Safe. Secure.
And ready for GDPR

While it is always good practice to receive explicit consent from your Respondents, certain laws and regulations (such as the GDPR) require consent prior to collecting personal data of certain individuals (such as those in the EU). As the survey owner, You must explain why personal data are being collected, for what purpose, and how long the data will be held before being deleted. Also, You must provide contact details to the Respondent. This information may be stated on a privacy policy web page or as a text block within the survey.

It is also important to note that under GDPR, consent is one of a number of legitimate interests for processing data. Others include the need to process for the performance of a contract, the need to process in order to comply with a legal obligation, and the need to process in order to protect the vital interests of the data subject or another natural person. Full details can be found in Article 6 of GDPR.

GDPR requires Transparency with regard to the functions and processing of personal data – this is all about giving the individual control over how their data are processed.

In the Qualtrics platform, You may easily create a multiple choice question to display a landing page and ask for consent. The Respondent can select Yes or No before they proceed with the rest of the survey. That response is recorded with the others, and may be used as evidence that the respondent did, indeed, consent. To ensure that the question is answered, the Force Response option should be used. If the Respondent chooses No, then direct the Survey Flow to the End of Survey so no data will be collected.

Yes, You may design a survey that will not collect any personal data or other identifying information (such as geo-location or IP address). When distributing a survey using Anonymous Links, no contact personal data will be associated with the resulting response.

In addition, You may enable Anonymize Response in Survey Options so that no location or IP information are collected.

Using both of the above options means that the completed responses will be completely anonymous with no embedded identifying information.

Yes, You may modify all response data to correct personal data as required by GDPR when You receive a Subject Access Request, or for other reasons.

The process is easy. First, You search for a specific contact or response. Then You edit the data point, such as a name (when it was entered in an open text field) or an answer (such as for a multiple choice question).

It should be noted that a Qualtrics user may be prohibited from editing or deleting a survey response if they do not have permission (as controlled by the Brand Administrator or another user with appropriate rights).

The screen images below show how the name George was changed to Georgiana.

Also, the Qualtrics API provides automated ways to delete contacts and responses.

Yes, You may delete any response, including a response that contains personal data, as required by GDPR.

For responses, the deletion may be:

• a single response
• all responses
• the entire survey project (and all related data and associations to contacts)

For contacts, the entire contact and related details may be deleted.

The screenshot below shows how a single response will be deleted.

Like in a desktop operating system, deleting a response flags it for deletion. The next section explains how deleted data can be made unrecoverable.

A deleted response is initially flagged for deletion, and may be recovered by Qualtrics Support (Quni) upon requested. After 30 days, the deletion becomes permanent and unrecoverable.

To permanently and immediately delete data, the Brand Administrator (or a user with equivalent permissions) may perform a permanent deletion. Permanently deleted data are unrecoverable, even by Qualtrics Support.

When a contact is deleted, it is permanently deleted.

Qualtrics philosophy is that customers own and control all the data they collect. Any retention period required by law or Your company policy is controlled by You.

You should ensure that all contacts and personal data are deleted prior to terminating Your Qualtrics brand, especially if required by policy, law, or regulation.

Yes. Qualtrics backs up all customer data each night, and retains the backup dataset for 30 days. After 30 days, the backup dataset is deleted.

No. The nightly backup dataset contains all customer data, and is used for disaster recovery purposes only. This is required for legal and compliance reasons related to availability obligations. Any personal data in these offline backups will be permanently deleted after 30 days.

Generally speaking, Qualtrics processes all Your EU data in the EU, and does not transfer Your data out of the EU.

When You contact Support, the call may be handled by someone in the U.S. where we have a large number of highly trained employees to handle requests worldwide. If You allow access to Your account by Support, and EU personal data is viewed by Support, then it is technically a transfer to the United States. Such transfer is covered by the EU-US Privacy Shield framework, and allowed by GDPR as providing adequate safeguards.

You may ask for an EU support representative to handle your request.

