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Version 0.6 draft · Last updated 8 October 2026
In short: we collect what we need to do the work you commissioned, we tell the people we meet why we are asking, we do not sell personal data, we keep it only as long as we must, and you can ask us what we hold about you, have it corrected, and in most cases have it deleted.
This policy explains what personal data Ground Insights Uganda collects, why we collect it, who sees it, how long we keep it and what you can do about it. It is written to be read by the people it is about. Where a word has a special meaning, section 1.4 explains it.
We follow the Data Protection and Privacy Act, Cap. 97 (passed in 2019) and the Data Protection and Privacy Regulations, 2021. In this policy we call them 'the Act' and 'the Regulations'. Where the law of another country also protects you, for example because you live in the European Union, the United Kingdom, Kenya, Tanzania or Rwanda, we apply this policy in a way that respects those rights as well.
This policy sits beside other documents: our terms of service, the consent wording shown at the start of each survey or data collection exercise, the notice a researcher gives in the field, and the agreement each researcher signs. Where one of those says something more specific about a particular activity, the more specific wording applies to that activity, and this policy applies to everything else.
Ground Insights Uganda provides field verification, research and data collection services in Uganda and, where we are engaged to, elsewhere in East Africa. For the personal data described in this policy we are the data controller: we decide why and how it is used. In some work we act on a client's written instructions instead, and section 3.12 explains what changes then.
Data protection officer. One named person in our business is responsible for this policy, for training the people who handle personal data, and for answering questions and requests about it. Write to the data protection officer at info@groundinsightsuganda.com, or by post to the postal address above, and mark your message 'Data protection'.
Registration. The Act requires everyone who collects or processes personal data to register with the Personal Data Protection Office and to renew that registration. Our registration number is published on this page once it is issued, and we keep the registration up to date as our activities change.
Our company registration details are set out in the terms of service.
This policy covers personal data about:
It covers that data in whatever form we hold it: on our website, Insight Room, Fieldbook, Ground Control, programming interface and any mobile app we publish; in email, phone calls, text messages, WhatsApp and social media; on paper; and in person.
It does not cover what a client does with a report after we deliver it. The client is responsible for its own copy and its own decisions. It also does not cover other organisations' websites or services that we link to, which have their own policies.
| Word | What we mean by it |
|---|---|
| Personal data | Any information about a living person who can be identified from it, alone or with other information: a name, a phone number, a photograph of a face, a voice recording, an identity number, a location, an opinion about the person. |
| Special personal data | Personal data the Act protects more strictly: a person's religious or philosophical beliefs, political opinion, sexual life, financial information, health status or medical records. |
| Processing | Anything done with personal data: collecting, recording, storing, reading, using, sharing, changing, hiding the identity in it, or deleting it. |
| Data controller | The person or organisation that decides why and how personal data is processed. |
| Data processor | A person or organisation that processes personal data for a data controller, on its instructions. |
| You | Any person whose personal data we hold, whichever group in section 1.3 you belong to. |
| Client | The person or organisation that engages us to carry out work. |
| Researcher | A person we have vetted and engaged to carry out fieldwork, whether as an employee or as an independent contractor. |
| Assignment | One piece of work for a client, with a written scope. |
| Evidence | The photographs, video, audio, notes, documents, locations and times gathered on an assignment. |
| Consent | A free, specific and informed agreement, shown by a statement or a clear action, that a person can take back at any time. |
| Anonymised | Changed so that no person can be identified from it by any means reasonably likely to be used, and so that this cannot be undone. |
| Child | A person under the age of 18. |
| The Office | The Personal Data Protection Office of Uganda, which supervises the Act. |
The Act sets out principles for anyone who handles personal data. We apply them to every activity in this policy:
To those we add three rules of our own. We do not sell personal data. We do not record anyone in secret where the law forbids it. And a researcher never pretends to be a public official or any other person in authority.
This policy is written to cover the services we provide today and those we expect to provide as the business grows. Some activities described here may not be on offer at the time you read it. Where that is so, the wording says 'where we offer', 'if we' or 'once we'. Nothing in this policy means that an activity has already begun.
Before a new kind of processing starts, we check it against this policy, assess the risk to the people concerned where the Regulations or good practice call for an assessment, update our registration with the Office where that is required, and tell the people affected in the way set out in section 8.4 if they would not otherwise expect it.
When you ask for a quotation, send us a brief or engage us, we collect your name, your organisation and role, your email address, phone number and country, the details of the assignment, and what you tell us about why you need it. We keep the messages we exchange with you.
When you create an Insight Room account we also hold your first and last name, your email address, a password (kept only as a one-way scrambled copy that nobody can read back), the date and version of the terms and of this policy you agreed to, and, if you choose to give them, a phone number, an organisation, and whether we may send you text messages. We email a one-time code to confirm that the address is yours, and again if you reset your password.
