What data do we collect?

• Name, preferred name, email address, telephone number(s), gender, ethnicity, date of birth, and home address; 
• Job title and name of your business or employer, work address & industry sector; 
• Your status as a either a high-net worth individual, very important person (VIP), politically exposed person (PEP), and/or any other appropriate title or status you have achieved; 
• Where applicable, any accessibility needs you may have which may include car registration numbers or any other relevant identifiers for your safety, accessibility and safeguarding that may be appropriate; 
• Where applicable, payment and/or donation details which may mean individual bank details and financial status tier allocation; 
• Political opinion and/or opinion(s) on various societal concerns and improvements; 
• Further information about yourself, your family and your circumstances you divulge in conversation and/or communications and/or research you are participating in with/for  Labour; 
• Information you provide in relation to surveys and questionnaires we may send you and you complete; 
• Availability information which may include location information; 
• Where applicable, CCTV footage of you, image and videos you have allowed us to take of you as an ‘Endorser’ to Labour. 

Where do we get your personal data?

We may collect personal data in a variety of ways and at a variety of times throughout the research study being conducted. 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) Please read the section below that is relevant to you: 

• From yourself within communications we have with you (direct data collection); 
• From the electoral register and our internal systems where information has been collected from you previously (indirect data collection); 
• From your business, personal assistant(s), employees or other individuals you have allowed to communicate about you with us (indirect data collection); 
• From information that is publicly available on websites, social media, news agencies, television broadcasts and/or print media including relevant research papers (indirect data collection); 
• From yourself within an online, telephone or in-person conversation, interview or meeting with you which may or may not be recorded (direct data collection); 
• From yourself via an online or paper based survey or questionnaire we have sent you or asked you to complete while we have been with you (direct data collection); 
• From an individual who recommended we make contact with you based on a topic they know you are interested in (indirect data collection). [We will make sure you are happy for use to contact you upon first communication with you and you have the right to ask us to discontinue any contact and delete your information.]; and 
• From yourself within any online forms you may complete which may be to register an interest in a Labour initiative or event or to be contacted by us regarding something relevant to yourself and your business or business sector (direct data collection)

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

Please see the table below for how we will use your personal data including the purpose of use and the relevant lawful basis. Not all fields will be relevant to all business associates. 

Purpose for using personal data	Lawful basis for using
To communicate with you and personalise our communications with you.	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).
For the improvement to society as a whole as a performance of ‘democratic engagement’.	The lawful basis we shall be relying on is the for the performance of a task carried out in the public interest by a data controller in accordance with UK GDPR Article 6.1(e).
Where you have signed up to an event and the event is sponsored, we will share your name, email address and job title with the event sponsor organisation.  [NOTE: Any further use of your personal data by an event sponsor will be as an independent data controller after their first initial contact. This will not be relevant for all events or conferences so please ask if you do not want your data to be shared with a sponsor.]	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 record your opinion so we are able to have a more targeted conversation with you and decide who may be the most appropriate department and individual within Labour for you to interact with.	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 understand you and your business alongside conducting any relevant due diligence or safeguarding review to ensure the alignment of interests with Labour as a political party and to ensure all individuals personal safety at all times.	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). And;  The lawful basis we shall be relying on is that processing is necessary in order to protect the vital interests of the data subject or of another natural person in accordance with UK GDPR Article 6.1(d). And;  The lawful basis we shall be relying on is where processing relates to personal data which are manifestly made public by the data subject UK GDPR Article 9.2(e).
To make any relevant adjustments for accessibility or health needs you may require during any interaction with Labour.	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). And; When relevant the consent you have provided us for this use of your personal data in accordance with UK GDPR Article 6.1(a) and also in alignment with UK GDPR Article 9.2(a).
To process any purchases, donations or other ad hoc financial transaction as relevant to the circumstance which you are aware of.	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 invite you to participate in relevant conferences, events, debates and/or endorsement activities.  You are under no obligation to accept invitation we send you.	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 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. Digital communications and storage providers; 

2. Online survey platform providers; 

3. Where applicable, travel, security and/or events service providers; 

4. If applicable, relevant government related departments and contacts where this is of clear benefit to society, and/or your individual or business sectoral interests; and 

5. Event sponsors (where an event sponsor is an independent data controller for the event they are sponsoring. This is not relevant for all events or conferences held by Labour). 

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’.  

This will include giving only relevant and often only geographically restricted access to your personal data to our local Labour Party organisations, Labour Candidates hoping to be elected, Labour Councillors, Labour Mayors and Labour Members of Parliament (MPs) so they can all conduct their democratic engagement activities. 

You can find further information on how local Labour Party organisations, Labour Candidates hoping to be elected, Labour Councillors, Labour Mayors and Labour Members of Parliament (MPs) use your personal data on their respective websites and more generally within our list of privacy notices which can be accessed by clicking here. 

Information on the meaning of ‘democratic engagement’ for national and local political parties, and their candidates and elected representatives can be found by clicking here. 

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? 

Data shall be reduced, redacted, de-identified and deleted at appropriate times so we retain the minimum amount of data possible throughout our varying interactions with you. We keep your personal data for the minimum time necessary. 

Where you have requested a deletion of your data we will delete the data within 60 days of your request. Where we have not had any interaction with you for any of the activities you have been engaged with at any time for two years we shall delete your data at that time. 

All data is securely stored for this time and safely deleted. 

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.