What personal data do we collect? 

Some categories of personal data we use will vary depending on whether you are a Labour Member or how you entered into a Prize Draw, e.g. via an online form or a paper form. 

Information we may collect include: name, home address, email address, phone number, bank/payment card information, and for winners, if you give us permission, photos and maybe a testimonial about our Prize Draw. 

Where do we get your personal data? 

We will collect personal data in a variety of ways and at a variety of times when you are a Player. 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). We will collect personal data about you in the following ways: 

• From yourself when you become a Labour Member or when you make a donation or volunteer to participate in an activity with Labour and are not a Labour Member (direct data collection); 
• From yourself when you complete either a paper or online form and submit it for entry which may include payment information (direct data collection); and 
• From yourself when you communicate with us by post, over the phone or email e.g. where we are interacting with you as a winner or responding to a query about the Prize Draw (direct data collection). 

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

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

Purpose for using personal data	Lawful basis for using
To invite you to take part in a Labour Prize Draw. This will either be by post or email.	The consent you have provided us for this use of your personal data in accordance with UK GDPR Article 6.1(a).
To personalise Labour’s interactions with you whilst communicating with you about a Prize Draw. E.g. using your name in the invitation and further correspondence 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).
To make it easier for you to enter the Prize Draw(s) such as pre-printing contact information on Prize Draw tickets and entry forms that are sent to you in the post. [This also helps us to identify you as a winner when we make the draw.]
To enter you into the Prize Draw upon successful receipt and processing of your entry.	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 process payment as part of the entry to a Prize Draw.
To handle any issues or disputes that arise as a result of the Prize Draw.
To notify you if you have won a prize in any of the Prize Draws and provide you with your prize.
To make sure you are eligible for participation according to the rules e.g. check if you are over 18 and not a Labour employee.	Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the Gambling Act 2005. And; 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 you are a winner, to ask permission to publicise you are a winner within marketing information for future Prize Draws. [NOTE: Where we have gained your permission and you withdraw this permission we will remove your data immediately although where this has been printed on leaflets and booklets we will make sure we don’t reprint this information and it may be in circulation until then]	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 note and take action on any replies from you that request to be opted-out of further engagement in Prize Draws, also known as ‘self-exclusion’.	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).
Labour works to improve its levels of engagement in Prize Draws and other marketing and funding initiatives and where you engage with a Prize Draw this will inform an engagement scoring processes. We also use this information to decide to make further contact with you where we think you would have interest in Labour’s new initiatives for engagement and activity.
To create pseudonymised identifiers to help reduce identifiability and allow us to monitor your activities within our systems.
To identify personal data and take relevant action upon submission of a data subject rights request. Note: any data subject rights requests submitted in the context of a Prize Draw will be for personal data processed within the Prize Draw only unless to specifically state otherwise.	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 stated will be under UK GDPR Article 9.2(g).

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; 

2. Pre-approved print and post service providers; and 

3. Payment service providers. 

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? 

The retention period for the personal data processed for Prize Draws is determined by the length of time the Prize Draw. Most Prize Draws are between 3-5 months although could be longer.  

Once a draw has been made for a particular Prize Draw we delete your Prize Draw entry information captured on paper as soon as payment has been processed and at least within one month of the transaction being complete. We add a record of your engaging with a Prize Draw you’re your Labour Member profile which you and we have access to. 

Printing service providers that print and send the Prize Draw tickets and invitations to enter deletes the personal data Labour shares with it upon completion of the print and send job they conduct on our behalf. 

If you are a winner and have agreed to participate in promotional activities for future Prize Draws and we have taken photos of you (which may also include your family and friends), and maybe a testimonial, we will hold this data indefinitely unless you tell us you no longer wish to be depicted in the promotional activities.  

When you tell us this we will make sure we will no longer print this or display this in any promotional material although anything already printed on a leaflet or other print media would not be able to be removed. 

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.