For billing we hold what an invoice or receipt must show: the name and address to bill, a tax identification number where you give one, what was invoiced, what was paid, when, and by which method. section 2.10 explains what we do not hold.
Where the law requires us to know who we are dealing with, or the nature of an assignment makes it prudent, we may ask a client to show who they are and that they have a lawful reason for the work, and we keep a record of what we were shown.
A researcher on an assignment may speak to people at or near the place being visited: an occupant, a neighbour, a shopkeeper, a local council official, a member of staff. We record only what the brief requires, which is usually the person's role or relationship to the place and what they told us.
We record a name or a phone number only where it is needed and the person has agreed. A researcher says who they are, who they work for and why they are asking, unless the visit is an unannounced assessment of the kind described in section 3.6. Nobody is obliged to speak to us, and a refusal is recorded as a refusal and nothing more.
Photographs and video taken in a public place or at a site may show people who happen to be there. section 3.5 explains how we limit that and what we do with it.
A verification is usually about a property, a business or a claim, and so it touches the people connected to it: an owner, a seller, a landlord, a tenant, a director, an agent, a borrower, a supplier. We record facts that answer the client's brief, for example who occupies a building, whether a business trades where it says it does, or what a boundary looks like on the ground.
Where the client has a relationship with the person concerned, for example as a lender, landlord, buyer, insurer or employer, we ask the client to confirm that the person was told a visit might be made and agreed to it. Where there is no such relationship, we keep to what can be seen from a public place, what is on a public record, and what people at the place choose to tell us.
We do not record opinions about anyone's character, and we do not collect a person's private life beyond what the brief lawfully requires. We do not carry out surveillance of individuals, follow anyone, or look into a person's relationships, movements or private affairs. We decline assignments of that kind (section 2.14).
If you think we hold information about you because of work we did for someone else, you can ask us what it is and use the rights in section 6.1. We will tell you what we hold. We will not tell you who commissioned the work where that would break a duty of confidence we owe, unless the law requires us to.
Where we run a survey, an interview, a focus group or another study, we collect the answers you give, the time and place of the interview where the method records them, the consent wording you agreed to, and your confirmation that you are 18 or older, or the consent of a parent or guardian where the study lawfully includes children (section 2.13).
A study may ask about your household, your work, your income or spending, your health, your opinions or your experience of a service. You are always told before you start what the study is for, who it is for where that can be disclosed, roughly how long it takes, that taking part is voluntary, that you can skip a question or stop at any time, and whether your answers will be reported with or without your name.
Unless the consent wording says otherwise, results are reported in a way that does not identify you. Contact details collected so that a supervisor can check that the interview took place are kept apart from your answers and are used only for that check.
Where we collect material for a dataset, such as photographs of specified subjects, speech recordings in a named language, handwriting samples or labelled text, we collect the material itself and details about the contributor that the specification requires, for example age range, gender, language, dialect and district.
A voice or a face can identify a person, so we treat this material as personal data unless and until it is anonymised. Every contributor is given a consent form that says exactly what the material will be used for, who may receive it, whether it may be used to train or test computer systems including artificial intelligence, whether they are paid, and how to withdraw. We keep the signed or recorded consent for as long as the material is kept or licensed. section 3.9 sets out the rules we apply.
When you report a lost or found item we collect your name, your phone number and, if you give it, your email address, with a description of the item and where and when it was lost or found.
For an identity document we record only the name printed on it and the last four characters of its number, never the full number and never a photograph of the card. Someone reporting a found item also tells us which identity document they will show at the handover and its last four characters. Those details stay private and are not shown to the owner without the finder's agreement.
Where an item is returned, we record that it was, when, and to whom.
Verification work depends on knowing exactly who went where. For researchers, regional leads and staff we hold identity documents, a photograph, contact details, the districts and languages they cover, references and the results of the checks we carry out, the agreement they signed, training and performance records, the assignments they carried out, and bank or mobile money details for payment, with tax details where the law requires them.
While a researcher is working, Fieldbook records the location and time of each piece of evidence they capture, and the times at which they start, submit and complete an assignment. It does not track a researcher's location outside an assignment.
For applicants we hold what they send us and what their referees tell us. We may carry out identity, reference and, where the role justifies it and the law allows, criminal record checks, always with the applicant's knowledge. We hold a next of kin's name and phone number so that we can reach someone in an emergency, and we ask the researcher to tell that person we hold it.
Staff and researchers who use Ground Control or Fieldbook have an account. We record sign-ins and the actions taken in those systems so that every change to a record can be traced to a person (section 5.1).
We hold the business contact details of the people we deal with at suppliers, partner organisations, professional advisers, public offices and the media, with a record of our dealings. Where a partner's staff work on an assignment with us, we hold what is needed to manage that work.
