High profile individuals privacy notice

What personal data do we collect? 

We may collect and using the following personal data: 

  • First name, surname, and if applicable a preferred name or stage name; 
  • Home address, maybe pick-up address(es) which are different to your home address or other information relevant to you attending a location; 
  • If applicable, contact details and personal data of an agent or representative of yourself who may be acting on your behalf; 
  • Relevant email address(es) and contact details for individuals that may be relevant to you for an event or engagement you are due to attend; 
  • Social media handle(s), level of public presence and what you may be known for by the public (e.g. sport; business; politics; entertainment etc.); 
  • Photographs and videos including images and voice recordings that are already available and in the public domain; 
  • If applicable, photographs, videos and recordings of your voice you may have initiated, volunteered to engage with or we have asked you to take part; 
  • Photographs and videos including images recorded using CCTV at events you may attend; 
  • If applicable, next of kin information, dietary requirements, any disability or accessibility requirements in which we need to make any reasonable adjustments;  
  • If applicable, bank details or related financial records inc. donation amounts etc.; 
  • Topics of interest to you which may be a campaign or charity you are involved with, or an area of concern and/or any specific anecdotes, stories or personal background which may or may not be in the public domain; and 
  • Which publication you may have appeared in due to interactions with Labour or where you are aligned to Labour’s goals and objectives and any further information contained therein. 

Where do we get your personal data? 

We may collect personal data in a variety of ways and at a variety of times throughout our interactions with you. We refer to “direct data collection” when data is collected directly from you and we refer to “indirect data collection” when the data is not collected directly from you. Here is the list of ways we will collect your personal data from you: 

  • From an Agent or an individual known to you or representing you on your behalf (indirect data collection); 
  • From publicly available information including social media and websites (indirect data collection); 
  • From yourself when you make a donation to Labour (direct data collection); 
  • From Labour Fund Raising or Labour External Relations teams who have interacted with you in the past for any other reason (indirect data collection); 
  • From an individual who recommended you to us or has relevant information about you, which may include, but is not limited to, MPs, Labour Members, Labour Staff, other Labour volunteers and Specialist Volunteers, Labour Candidates, or members of a trade union etc. (indirect data collection); 
  • From yourself via email, telephone or face to face communications we have with you (direct data collection); 
  • From yourself through any speaking engagements you conduct with or for Labour and talk about yourself or reveal any information we were not aware of (direct data collection); and 
  • From yourself via an online survey or questionnaire we have sent specifically to you (direct data collection). 

What do we use your personal data for and what is our lawful basis for using it? 

We may use your personal data for the following purposes and on the following lawful bases.  

Purpose for using personal data Lawful basis for using 
To identify you as an individual who may be interested in being involved with Labour or have goals and objectives which may be aligned to a Labour policy, campaign or area of focus for endorsement, donation or event attendance. The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). 
To make contact with you and continue to communication with you or an individual on your behalf (such as an agent or representative). 
To help change government policy or financial targeting of areas of society, each with the goal of positive improvement. 
To invite you to attend events either as a guest, a special guest star or a speaker.  The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). Or, if applicable, the lawful basis we shall be relying in accordance with UK GDPR Article 6.1(b) where the use your personal data is necessary in the performance of a contract which you have agreed to or where we are working to enter into a contract with you. 
To make sure there is a higher level of protection around your personal data and treat all personal data associated to you as sensitive. The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). 
If required, to book travel and/or accommodation and make the necessary provisions for your attendance to a location, event or engagement. 
If applicable, in the rare event that we make a payment to you or a reimbursement to you for an unforeseen circumstance. 
To use photographs, videos or any other digital media that has been produced in partnership with Labour, where you are in agreement with us, either contractual, recorded or sufficiently implied, to endorse Labour and it’s values, objectives, policy and priorities at any time. Also see the Endorser’s Privacy Notice for further information on the use of an Endorser’s personal data. 
To identify personal data and take relevant action upon submission of a data subject rights request.  Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the UK General Data Protection Regulation to uphold your data protection rights. Special categories of personal data used for the purpose of Substantial Public Interest (Preventing or detecting unlawful acts; Protecting the public; Regulatory requirements) under UK GDPR Article 9.2(g). 
To be able to assess any impact on individuals of a data breach involving personal data held on Labour Party systems or on third party systems. 
To help protect an individual from neglect or physical, mental or emotional harm, or protect the physical, mental or emotional well-being of an individual. Use of the personal data is necessary to protect the vital interests of an individual or individuals in accordance with UK GDPR Article 6.1(d). Special categories of personal data used for the purpose of Substantial Public Interest (Preventing or detecting unlawful acts; Protecting the public; Regulatory requirements) under UK GDPR Article 9.2(g). 
To deal with legal claims and ongoing litigation cases. Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the UK General Data Protection Regulation to uphold your data protection rights. Special categories of personal data used for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity under UK GDPR Article 9.2(f). 

