Privacy Notice for Labour Party Training
The Labour Party (“Labour”, “we”, “us”, “our”, the “Party”) is committed to protecting the privacy and security of the personal data we collect about individuals (“you”, “your”, “data subjects”, and “Learners”).
The purpose of this privacy notice is to explain what personal data we collect about you and use when we provide you all types of training including in person or online. When we do this, we are the data controller.
Please read this privacy notice carefully as it provides important information about how we handle your personal data and your rights. If you have any questions about any aspect of this privacy notice you can contact us using the information provided below or by emailing us at [email protected] quoting “Labour Training” or “#LPN713” in the subject or body of the email.
2. Personal data we will collect from you
- Name, age, email address, telephone number, home address/location
- Gender, ethnicity, whether you have a disability
- Any further training you have participated in, in the past
- Any personal information you volunteer about yourself within a training session or in communications with us
- Roles held within the Party and affiliated organisations
- Where applicable within the nature of the training being delivered:
- Dietary requirements
- An image of you
3. How we collect information about you
We will collect personal data from Learners in a variety of ways. We refer to “direct data collection” when data is collected directly from you, and we refer to “indirect data collection”. We collect personal data about you in the following ways:
- From yourself upon becoming a member of the Labour Party (“Members”) and when you may request further training (direct data collection)
- From yourself upon becoming a member of staff at Labour (“Staff”) and when you may request further training (direct data collection)
- From yourself upon requesting training from Labour for activities you are participating in for Labour via our website or other means when you are not a Member and not Staff (direct data collection)
- From Staff or a Member who has recommended yourself to us for training to be provided to you (indirect data collection)
- From yourself within verbal or digital communications or conversations in (person/online/telephone) you have either with Labour or with a training partner organisation on Labour’s behalf (direct data collection)
- From a training partner organisation on Labour’s behalf where Labour has not been the first point of contact for you (indirect data collection)
- From yourself via an online form or survey we have sent you (direct data collection)
4. Purposes for using your personal data and the lawful basis
We will use your personal data for the following purposes and on the following lawful bases. The table below is relevant to all Learners:
|4.2 Lawful Basis for Processing
|To provide you with relevant training on behalf of Labour either in anticipation of activities you will be conducting, to refresh your training, to meet a regulatory or compliance requirement, or for best practices maintained by Labour.
|If you are considered to be Staff (including external consultants and contractors) the lawful basis we will be relying on is in accordance with UK General Data Protection Regulation (“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 i.e. your contract of employment or consultancy agreement etc. Where you are providing any services or activities for Labour there may be a legal obligation for us to provide relevant training to you before you participate in that activity or handle any personal data the lawful basis we will be relying on is in accordance with GDPR, Article 6.1(c) for laws which include, but are not limited to, the Children and Social Work Act 2017; Antisocial Behaviour Act 2003; Representation of the People Act 1983 etc. The lawful basis we shall be relying on for any other training is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f).
|To invite you to attend a training session either in person or online.
|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 allow you access to online training materials and for training to be delivered to you online.
|To monitor Learner attendance and follow up any non-attendance.
|Where training is in-person, we will use your personal data to ensure any accessibility requirements are met and, if applicable, we can account for dietary requirements.
|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). Special categories of personal data used for the determination of any health-related accessibility requirements will be under UK GDPR Article 9.2(h).
|To update a regulatory body based on any relevant statutory requirements.
|The lawful basis we shall be relying on is GDPR, Article 6.1(c) in which the relevant law will be specified in the lead up to the training.
|To update a regulatory body or external assessor based on best practice or requirements of the type of training you are receiving.
|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 send you a questionnaire or survey to complete within the training and also as a follow-up after the training has finished so we are able to engage further with Learners and monitor effectiveness of the training provided or the training provider.
|To send you any certificates or notification of qualification or outcomes of the training.
|To notify you of further training you may like to attend. We will only send you these notifications if you have expressed an interest in receiving training from Labour either verbally or digitally or you have attended a training session in the past. Note: You can let us know if you no longer wish to receive these notification by either, clicking ‘Unsubscribe’ if the email is from an emailing service we use, notifying the course leader, leaving a message within the digital training platform (if available), or by emailing [email protected]
|Where you have expressed an interest in further participation in Labour’s activities as a result of training we will use your personal data to make contact with you to explore the options that may be available to you. Note: Upon contact where you express a desire to participate in further activities with Labour, this privacy notice will no longer apply and you should refer to https://labour.org.uk/general-electorate-and-donors-privacy-policy/ for how your personal data will be used.
|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 stated will be under UK GDPR Article 9.2(g).