Like every website, ours receives the internet address of the device that asks for a page, with the time, the page asked for, and the type of browser and device. Our hosting provider keeps these as server logs for security and to keep the service running.
To stop abuse of our forms and sign-in pages we keep a scrambled fingerprint of the address a request came from, never the address itself, for up to two days. It lets us count attempts without being able to tell who made them.
When something breaks, an error report is sent to our monitoring provider so that we can fix it. Names, email addresses, phone numbers and addresses are removed before the report leaves our system, and we do not record what you type or replay your visit.
section 7.1 lists the cookies and similar storage we use. section 7.6 covers what Fieldbook can reach on a researcher's phone.
Where we take payment online, card and mobile money details are entered on the payment provider's own pages and go to that provider directly. They never reach our systems. We receive only a confirmation of whether the payment succeeded, the amount, the currency, the method, a reference number, and the name and contact details given with the payment.
Where you pay by bank transfer, our bank statement shows the name and account the money came from. We use it to match the payment to your invoice.
We keep records of invoices, receipts, refunds and payouts for as long as tax and accounting law requires (section 5.2).
When you call, email, text or message us, we keep the message and your contact details so that we can answer and keep a record of what was agreed. Messages on WhatsApp and on social media platforms are also held by those platforms under their own policies, which we do not control.
We do not record phone calls as a matter of routine. If we introduce call recording, for example to keep an exact record of instructions or to train staff, you will be told at the start of the call and can ask us not to record.
If you interact with our pages on social media, we see what the platform shows us about that interaction, such as your public name and your comment.
The Act gives extra protection to information about religious or philosophical beliefs, political opinion, sexual life, financial information, health status and medical records. We do not set out to collect it, and a brief that asks for it without a lawful reason is refused.
We handle special personal data only in these cases:
Where we do handle it, fewer people can see it, it is reported without names wherever the purpose allows, and it is kept for the shortest period the purpose permits.
Our services are for adults and organisations. A person under 18 may not open an Insight Room account or commission work, and our public surveys ask each participant to confirm that they are 18 or older.
We collect personal data about a child only where a parent or guardian has agreed, where the law requires it, or where it is for research or statistical purposes the law permits. A study that includes children is designed for them: the questions are suited to their age, a parent or guardian agrees first, the child is also asked and may refuse, and an adult the child trusts may be present.
Researchers are instructed not to photograph children as the subject of a picture unless the assignment requires it and a parent or guardian has agreed. Where a child appears incidentally in a photograph, section 3.5 applies.
We take the same care with any adult who may find it hard to give or refuse consent freely, for example because of illness, disability, displacement, detention, or dependence on the person asking. If a researcher doubts that consent is free and informed, they do not proceed.
Most personal data comes from you: you fill in a form, send a message, answer a question, sign an agreement or speak to a researcher. The Act prefers this, and so do we.
We also receive personal data from other sources where the law allows it:
Where we collect personal data about you from someone else, we use it only for the purpose it was collected for, and you have the same rights over it as over data you gave us yourself.
The Act allows personal data to be collected and processed with the consent of the person concerned. Without consent, it allows it only where the law authorises or requires it, or where it is necessary for a contract with that person or for steps they asked us to take before one, for a legal obligation we are under, for the prevention, detection or investigation of an offence, for medical purposes, for national security, or for a public body's public duty. The table shows which of these we rely on for each purpose.
| What we do | Whose data | What allows it |
|---|---|---|
| Answer an enquiry, agree a scope and give a quotation | Clients and people who enquire | Steps taken at your request before a contract |
| Carry out the assignment and deliver the report | Clients | The contract with the client |
| Speak to people at or near a place | People we meet in the field | Consent, given when the researcher explains who they are and why they are asking |
| Record facts about the people an assignment concerns | People our work is about | Their consent, where the client has obtained it, for example in a loan, tenancy, supply or job application. Otherwise we collect only what is in public view, on a public record, or what the Act lets us collect from another source, and nothing that is private to the person |
| Keep an evidence record that can be checked later | Everyone who appears in the evidence | The ground the evidence was collected on; our legal obligations to keep business records; and the law that lets records be used to establish or defend a legal claim |
| Run a survey or study and report its results | Participants | Consent, recorded with the wording agreed to |
| Build and license a dataset | Contributors | Consent, specific to the uses named on the consent form |
| Reunite a lost item with its owner | People who report items; owners | Steps taken at your request, and consent |
| Run Insight Room, Fieldbook and Ground Control accounts | Account holders | The contract with you; our legal obligation under the Act to secure personal data |
| Take payment, issue invoices and receipts, pay researchers | Clients; researchers; staff | The contract; legal obligations under tax and accounting law |
| Vet, engage, train, manage and keep safe our researchers and staff | Researchers; staff; applicants; referees; next of kin | The contract or steps before one; consent to the checks we carry out; legal obligations under employment, tax and safety law |
| Send service messages about your request, such as a code, a receipt or notice that a report is ready | Clients; people who report items | The contract with you |
| Send news or marketing about our own services | People who asked for it | Consent, which you can take back at any time (section 3.10) |
| Keep our systems secure, prevent abuse and fraud, and find faults | Everyone who uses our systems | Our legal obligation under the Act to secure personal data; the prevention and detection of offences |
| Improve our services, train our people and produce statistics | Clients; researchers | Done with anonymised data, which is not personal data. Where personal data is needed, the ground it was collected on, and only for a purpose that fits with it |
| Meet a legal duty, answer a lawful demand, and establish or defend a legal claim | Anyone concerned | A legal obligation we are under; processing authorised or required by law |
The Act prefers personal data to be collected from the person it is about. It allows collection from another source in limited cases, including where the data is in a public record, where the person has made it public, where the person agreed to it, where it does not prejudice the person's privacy, or where asking the person is not reasonably practicable. We rely on those cases only as far as an assignment needs.