Backup datasets with EU data are stored at an alternate data centre in the EU.

You may request to have support and any account access by a Qualtrics employee located in Dublin. For customers wishing to make this a default for all their users, the EU Data Silo option is available by contacting Your Qualtrics Account Executive. Qualtrics provides the best support using employees (not outsourced) from our U.S. headquarters in Utah, and our EU office in Dublin. GDPR does not require that support must come from the EU. But it does require that any personal data accessed are adequately protected by qualified staff. Background checks are performed on each Qualtrics employee (as allowed by law), and upon hire, the employee must sign a letter of confidentiality.

As required by GDPR, only qualified Qualtrics employees with a specific need are permitted to access Your account. The typical reason for accessing Your account would be upon Your specific request for support. As Qualtrics provides self-service products, customer accounts are unmonitored. Qualtrics employees do not routinely access any customer account except when specifically asked.

Yes, Qualtrics uses the subprocessors currently listed at (https://www.qualtrics.com/privacy-statement/).

If a confirmed data breach occurs that is caused by Qualtrics actions or inactions, we will, without undue delay, notify the Brand Administrator. Information about the breach will be released as it becomes available, as allowed by GDPR. The Brand Administrator will be the main point of contact for all notifications, and will be kept aware of the investigation and remediation efforts as they progress.

As You know about the data You are collecting, You are responsible for handling any subject access request (SAR). Qualtrics only provides the platform and wouldn’t know the details about Your survey or Your respondents.

A SAR means that a Respondent is asking about information being collected about him or her in a survey that he or she completed. If You collected personal data of an EU citizen or a person residing in the EU, You may have a legal obligation to respond to a SAR.

Response data may be downloaded in industry-standard formats for data portability to comply with GDPR.

If Qualtrics receives a SAR, it will do its best to contact the survey owner. It may not always be possible to know what survey the Respondent took, and who the rightful owner is.

Similar to the above, You know Your survey and what data you have. If You collected personal data of an EU citizen or a person residing in the EU, You may have a legal obligation to respond and comply with a request to delete all identifiable data. As previously stated, You have the ability to delete a Respondent’s data.

Learn more about the Qualtrics data deletion feature

Qualtrics products provide easy ways to download all Your survey data in industry-standard formats. And, as previously described, You may easily delete data points, all survey responses, and entire projects.

All response data stored in our EU data centre are encrypted using the industry standard AES-256 cypher. All data transmitted to the Qualtrics platform are encrypted using the industry standard TLS protocol.

Qualtrics is committed to safeguarding Your data. We use sophisticated and industry best controls during processing to maintain the confidentiality, integrity, availability, and resilience of Your data. The Qualtrics Security White Paper, available upon request for existing customers and with an NDA for prospects, explains all key security controls, processes, and procedures related to data protection and processing.

As related to Article 28 in the GDPR, Qualtrics will only process personal data according to Your instructions. In other words, the commands You use in the platform are the “instructions,” and Qualtrics does not use personal data for any other means. In addition, it does not transfer personal data to a third party without your consent. If personal data are transferred from the EU to a third country, then adequate safeguards will apply to the transfer (such as the EU-US Privacy Shield Framework).

Qualtrics has developed recovery procedures to minimize downtime related to a disaster, with the ability to restore access to personal data in a timely manner in the event of a physical or technical incident.

We regularly test, assess and evaluate the effectiveness of our technical and organizational measures to ensure the security of the processing.

Qualtrics has conducted a Privacy Impact Assessment that maps how personal data are used in the platform (mainly, the user account names and email addresses used to login to an account). Also, it has prepared a Data Protection Impact Assessment regarding personal data collected by its customers, that may be presented to a Supervisory Authority upon request.

In 2018, Qualtrics expects to be ISO 27001 certified. Our controls are based on FedRAMP and NIST 800-53 frameworks— “gold standard” security authorizations.

For more information about our security and privacy, please visit the links at the bottom of each web page.