Post: Data Protection Office, Sony Interactive Entertainment Europe Limited, 10 Great Marlborough Street, London, United Kingdom, W1F 7LP
Sony Interactive Entertainment Europe Limited is registered in England under company number 03277793.
2. Data Collection and Handling
2.1. Who collects your personal data?
SIEE is a data controller and gathers and uses certain personal data about you relating to your participation in our PlayStation user research. This means that we are responsible for deciding how we hold and use personal data about you.
2.2. About the personal data we collect and hold about you
Personal data means any information about a person that can directly or indirectly identify that person. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you including:
- Identity data which includes first name, last name, title, date of birth and gender.
- Contact data which includes address and telephone number.
- Profile data which includes your interests, preferences, feedback and survey responses.
- Session data which includes video, image and audio recordings, device and test environment data.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to compensate you for your participation in PlayStation user research). In this case, we may have to cancel your participation in our research but we will notify you if this is the case at the time.
2.3. Special categories of personal data
We may process data concerning your health, such as whether you have a physical disability or medical condition, for the purposes of providing context for research findings related to the development of PlayStation games. Health data is a special category of personal data and we will not process or share such data with other SIE companies without first obtaining your explicit consent to do so. You may withdraw your consent at any time by contacting us at email@example.com.
2.4. How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions: you may give us your identity or contact data by filling in forms. This includes personal data you provide when you: apply to participate in our research; fill in any questionnaires presented to you; and/or give us feedback or contact us.
- Automated technologies or interactions: as you participate in our research, we will automatically collect session data about your use of equipment and patterns. We collect this personal data through video, images and audio of you and the testing environment.
- Third party recruitment agencies: we may receive some personal data about you from our third party recruitment agencies in situations where you have been referred to us by those agencies in order to take part in our user research.
2.5. How we use your personal data
- To register you as a new participant.
- To develop and improve PlayStation products and services.
- To illustrate internal reports and presentations.
- To enable you to complete a survey and provide feedback.
- Where it is necessary for the performance of a contract with you or to take steps prior to entering into a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- For auditing, compliance and legal purposes (for example, making or defending claims or activities that are required by law).
2.6. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
2.7. How long we keep your personal data
We keep your personal data during and after your participation in our user research for no longer than is necessary for the purposes for which the personal data is processed and in accordance with our records retention policy.
2.8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
3. Data Sharing
3.1. Who we share your personal data with and where
We may share your personal data with other entities in the Sony group of companies (SIE Group) and, in the process of giving presentations to other third parties, such as publishers and developers working on PlayStation games, or at conferences. Other entities in the SIE Group, along with Us, may use your personal data to allow their development and research personnel to observe your research session at a later stage to help develop and improve PlayStation products and services and to illustrate internal reports and presentations. Personal data that we may share includes personal data collected before or after the session by or on behalf of SIEE (e.g. feedback, questionnaires and photos) and personal data collected during the session (e.g. feedback, recordings, device and test environment data).
Your information may also be available to third parties during negotiations for a transfer of all or part of our business and may be transferred by us as part of that business. We may retain, use and/or disclose any of your information as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.
3.2. Security of personal data transferred to third parties
We require all third parties to respect the security of your personal data and to take appropriate security measures to protect your personal data in line with our policies and in accordance with the law. We do not allow third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
3.3. International transfers
4. Your Rights
4.1. Your right to object to us processing your personal data
Where our processing of your personal data is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your personal data unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. Please contact our Data Protection Office (DPO) at firstname.lastname@example.org if you wish to object in this way.
4.2. Your rights to correct and access your personal data and to ask for it to be erased
4.3. How to complain
We hope that our DPO can resolve any query or concern you raise about our use of your personal data, so please contact the DPO at email@example.com. If you are not satisfied with the resolution of your query or concern by our DPO, you do have the right to contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.