We do not use personal data for a purpose that does not fit with the one it was collected for. If a new purpose arises, we ask for consent or explain the lawful ground before we go ahead.
Where we rely on consent, we ask for it in plain words before we collect anything, and separately for each purpose. A box is never ticked for you, and agreeing to one thing is never made a condition of something unrelated.
We keep a record of each consent: the exact wording agreed to, its version, when it was given, and how. For a survey that record is stored with the answers for as long as the answers are kept.
You can withdraw a consent at any time, as easily as you gave it (section 6.6). Withdrawal stops what we do from then on. It does not undo what was lawfully done before, and it does not remove an anonymised result that can no longer be linked to you.
In the field, consent is often spoken. The researcher explains who they are and what the information is for, and records that the person agreed. Where the work involves a recording, special personal data or a child, we obtain consent in a form that can be shown later.
Photographs, recordings and notes gathered on an assignment are stored with the location and time the device recorded, the identity of the researcher, and the signature of the person who reviewed them.
Once reviewed, the record is locked. A correction is added as a new version beside the original and never overwrites it. This is deliberate: an evidence record cannot be silently altered, including by us, so that a disputed finding can always be checked against what was recorded on the day.
For this reason a request to correct or delete personal data in a locked evidence record is handled by adding a correction, by restricting who can see the record, or by removing the personal detail from the copies in use, as the case requires. section 6.4 explains when we cannot delete outright.
Researchers photograph what the brief asks about: a building, a boundary, a signboard, a shelf, a room, a road. They are instructed to frame the subject and not the people nearby.
Where a person is the reason for a photograph or a recording, for example an interview that is recorded, we ask that person first. Where people appear only in passing, we avoid them where we reasonably can, and before a report is delivered we blur or crop a face or a vehicle number plate that the client has no need to see. A client may ask for an unblurred image only where the brief lawfully requires it.
Audio is recorded only with the knowledge of the person speaking, except where the law allows a recording to be made by a person who is party to the conversation and the assignment is an unannounced assessment under section 3.6.
Every photograph and recording carries the location and time the device recorded. This is information about the researcher and the place, and it is what makes the evidence checkable.
If we use aerial photography, for example by drone, we will do so only with the permits the law requires, away from places where people expect privacy, and with the same rules on faces and number plates.
Some assignments only work if the visit is not announced. In a mystery shopping exercise a researcher presents as an ordinary customer and records how they were served. The business that commissioned the exercise is the employer or principal of the people assessed, or has their agreement through a contract with the outlet.
We ask a client who commissions this work to confirm that its staff, agents or outlets have been told that unannounced assessments may take place from time to time. Findings are reported about the service given, such as the wait, the price charged and whether a receipt was issued. They are not a judgement of a named individual, and we recommend that a client does not use a single visit as the only basis for a decision about a person's job.
A researcher on an unannounced visit does not record audio or video unless that is lawful and necessary and the client has confirmed in writing that the people assessed have been told that recording may be used.
Where an assignment includes a search of a public register, such as a company, business name, land or court register, we ask for the record in the way the register provides, pay any official fee, and report what the record shows.
A public record often contains personal data, such as the names of directors or of a registered proprietor. We use it only for the assignment it was obtained for. We do not build our own database of people from public records.
We may use the information we hold to produce statistics and insights: for example average prices by district, how often a kind of claim is confirmed, or how long assignments take. Before we publish or share anything of this kind we remove names and anything else that could identify a person or a client, and we do not publish a figure drawn from so few cases that someone could be worked out from it.
Data that has been anonymised is no longer personal data, and this policy does not restrict how long we keep it or how we use it. Where data has only had names removed and could still be linked back to a person with other information, we treat it as personal data.
