General Electorate and Donors Privacy Policy
Who we are
We are the Labour Party and we are a century old political organisation, borne out of the trade union movement and built on equality, social justice and compassion. We are committed to placing the rights of individuals at the centre of how we collect, hold and process personal information.
The Labour Party is registered with the Information Commissioner’s Office for data protection purposes (registration number Z5487928). It is sometimes the case that our local Labour Party offices have their own registration and separate Privacy Policies. This might be the case where they are using your personal data for local campaigning purposes. Your local MP is also likely to use your personal data in some way and we would encourage you to always check any applicable websites, or contact your MP, if you need further information about this.
Scope of this Privacy Policy
This Privacy Policy sets out the way in which the personal data you provide to us (and the data collected by us) is handled, stored and processed.
Separate Privacy Policies are in place for the following individuals and can be accessed via these links:
Contents
– How we obtain your information
– Special Category Data
– Does the Labour Party have to use my personal data?
– Third party data use
– How we use your information
– Record Management
– Profiling
– When we might disclose your data
– Transferring data outside the European Economic Area (EEA)
– Security of your Data
– How long we retain your personal data
– Your rights and how to contact us
– How do I raise a concern if my rights are not met?
– Different versions of this Privacy Policy
– Changes to our Privacy Policy
How we obtain your information
Your information may come to us from a number of different sources. You may provide it directly or indirectly, we may purchase this data, or it may be publicly available information.
Information may be provided directly by you in some of the following circumstances:
- You complete a form on our website
- You sign up to attend one of our events
- You fill out a form delivered by a Labour Party representative
- You have a conversation on the doorstep or over the phone with a Labour Party representative about your views
- You interact with us online, including on social media channels such as Facebook or Twitter
- You interact with the party in some other way, such as joining the party as a member, affiliated or registered supporter, donating or signing up to volunteer for us (see separate Privacy Policies shown at the top of this policy)
- You apply for a job at the Labour Party
Examples of where the Labour Party obtains information from other sources:
- Information taken from the electoral register (even where you have opted out of the “open register”)
- Publicly available data such as census information and election results, as well as contact information we might purchase lawfully via the BT OSIS service (equivalent to the BT Phone Book)
- Commercially available data including both information specific to you (such as date of birth), as well as estimates of other personal information (such as whether your house is council-owned or privately owned), and other information linked to the area you live in (this is called “geodemographic segmentations”)
- Information about whether our efforts to contact you in person or over the telephone have been successful, and survey data which you may have directly provided to us or a third party.
The Labour Party, by virtue of regulations made under the Representation of the People Act (1918), the Political Parties Elections and Referendums Act (2000) and other connected legislation, have a statutory right to some of the above data.
The data we hold to which we do not have a statutory entitlement is either data which is made available for use in a way that permits its use by political parties (for example census data, national land registry data, local election results, or data released through a Parliamentary Question, or Freedom of Information (“FOI”) request, where the data released in response to that question or request is not restricted from such reuse), or is provided through commercial agreements with suppliers who make such information available for resale to a range of customers. You can find out more about how we protect your personal data in the next section.
Special Category Data
The Labour Party will sometimes need to process more sensitive data, which is known under the Data Protection Act as “special category data”.
One of the main areas where this occurs is in relation to your political opinions, which the Labour Party may compile in the course of its electoral activities. This may be collected directly from voters on the doorstep, on the phone, online via a web survey or form, or we may estimate it. Our legal basis for using this data is listed in the table in the previous section. The maintenance of political opinion data collected by political parties and combined with electoral register data is a long established feature of the operation of the democratic system in the UK and crucial to our engagement with voters as a core part of the democratic process.
Other information that is considered more sensitive is personal information in relation to children. The Labour Party does not knowingly process any personal details from individuals under the age of 14 without parent/guardian consent. Details of under 18s are processed as part of their inclusion in the electoral register in the year they attain voting age, for membership purposes, or for other purposes defined prior to the data being submitted. The Labour Party is aware of its obligations under the ICO’s Code of Conduct in relation to “Age Appropriate Designs”, and provides a separate privacy Policy for those members aged 14-17. For those individuals who are included on the electoral register before they turn 18, a separate fact sheet is included about how we use this data, which can be found here.
The Labour Party may process the personal data of children to comply with our responsibilities under the Children Act 2004 and the government safeguarding guidance contained in Working Together to Safeguard Children for England and Wales and National Guidance for Child Protection in Scotland.
Does the Labour Party have to use my personal data?
