information that has been provided, we will take full account of your explanation. However, we cannot give an assurance that confidentiality can be maintained in all circumstances.   

Annex 1

Asian:

• Indian
• Pakistani
• Bangladeshi
• Chinese
• any other Asian background - please describe

Black:

• African
• Caribbean
• any other Black / African / Caribbean background - please describe

Mixed / multiple ethnic groups:

• White and Black Caribbean
• White and Black African
• White and Asian
• any other mixed / multiple ethnic background - please describe

Other minority ethnic group:

• Arab
• any other ethnic group - please describe

White:

• English / Welsh / Scottish / Northern Irish / British
• Irish
• Gypsy or Irish Traveller
• Roma
• any other White background - please describe

Annex 2

• David Tyler, Chair
• Soumen Das, Co-chair
• Rachel Askew-Sammut
• Doyin Atewologun
• Arun Batra
• Andrew Death
• Timothy Deller
• Lesley-Ann Nash
• Sir Ken Olisa
• Matthew Percival
• Sir Trevor Phillips
• Latika Shah
• Fatima Tresh
• Sue Vinnicombe
• Ariel White-Tsimikalis
• Amy Winepress