Some of what we collect is collected so that it can be licensed to others: survey answers licensed for research, or photographs, recordings and text licensed for building and testing computer systems, including artificial intelligence. We apply these rules:
We do not license personal data gathered on a client's verification assignment. That evidence belongs to the client's matter and is used for nothing else.
A service message is one you need because of something you asked us to do: a sign-in code, a quotation, a receipt, notice that a report is ready, or a material change to our terms or this policy. We send these by email, and by text message or WhatsApp where you have given us a number and agreed to be contacted that way.
Marketing is anything that promotes our services. We send it only to people who asked for it, by ticking a separate box or by subscribing, or to an existing client about services similar to the one they bought, where the law allows and they have not objected. Every marketing message says who it is from and how to stop receiving it, and we act on a request to stop within the time the law sets and in any case within 14 days.
We do not use your enquiry to market unrelated services, we do not pass your details to anyone else for their marketing, and we never market to the people we meet in the field.
We use software to help with our work: to check that a photograph carries a location and time, to flag an answer that looks inconsistent, to count attempts at signing in, to convert currencies and to estimate a price. A person reviews anything that affects a client, a researcher or a member of the public before it is acted on.
We do not make a decision that has a legal effect on you, or that significantly affects you in a similar way, by automated means alone. If that ever changes, you will be told that the decision was automated, and you can ask for a person to look at it again, as the Act provides.
Where we use an artificial intelligence service, for example to answer general questions on our website (section 7.4), to draft or translate text, or to help check the quality of a report, these rules apply. We send it only what the task needs. We do not send it evidence, reports or account details unless the provider is bound by a contract that forbids it to use what we send to train its own systems, and the provider appears in section 4.3. A person remains responsible for the result.
We do not use artificial intelligence to recognise faces, to guess a person's identity, beliefs or health, or to score people.
In some work the client decides why and how personal data is used and we only carry out its instructions: for example where we administer a client's own questionnaire to a list of people the client supplied, and return the answers. The client is then the data controller, we are its data processor, and the client's privacy notice applies to that data.
In that role we act only on the client's written instructions, keep the data confidential and secure, use no other processor without the client's agreement, help the client answer requests from the people concerned, tell the client without delay if there is a breach, and return or delete the data when the work ends, as a written agreement between us sets out.
If you contact us about data we hold as a processor, we pass your request to the client and tell you that we have done so.
People in our business see only what their work needs. The researcher assigned to a job sees the brief for that job. A regional lead sees the work in their region. The person who reviews a report sees its evidence. Finance staff work with invoices and payments. Each role's access is set in our systems and enforced by them, and every change to a record is logged against the person who made it.
Everyone who handles personal data for us has signed a confidentiality undertaking and is trained on this policy before their first assignment.
The client who commissioned an assignment receives the report and the evidence that supports it. That will include personal data where the brief required it. The client becomes responsible for its copy, as a data controller in its own right, and our terms require it to use the report only for the purpose it was commissioned for and in line with the law.
We do not tell a client more about a person than the brief needed, and we do not tell one client about another client's work.
We use other companies to run parts of our service. Each one handles personal data only on our behalf, only to provide its service to us, and under a contract that requires it to keep the data confidential and secure. The table lists them. We keep it current: when a provider changes, we update the table and the date at the top of this policy. A change of provider does not change the commitments in this policy.
| Provider | What it does for us | Where | What it handles |
|---|---|---|---|
| Vercel | Hosts the website and applications | Frankfurt, Germany | Pages, forms in transit, and server logs |
| Supabase | Holds the database, uploaded files and sign-in | Frankfurt, Germany | Everything stored in our systems, including evidence |
| Resend | Sends our emails | United States | Email addresses and the content of emails we send |
| Pesapal | Takes card and mobile money payments, where online payment is offered | Kenya and Uganda | Card and mobile money details, which go to Pesapal directly and never reach us |
| Africa's Talking | Sends text messages, where we offer them | Kenya | Phone numbers and message text, only for people who asked for texts |
| Meta (WhatsApp Business) | Carries WhatsApp messages, where we offer them | United States and Ireland | Phone numbers and message text, only for people who chose WhatsApp |
| Sentry | Receives error reports | Frankfurt, Germany | Technical details of a fault, with names, email addresses, phone numbers and addresses removed first |
| GitHub | Stores our nightly copy of the database | United States | A full copy, encrypted before it is stored with a key only we hold, and deleted after 30 days |
| Have I Been Pwned | Tells us whether a new password has appeared in a known breach | United States | The first five characters of a scrambled copy of the password, never the password itself |
| Anthropic | Writes the answers of the question assistant on our website, where it is switched on | United States | What a visitor types into the assistant. It cannot see any request, report or account |
| Google and Apple | Confirm your email address if you choose to sign in with them, where that option is offered | United States | Your email address and name, as you approve on their screen |
Our bank, our accountants and auditors, our lawyers and our insurers also receive personal data where their work for us requires it, each under a duty of confidence.
