Privacy Policy


The Bermuda Tourism Authority (BTA) respects your privacy. In protecting your privacy, the Bermuda Visitor Panel follows the privacy policy of our research partner, TRA. Details on the privacy policy are outlined below.

Your Privacy

At TRA, respecting privacy is an important part of our commitment to you, our respondents, and the general public.

When you participate in survey research conducted by our organization, you can be confident that any personal information that you share with us will stay with us.

Any time you participate as a respondent in one of our surveys, whether in person or by telephone, mail or Internet, you can be assured that your individual responses will be kept confidential and never linked to your personal identifying information without your express permission.

Your personal identifying information will never be sold to anyone.

You are free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

The TRA Privacy Policy is a statement of principles and guidelines describing the level of protection of personal information provided by TRA to respondents and the general public. The objective of the TRA Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Market Research Intelligence Association.

TRA will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.
If you have any concerns about how your privacy is protected at TRA, please contact our Privacy Officer by e-mail at info@totalgroup.bm, or by mail at 25 Woodlands Road, Pembroke HM 09, Bermuda.

The Detailed TRA Corporate Privacy Policy

Detailed Privacy Policy

Scope and Application

The ten principles that form the basis of The TRA Privacy Policy are interrelated and TRA shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary.

The scope and application of the TRA Privacy Policy are as follows:
  • The TRA Privacy Policy applies to personal information collected, used, or disclosed by TRA in the course of commercial activities.
  • The TRA Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
  • The TRA Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by TRA:
    1. non-personally identifiable information;
    2. the name, title, business address and/or telephone number of an employee of an organization;
    3. other information about an individual that is publicly available.

Definitions

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of TRA. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to TRA.

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.

respondent: A member of the public who provides personal information to TRA in the course of a survey conducted by TRA. For example, a respondent is an individual who discloses personal information to TRA in the course of quantitative or qualitative marketing or social research.

third party: An individual or organization outside of TRA.

use: The treatment, handling, and management of personal information by and within TRA or by a third party with the knowledge and approval of TRA.

The Ten Principles of Privacy

Principle 1 – Accountability

TRA is responsible for personal information under its control and shall designate one or more persons who are accountable for TRA’s compliance with the following principles.

Responsibility for compliance with the provisions of the TRA Privacy Policy rests with the TRA Privacy Officer who can be reached by e-mail at info@totalgroup.bm or by mail at 25 Woodlands Road, Pembroke HM 09, Bermuda. Other individuals within TRA may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

TRA is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 – Identifying Purposes for Collection of Personal Information

TRA shall identify the purposes for which personal information is collected at or before the time the information is collected.

TRA collects personal information from the public only for the following purposes:
  1. to conduct quantitative or qualitative marketing and social research;
  2. to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and
  3. to meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

TRA shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within TRA who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

TRA may provide clients or other third parties with information from any survey, in aggregate form. In aggregate form it is impossible to identify an individual respondent’s personal information.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating.

Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, TRA always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure.

A respondent is always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, TRA shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.

Generally, TRA shall seek consent to use and disclose personal information at the same time it collects the information. However, TRA may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, TRA shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for TRA to collect, use and disclose personal information for the identified purposes.

Principle 4 – Limiting Collection of Personal Information

TRA shall limit the collection of personal information to that which is necessary for the purposes identified by TRA. TRA shall collect personal information by fair and lawful means.

In conducting surveys, TRA limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.

TRA collects personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, TRA will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information

TRA shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

TRA may disclose a respondent’s personal information to:
  1. client of TRA where the respondent has consented to such disclosure;
  2. a third party engaged by TRA to perform functions on its behalf;
  3. a public authority or agent of a public authority if, in the reasonable judgment of TRA, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
  4. a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only TRA’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

TRA shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, TRA shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

TRA shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 – Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by TRA shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

TRA shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 – Security Safeguards

TRA shall protect personal information by security safeguards appropriate to the sensitivity of the information.

TRA shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

TRA shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of TRA’s employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 – Openness Concerning Policies and Procedures

TRA shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

TRA shall make information about its policies and procedures easy to understand, including:
  1. the title and address of the person or persons accountable for TRA’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
  2. the means of gaining access to personal information held by TRA;
  3. a description of the type of personal information held by TRA, including a general account of its use; and
  4. a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, TRA shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, TRA will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.

In certain situations, TRA may not be able to provide access to all the personal information that it holds about a respondent. For example, TRA may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, TRA may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit TRA to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

TRA shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, TRA shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting the TRA Privacy Officer.

Principle 10 – Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for TRA’s compliance with the TRA Privacy Policy.

TRA shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding TRA’s handling of personal information.

TRA shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the TRA Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

TRA shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, TRA shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The respondent shall be informed of the outcome of the investigation regarding his or her complaint.

Additional Privacy Information

For more information regarding the TRA Privacy Policy, please contact the TRA Privacy Officer by email at info@totalgroup.bm or by mail at 25 Woodlands Road, Pembroke HM 09, Bermuda.