There is no specific obligation for members of the public or donors to provide their personal data unless it is needed for a specific purpose, such as providing further information on the work of the Labour Party. Where such personal data is needed to fulfil these purposes, then not providing this information may make it more difficult to carry out these. The Labour Party are legally entitled to use some of your data in certain circumstances and this is clearly detailed under the section “How do we obtain your information?”.
Third party data use
Where personal data is provided to us by a third party, we will make sure that these third parties have provided you with appropriate privacy information on the sharing of this data with the Labour Party and that they have a clear lawful reason for sharing this data.
Where this is found not to be the case, we will make every effort to make sure you are aware that we are processing this information within a month. Where contacting you directly in relation to this is difficult to achieve, then we will ensure that our Privacy Policies clearly detail where this is happening.
We have checks in place on the third parties we use, in order to ensure their data protection practices comply with the law. This includes checking what you were told when your personal data was collected, in order to ensure that the third party was transparent with how your information would be used. Where we are not satisfied with the information a third party has provided to you, we will review whether we are able to continue using this data. The protection of your personal data is our priority. There is also further information about our use of third parties in the separate “Profiling Privacy Policy”.
If you provide personal data related to a third party to us for any reason (i.e. you are the third party in this instance), you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this Policy. You can find contact information at the end of this Policy if you have any queries related to this.
How we use your information
This section describes how we use your information and our lawful basis to do so. Data protection laws set out there are six lawful bases that could apply depending how personal data is used – each of these have equal validity. The six lawful bases are as follows:
- Consent: you have explicitly said the Labour Party can use your personal data for a set purpose
- Contract: the Labour Party is delivering a contractual service to you
- Legitimate interests: the Labour Party has determined it has a legitimate interest in using your personal data and that this has minimal impact on your privacy
- Public task: the Labour Party is using your personal data to perform a specific task in the public interest that is set out in law
- Legal obligation: the Labour Party has a legal obligation to use your personal data
- Vital interests: the Labour Party is using your personal data in order to save your life.
We use a variety of lawful bases to process your personal data and this section explains this in more detail. In the following section, each purpose is described with detail relating to:
- Why we collect this information [Purpose]
- What we collect – what personal and potentially more sensitive data (also known as “special category” data) we collect for this purpose [Information]
- The source of this data – whether this was data was provided by you or obtained from another source [Source]
- Our legal justification for using this data – what lawful basis the Labour Party relies on under the Data Protection Act 2018 and other laws for using your data in this way [Legal Basis]
- Our additional condition to process your special category data [Additional Condition]
- How long we retain this information [Retention]
Record Management
The Labour Party regularly “weed” records so as to ensure that we retain the minimum amount of personal data in order to fulfil the purposes originally set out. We have a Retention Policy and all departments routinely check that they are securely deleting your personal data when it is no longer required.
Profiling
The EU General Data Protection Regulation includes certain provisions around how personal data can be used for:
- Profiling – where personal data is processed to evaluate certain things about an individual
- Automated individual decision making – where a decision is made based on your personal data solely by automated means
This includes ensuring that individuals are made aware of this profiling, how decisions are made based on this, and the consequences of these decisions.
The Labour Party may carry out automated individual decision making about individuals. It does however carry out profiling including matching data from different sources for the purposes of profiling the general electorate.
Wherever possible, the Labour Party will make you aware of any new profiling activities including their data, unless a detailed risk assessment demonstrates that this may involve disproportionate effort, or proves to be impossible. In such a case, this Privacy Policy will be updated to include any new processing activities.
You can find out more about profiling by opening our Profiling Notice.
When we might disclose your data
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes set out in this Policy.
We may share your data with third parties to perform services on your behalf and to help promote the Labour Party by serving you advertisements and content online about our politicians, campaigns and policies we think you might be interested in. Types of third parties who may have access to your personal data include:
- Third Party IT System Suppliers who may host your data on their systems and may need some level of access to resolve technical concerns
- Printers and digital advertising suppliers to print off and send out campaign materials
- Event venues, who may need your information for security purposes, or seating requirements
- The Electoral Commission for publication of donation information in line with regulatory requirements
- The Police in relation to security of specific events
- Solicitors, counsel and claimants in relation to legal matters
- Statutory agencies and/or the police in relation to safeguarding or member welfare concerns
- Social Media Providers
- Confidential Waste Providers
- Volunteers working on behalf of the Labour Party
We may disclose your personal information:
- to the extent that we are required to do by law
- in connection with any ongoing or prospective legal or safeguarding proceedings
- in order to establish, exercise or defend our legal rights (including providing information to others for the purpose of fraud prevention and reducing credit risk)
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such or authority would be reasonably likely to order disclosure of that personal information
We will never sell or share your personal information with other organisations for their direct marketing purposes without your explicit consent.