We disclose personal data where the law requires it: to a court, the police, a tax authority, a regulator or another public body with a lawful power to demand it. We check that a demand is valid, give no more than it requires, and, where the law allows, tell the person concerned.
For a Lost & Found case we may share what is needed with the police or the National Identification and Registration Authority to return an item or to report a suspected theft.
We may also disclose personal data where it is necessary to prevent serious harm to a person, to report a suspected offence, or to establish, exercise or defend a legal claim.
If we sell, merge or reorganise the business, or bring in an investor, personal data may be disclosed to the other party and its advisers under a duty of confidence, and may pass to the new owner. The new owner must go on honouring this policy for the data it receives, and you will be told of the change and of your choices before your data is used differently.
Most of the providers in section 4.3 are abroad, so personal data is stored and processed outside Uganda: mainly in Germany, which is covered by the European Union's data protection law, and for some services in Kenya, Ireland and the United States. A client outside Uganda also receives its report, and any personal data in it, in the country where it is.
The Act allows personal data to be processed or stored outside Uganda where the country it goes to has adequate measures for protecting it, at least equal to those of the Act, or where the person concerned has consented. We meet this in these ways:
Personal data that has been sent abroad is not passed on to a further country without the safeguards above and, where the Regulations require it, your express consent. You can ask us for more detail about the safeguards for any transfer of your data.
If we open an office or engage researchers in another country, the data protection law of that country applies to what we collect there, alongside this policy.
The Act requires us to identify the risks to the personal data we hold, put safeguards in place against them, check that the safeguards work, and keep them up to date. These are the main ones:
No system is perfectly secure, and we do not promise that ours is. If you believe your account or your data has been compromised, tell us at once at info@groundinsightsuganda.com.
We keep personal data for as long as the purpose it was collected for requires, and for any longer period the law requires. The table sets out the periods. Where a contract with a client or the consent wording for a study sets a different period, that period applies.
| Record | Kept for | Why |
|---|---|---|
| An enquiry or quotation that does not become an assignment | 12 months from the enquiry | So that we can answer if you come back to it |
| Assignment records, reports and their evidence | 7 years from delivery of the report | This is the period in which a finding is most likely to be challenged, and business records must be kept |
| Invoices, receipts, refunds and payout records | 7 years from the end of the financial year | Tax and accounting law |
| Insight Room account details | Until you delete the account or we close it after long disuse | To let you sign in. Requests, invoices and reports follow their own periods |
| One-time email codes | 15 minutes in use; deleted within a day of expiring | Security |
| Scrambled fingerprints used to limit abuse | Up to 2 days | Security |
| Server logs and error reports | Up to 90 days | Security and fault finding |
| The audit trail of actions in our systems | 7 years | Accountability, and to investigate a dispute or a breach |
| Encrypted database backups | 30 days | Recovery from loss or damage |
| Survey answers and study records | The period stated in the consent wording; where none is stated, no longer than 7 years from the end of the study | The purpose of the study |
| Consent records | As long as the data they cover, and 7 years after | To be able to show that consent was given |
| Dataset contributions | As long as the dataset is kept or licensed, or until you withdraw | The purpose named on the consent form |
| Lost & Found cases | 12 months after the case closes | To answer a later question about a handover |
| Researcher and staff records | The length of the engagement and 7 years after | Tax, employment and liability |
| Applications that do not lead to an engagement | 12 months from the decision | To answer a question about the decision, or to consider the applicant again if they agreed |
| Marketing preferences | Until you unsubscribe, and a record of the unsubscribe after that | So that we do not contact you again by mistake |
| Call recordings, if introduced | No longer than 12 months | Record of instructions and training |
| Closed-circuit television images, if introduced at our premises | No longer than 30 days, unless an incident is being investigated | Safety of people and property |
We keep a record longer than its period only where the law requires it, where it is needed for a dispute, claim, investigation or legal demand that is under way, or where it has been anonymised.
Enquiries that did not become work, closed Lost & Found cases, expired codes and abuse fingerprints are deleted automatically by a job that runs every day, and each run is written to the audit trail. The longer periods are applied by a review at least once a year.
Deleting a record removes it from our live systems at once. It disappears from the encrypted backups as each backup reaches the end of its 30 days. Where a record cannot be deleted outright, because it is part of a locked evidence record or a tax record, we remove the personal details from the copies in use and restrict who can see the original.
Paper records are shredded. A device that held personal data is wiped before it is reused, sold or thrown away.