If you have interacted with Labour in a different way and if you expected to see something different to the list above, you can access all of our privacy notices by clicking here. If it is still not there, feel free to get in touch as mentioned below. 

Who do we share your personal data with? 

Any data shared with the below categories of recipients is the minimum necessary for the task they have been instructed to carry out on our behalf or in conjunction with us. Each category of recipient is subject to review by the Data Protection Team to make sure they have the right methods in place for keeping your personal data secure. 

Where the sharing of personal data is within the context of a product or service being supplied under contract to Labour, a Data Processing Agreement, in accordance with GDPR Article 28 is put in place. This makes sure the supplier cannot use your personal data outside of the list of uses above. 

Within the purposes of using your personal data, as listed above, we will share your personal data with the following: 

  1. Pre-approved digital communications and storage providers; 
  1. Pre-approved digital contact management platform (with limited access to Labour Staff in the External Relations Team and the Fund Raising Team); 
  1. Pre-approved online survey platform providers;  
  1. Pre-approved celebrity agents or agencies; 
  1. If relevant, venues, hotels, travel companies and any other concierge services;  
  1. If relevant and agreed by you or your representative, Labour Candidate(s) or MP’s or their office staff (both of which are separate data controllers although this Privacy Notice will be relevant for any work you do with them); 
  1. If relevant and agreed by you, media organisations which may include news media and journalists who represent specific and relevant views; and 
  1. If relevant and agreed by you, charities, charitable causes or individual families which have the possibility of being positively impacted from your contact and engagement with them (if agreed, any further uses of your personal data will be in line with their privacy information and Labour takes no liability for any use of your personal data in how they use your personal data). 

There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime, or prove we have adhered to their request. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law. 

Data sharing with a third-party organisation that is not a supplier of a product or service to Labour does not occur unless there is a legal obligation or sound lawful purpose for such sharing.  For any such sharing we put a Data Sharing Agreement in place between Labour and the third-party containing specific information in accordance with the Information Commissioner’s Office ‘Data sharing code of practice’.  

In all circumstances, the unlawful and unauthorised sharing of copies of personal data in which the Labour Party is the data controller is expressly prohibited. Any unauthorised sharing of Labour Party data is classified as a data breach which we will record and report to the ICO as required. 

How long will we keep your personal data? 

We only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

 In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.  

Once you indicate to us that you no longer wish for us to hold any personal data of you that is not in the public domain we shall deletion this information within one month. Where images and videos have been published by us are in the public domain, we may not be able to remove or delete your personal data but will make sure not to re-use your personal data in any future publications or broadcasts. 

Where you are no longer interacting with us after a previous engagement or communications with us we will delete and securely destroy your personal information within 7 years. 

What are your rights and how can you express them? 

To understand your data privacy rights and to submit a rights request, the best way to do so is by visiting the ‘YOUR RIGHTS’ page on our website which you can get to by clicking here

How can you complain about our use your personal data? 

The best way to make a complaint is by visiting our page on ‘HOW TO MAKE A DATA PROTECTION COMPLAINT’ which you can access by clicking here.  

How can you contact us about this privacy notice? 

If you have any questions about the information in this privacy notice, then you can contact the Data Protection Team via email using [email protected] or by post within a letter to: 

Labour Statutory Data Protection Officer 

The Labour Party, Southworks, 20 Rushworth Street, United Kingdom, SE1 0SS 

When was this privacy notice last updated? 

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify you of the changes where required by applicable law to do so.