5. Sharing your data
It is unlikely that we’ll ever share your personal data outside the UK. If, however, it becomes necessary for the purposes of conducting training we will only share it with organisations in countries benefiting from a UK or European Commission adequacy decision, or on the basis of International Data transfer Agreements or European Commission Standard Contractual Clauses with a UK required addendum (all of which are recognised by the UK) which contractually oblige the recipient to process and protect your personal data to the standard expected within the UK.
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 pre-approved review to ensure comparative technical and organisational measure for keeping the data secure.
- External training providers for in-person training
- Online digital training platform service provider(s)
- Where relevant, the National, Regional and/or Local Labour Party offices
- Digital communications and storage providers (for email and maintaining relevant records)
- Pre-approved online survey platform providers
- If applicable, training location providers and/or catering providers
- If applicable, regulatory bodies or certification providers
- If applicable, your employer
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. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.
Where you have provided your permission for us to use your personal data within the wider activities of the Party we will use your personal data in line with our website privacy notice which can be found on: www.labour.org.uk/privacy-policy/
6. How long we keep your data
We keep your personal data for the minimum time necessary for the training to be provided successfully and for any necessary follow ups as required.
Personal data shall be reduced, redacted, de-identified and deleted at appropriate times so we retain the minimum amount of personal data possible. For example, a paper based login sheet at a venue will be destroyed once added to a digitised spreadsheet or training platform.
In general, unless any other laws are not in conflict with this, we will keep a record of your training with the minimum amount of data necessary for at least 7 years. If you are Staff or a Member, we will keep a record of your training for at least 7 years after you are no longer Staff or a Member.
Local record keeping may differ where it is associated to a Local Labour Party known as a Constituency Labour Party (CLP) or a Member of Parliament’s Office (MPO). It is highly likely they will also keep you training records on file for at up to 7 years. Any training records shared with CLPs and MPOs from Labour are in alignment with a Labour data protection framework in place with them which governs such sharing, this means that they are able to make local adjustments to how long they keep your training data. To understand these differences either see their website or contact them directly.
7. How we protect your data
We implement appropriate technical and organisational measures to protect data that we process from unauthorised disclosure, use, alteration or destruction. Data protection risk assessments are conducted where necessary in alignment with the requirement of the GDPR.
We will always keep these under review to make sure that the measures we have implemented remain appropriate. Any personal data is not subject to any automated decision-making.
8. Your rights and options
You have the following rights in respect of your personal data:
- You have the right of access to your personal data and can request copies of it and information about our processing of it.
- If the personal data we hold about you is incorrect or incomplete, you can ask us to rectify or add to it.
- Where we are using your personal data with your consent, you can withdraw your consent at any time.
- Where we are using your personal information because it is in our legitimate interests to do so, you can object to us using it this way.
- Where we use your personal data for direct marketing, including profiling for direct marketing purposes you can object to us doing do.
- You can ask us to restrict the use of your personal data if:
- It is not accurate,
- It has been used unlawfully but you do not want us to delete it,
- We do not need it any-more, but you want us to keep it for use in legal claims, or
- if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
- In some circumstances you can compel us to erase your personal data and request a machine-readable copy of your personal data to transfer to another service provider.
- You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, please contact us at [email protected]
9. How to Complain
You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk/concerns.
10. Contact us
If you have any questions, or wish to exercise any of your rights, then you can contact:
Organisation: The Labour Party
Address: Labour Central, Kings Manor, Newcastle upon Tyne, NE1 6PA
Alternatively, you can email us at [email protected]
11. Changes to this privacy notice
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.
Last modified 03 January 2024.