If personal data we hold is lost, stolen, changed without authority, or seen or taken by someone who should not have it, we act on a written plan. We contain the problem, find out what was affected, and notify the Personal Data Protection Office immediately, as the Act requires, describing what happened and what we are doing about it.
We tell the people affected in the way the Office directs or the Act allows: by email or post to the last address we hold, by a notice placed prominently on our website, or through the media. The notice says what happened, what data was involved, what we have done, and what you can do to protect yourself.
Where a provider in section 4.3 tells us of a breach on its side, we treat it as our own. Where we hold the data as a processor for a client, we tell the client without delay so that it can meet its own duties.
We keep a record of every breach, including those that did not need to be reported, and report on them each year as the Regulations require.
The Act gives you rights over your personal data. They belong to every person we hold data about, whether or not you are our client.
Clients can see, correct, download and delete most of what we hold about them from Your profile in the Insight Room, and can switch text messages off there.
Anyone else, including a person our work concerned and a person who met one of our researchers, can write to the data protection officer at info@groundinsightsuganda.com, or by post to 14 to 18 Cooper Road, Kisementi, Kololo, or can ask in person at 14 to 18 Cooper Road, Kisementi, Kololo. Tell us who you are, how to reach you, and what you are asking for. If you do not know what we hold, say when and where you think we collected it.
You can ask someone to act for you, such as an advocate or a family member. We will ask to see that they have your authority. A parent or guardian can ask on behalf of a child.
We will confirm that we have received your request, and we will answer it within 30 days, or sooner where the Act or the Regulations set a shorter time for that kind of request. If a request is complex and we need longer, we will tell you why and when to expect the answer.
Before we give out or change anything, we check that the person asking is the person the data is about. We ask only for what is needed to be sure, and we use what you send us for that check and nothing else.
We do not charge for a request. Where the Regulations allow a fee, for example for a request that is plainly excessive or repeated, we will tell you the fee before we do anything.
If we refuse a request in whole or in part, we tell you why in writing and remind you of your right to complain to the Office.
Your rights are real, and they also have limits that the law recognises. We may have to refuse or limit a request where:
Even then, we tell you what we can do, and we do that part.
Deleting your Insight Room account removes your name, phone number, organisation, password and choices at once. Your requests, invoices and reports stay on file for the periods in section 5.2, because we must keep business and tax records, and an evidence record that a finding can be checked against. Ask us if you want more erased and we will tell you what we can remove.
You can withdraw a consent in the same way you gave it, or by writing to info@groundinsightsuganda.com. For text messages, switch them off in Your profile, or tell us and we will do it for you. For marketing, use the link in the message. For a survey or a dataset, tell us the study and the date, or the reference on your consent form.
We act on a withdrawal promptly and tell you when it is done. We stop the processing that depended on the consent, and we delete the data unless we have another lawful ground to keep it, in which case we tell you what that ground is.
If you are unhappy with how we have handled your personal data, tell the data protection officer first. We will look into it, reply in writing within 30 days, and put right what we got wrong.
You can complain to the Personal Data Protection Office at any time, whether or not you have complained to us. The Office is part of the National Information Technology Authority, Uganda. Its current address, phone number and complaint form are published at pdpo.go.ug.
You also keep any right you have to go to court.
A cookie is a small file a website asks your browser to keep. We use only those that are strictly necessary to serve pages, keep you signed in and remember a choice you made. None of them tracks you across other websites, and none is used for advertising. Because they are strictly necessary, the site works without asking you to accept them.
| Name | Set when | What it does | How long it lasts |
|---|---|---|---|
| gi_currency | You choose a currency for prices | Remembers the currency so prices show in it | Until you change it or clear your browser |
| gi_portal | You sign in to the Insight Room | Keeps you signed in | Until you sign out, or after a period without activity |
| gi_portal_pending | You start creating an Insight Room account | Holds your place while you confirm your email address | A few minutes |
| Sign-in cookies set by our sign-in provider (names begin with sb-) | A staff member or researcher signs in | Keeps them signed in to Ground Control or Fieldbook | Until sign-out, or after a period without activity |
| gi_admin_active | A staff member uses Ground Control | Records the time of the last activity so that an idle session is ended | The length of the session |
| Browser storage on a researcher's phone | A researcher fills in a questionnaire in Fieldbook | Keeps unsent answers on the phone so that they are not lost without a signal | Until the answers are sent |
You can delete or block cookies in your browser's settings. If you block the sign-in cookies you will not be able to sign in.
We do not use analytics cookies, advertising cookies, tracking pixels or session replay. We do not advertise to you on other websites on the strength of your visit to ours.
If we add a tool to measure how the site is used, we will choose one that works without cookies and without identifying visitors wherever we can. Anything that is not strictly necessary will be switched off until you have agreed to it, refusing will be as easy as accepting, the choice will be offered by category, and a link at the foot of every page will let you change your mind. This policy and the table in section 7.1 will be updated before any such tool is switched on.