Transferring data outside the European Economic Area (EEA)
Occasionally, in order to meet the purposes defined in this Policy, we may need to transfer personal information you submit to us to countries or jurisdictions outside the EEA.
In each case, we ensure that our suppliers provide adequate protection for the confidentiality and security of this information and the rights of data individuals in connection to the transfer of their personal data.
Specific safeguards are in place to govern this sharing, including ensuring that relevant suppliers include standard contractual clauses agreed by the European Data Protection Board for international transfers within their contracts.
The measures listed above have been agreed as appropriate by the Information Commissioner’s Office.
Security of your Data
The Labour Party is committed to processing and retaining data within established technological and physical controls in a transparent manner, as well as promoting and safeguarding the information rights of data subjects.
The Labour Party has established procedures to ensure that technological and physical controls are in place that guarantee the privacy of data subjects, the security of data held on technological systems and that all data held by the Labour Party is processed according to an established lawful processing condition. Any such procedures will be reviewed as necessary and updated to ensure their effectiveness in line with advances in technology.
Our website has security measures in place to protect against the loss, misuse or alteration of the information under our control. Our servers are located in a locked, secure environment, with a guard posted 24 hours a day. When you donate online, we use a secure server to protect your credit card number and other personal information during transmission. The details are transmitted using encrypted mechanisms to ensure absolute security.
How long we retain your personal data
Personal data that we process for any purpose will not be kept for longer than is necessary for that purpose. Different purposes will have different retention periods, and we will (for example) retain data about whether you were on the electoral register, for purposes of checking the permissibility of donations, for longer than we would retain profiled information estimating your likelihood to vote in a general election.
Notwithstanding the other provisions of this section, we will retain your personal data:
- to the extent that we are required to do so by law, for example, for HMRC purposes
- if we believe that the information may be relevant to any ongoing or prospective legal proceedings
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
- to support the ongoing business purposes of the Labour Party as specified above (with due consideration for the rights and freedoms of individuals privacy)
- If we believe we have an overriding legitimate interest in order to do this. This is particularly the case for the “right to erasure”, where we maintain a minimal amount of information on our records.
Some examples of how long we retain your data are as follows:
- Names, addresses and values of donations given to the Labour Party – Indefinitely where we believe you may leave a legacy to the Labour Party. 7 years (from tax year of transaction) for all other financial data.
- Call notes and correspondence: indefinitely where we believe you may leave a legacy to the Labour Party. 10 years for all other data.
- Electoral Register data: we will retain this for a period of 15 years (subject to any updates we receive around a change of address);
- Profiled data: any data subject to profiling is retained for a maximum of 7 years.
- Interview notes: retained for 6 months and then securely destroyed.
Your rights and how to contact us
You have a number of rights under Data Protection law including:
- The right to be informed about the collection and use of your personal data e.g. via this Privacy Policy
- The right to access your personal data, also known as a subject access request (this allows you a right to your data, but not data related to other individuals)
- The right to have any inaccurate personal data rectified, or completed, if it is incomplete
- The right to have your personal data erased in certain circumstances (subject to the Party’s overriding legitimate interest, as outlined previously)
- The right to request the restriction or suppression of their personal data in certain circumstances
- The right to data portability – to obtain and reuse your personal data for your own purposes across different services
- The right to object to our use of your information in certain circumstances e.g. for marketing or profiling purposes
If you would like to do any of these things, or raise any other concern about how we use your information, please contact us by emailing [email protected] and stating your request clearly.
In the majority of cases, we will respond to your request within one month of receiving the necessary information required to deal with your request.
We may ask you to supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus an original copy of a utility bill showing your current address) and any additional information to help us to deal with your request effectively.
There may be some exemptions to dealing with your rights as specified in Data Protection law, but we will ensure you are fully informed of this within a month of receiving your request.
We follow the ICO’s Code of Practice when dealing with requests for access to personal data, which you can find here:
Full information on your rights under the Data Protection Act can be found from the following link:
How to raise a concern if your rights are not met
If you have a concern that cannot be resolved through discussion with us, these can also be raised with the Information Commissioner’s Office. The contact information for the ICO is as follows:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/concerns/
Different versions of this Privacy Policy
The information provided within this Privacy Policy can be made available in different formats including in printed form, different languages and approaches that meet the needs of the visually and hearing impaired.
Should you require this information in a different format, please contact [email protected]
Changes to our Privacy Policy
This Privacy Policy will be reviewed annually or sooner, should any new types of processing be identified, or changes to current data protection legislation may mean changes are required. Any changes we may make to our Privacy Policy in the future will be posted on this page, so please check from time to time to see if there are any changes.