Our website links to other sites, including our pages on social media, WhatsApp, and the payment provider's pages. When you follow a link, the other site's own policy applies, and we are not responsible for it.
We load our fonts and scripts from our own site, so that visiting a page does not send your internet address to another company. If we embed a video, a map or another item from elsewhere, it will load only when you choose to open it.
Where the question assistant is switched on, you can type a general question about our services and receive an answer written by an artificial intelligence service. What you type is sent to that service so that it can answer, and the provider may hold it for a limited time under its own terms. We do not keep your questions, and under the terms on which we use the service they are not used to train its systems.
The assistant knows only what is published on our website. It cannot see any request, report, account or payment, and it cannot take any action for you. Its answers are general information and can be wrong: a quotation, a scope and anything about your own request come only from a person on our team.
Please do not type personal details into the assistant, yours or anyone else's. To talk about your own request, message us.
Your Insight Room account is protected by your password and by the email address you confirmed. We record the time of each sign-in and of failed attempts, and we email you when your password is changed. Changing or resetting a password signs out every other session.
Where we offer sign-in with Google or Apple, and you choose it, that company confirms your email address and name to us. It learns that you use our service. We receive nothing else from it, and we do not post to or read from your account with it.
Staff and researcher accounts are created only by an administrator. Their use is logged as described in section 2.7.
Fieldbook is used by our researchers. It asks the phone for the camera, so that evidence can be photographed, and for location, so that each piece of evidence carries the place it was captured. Where an assignment needs a recording, it asks for the microphone. It asks for each of these when it is first needed, and the researcher can see and change the permissions in the phone's settings.
The app reads location only at the moment evidence is captured. It does not run in the background, and it does not read the phone's contacts, messages, call history, other photographs or other apps.
Answers a researcher has typed but not yet sent are held on the phone until there is a signal. Researchers are required to keep the phone locked and to report its loss at once.
If we publish an app in an app store, for clients or for researchers, this policy applies to it. The app's store listing will state what it collects. An app will ask your permission before it uses the camera, the microphone, your location, your photographs or notifications, and will work as far as it can without a permission you refuse.
If an app sends notifications, the phone's maker handles their delivery and holds a device token for that purpose. You can switch notifications off in the phone's settings.
The app stores and their operators collect their own information about downloads and purchases under their own policies.
Where we give an organisation access to our programming interface, we issue it a key. We keep only a scrambled copy of the key, the name of the organisation, and a record of when the key was used and what was asked for, so that we can secure the service, limit its use and answer a question about it.
A key can read only the requests and reports of the organisation it was issued to. The organisation is responsible for who within it holds the key.
If you visit our office we may ask you to sign a visitors' book with your name, the person you are seeing and the time, for the safety of the people in the building. The book is kept for 12 months.
If we install closed-circuit television at premises we occupy, signs will say so before you enter its view. Cameras will cover entrances and shared areas only, never a place where people expect privacy, and will not record sound. Images are kept for the period in section 5.2 and are shown to the police or an insurer only where an incident requires it.
When you apply to be a researcher or a member of staff, we use what you send us to assess the application, to check your identity and your references, and to contact you. We tell you before we carry out any check, and we do not contact a referee you have not named.
If you are engaged, your application becomes part of your record (section 2.7). If you are not, we delete it after the period in section 5.2, unless you asked us to keep it for future openings.
Many of our clients live abroad. If you are in the European Economic Area, the United Kingdom or another country whose law protects your personal data when a business outside it offers you services, that law may give you rights in addition to those in section 6.1, such as the right to complain to your own country's data protection authority. We will honour those rights. Nothing in this policy takes away a right the law of your country gives you and does not allow you to give up.
We review this policy at least once a year, and whenever our practices or the law change. Each version carries a number and a date at the top, and we keep earlier versions so that you can ask to see what applied when your data was collected.
A change that only corrects a detail, such as a new address or a change of service provider, takes effect when it is published. A change that affects how we use personal data we already hold, or that reduces your rights, is notified in advance to active clients and account holders by email, and to others by a notice on our website, and where the law requires your consent we ask for it before the change applies to you.
The version of this policy and of our terms that you agreed to when you opened an account or commissioned work is stored with your record.
This policy is governed by the laws of Uganda. It is written in English. If we publish it in another language and the two differ, the English version applies.
If any part of this policy is found to be unlawful or cannot be enforced, the rest continues to apply.
If anything in this policy is unclear, or you want to know how it applies to you, write to the data protection officer at info@groundinsightsuganda.com, call or message +256 705 498 258, or write to 14 to 18 Cooper Road, Kisementi, Kololo. We would rather answer a question than have you guess.
Questions about this policy: info@groundinsightsuganda.com or +256 705 498 258.