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Members and Supporters Privacy Policy

Who are the Labour Party?

We are the Labour Party and we are a century old political organisation, born 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 Z8604688).  It is sometimes the case that our local Labour Party offices have their own registration and separate privacy notices. 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.

The Labour Party’s Data Controller and Data Protection Officer details are included at the end of this document.

Scope of this Privacy Policy

This privacy notice sets out the way in which the personal data you provide to us (and the data collected by us) is handled, stored and processed.

It specifically provides information on how personal data of the following individuals are processed:

  • Labour Party Members;
  • Labour Party Affiliated Supporters;
  • Labour Party Registered Supporters.

Separate privacy notices are in place for the following individuals:

Contents
– How the Labour Party obtains your personal data
– How the Labour Party uses your personal data
– Special Category Data
– Why it’s necessary for the Labour Party to use your personal data
– When we might disclose your personal data
– Profiling and automated decision-making
– Transferring data outside of the European Economic Area (EEA)
– Security of your data
– How long we keep your data
– Your information rights
– Contact information

How the Labour Party obtains your personal data

Your information may come to us from a number of different sources.  You may provide it directly or indirectly, 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 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 notices above)
  • You apply to be a candidate in an upcoming election

Examples of where the Labour Party obtains information from other sources include:

  • Where information is collected by the Labour Party from available sources in the public domain, such as social media
  • When it is provided by others about you in relation to specific complaints or issues
  • From Trade Unions and Socialist Societies – particularly if you are an “affiliated supporter”.

There may be other sources of information where you are also a member of the General Electorate or a Labour Party Donor and these are described in the General Electorate and Donor Privacy Notice.

How the Labour Party uses your personal data

This section describes how we use your information.  Each purpose is described below with detail relating to:

  • Why we collect this information [Purpose]
  • What we collect – what personal and potentially more sensitive data we collect for this purpose [Information]
  • The source of this data – whether this was this 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]

Further use of personal data as part of being a member of the General Electorate, being a donor or more generally using Labour Party’s website and services can be found in the General Electorate and Donor privacy notice.

Joining the Party and renewing your membership online

Purpose
  • To allow the Labour Party to process your membership application and check you meet the conditions of membership, and to service the Contract you enter into when you join the Labour Party. To allow elected representatives nationally and locally, as well as candidates seeking selection in internal Labour Party elections to contact you, and in order to check you maintain the conditions of Labour Party membership.
Information
  • Name, contact email, telephone number, financial data, purchases and communications history and optional additional information such as gender, ethnicity, disability, date of birth and trade union membership to help us provide a better membership service to you. We may also use any information which you have made public, caused others to make public or which is already in the public domain.
Source
  • Provided by you and others via our website, social media channels, telephone or in writing. Collected by the Labour Party from available sources in the public domain.
Legal Basis
  • As part of the performance of a Contract to which the member or supporter is Party to and in the course of the Labour Party’s legitimate activities and in its interest as a political Party and membership organisation. In relation to more sensitive “special category” information such as ethnicity, disability and trade union membership, this will be done with explicit Consent of the member or supporter. That is, unless you become a Labour Party member via your trade union, in which case we would require this information in order to service the type of membership you are entering into.

Checking eligibility to participate in and administer the ballot process for internal elections

Purpose
  • To allow the Labour Party to check your eligibility to participate in and administer the ballot process for relevant internal elections, as determined by the Labour Party’s National Executive Committee (“NEC”), including sending electronic ballots. To share personal data with the relevant affiliated organisation, where appropriate, to verify you are a member of that organisation and to allow that affiliated organisation to update their records on the basis of the information you have provided.
Information
  • Name, address and contact email and other information provided as part of your application. Information that the Labour Party otherwise has a lawful basis to process (for example, your membership fees) and any information necessary from publicly available sources to confirm that you support the Party’s aims and values and meet the eligibility criteria set out in these terms.
Source
  • Provided by you as part of becoming a member or supporter of the Labour Party (see above) and from publicly available data sources.
Legal Basis
  • As part of the performance of a Contract to which the member or supporter is Party to, in particular the requirements of the Labour Party Rule Book.

Disciplinary Cases and other Legal Matters

Purpose
  • To manage disciplinary cases, the Party’s response to safeguarding and member welfare concerns, legal claims and ongoing litigation cases in order to ensure the application of the Party’s rules and procedures, and to manage ongoing cases.
Information
  • Names of individual/s involved in relevant disciplinary or legal case and any relevant information in relation to that individual. This would include the processing of personal data held on your membership record, as well as any wider publically available information that may be drawn to our attention, for example through a complaint made about you.
Source
  • Provided by you as part of any ongoing disciplinary or legal case. Collected from publicly available sources such as social media, or provided by others in relation to your case. Information may also be processed where there are concerns relating to wider criminal misconduct, which may involve the sharing of data with the Police and other relevant authorities.
Legal Basis
  • Necessary for performance of a Contract with you, namely to act in line with the Labour Party Rule Book. To comply with any Legal Obligation around safeguarding and welfare, and for the establishment, exercise or defence of legal claims. We may also process this using “Public Task”, where we act in the public interest to process your personal data, with a clear grounding in law.

Parliamentary and Wider Candidate Selection

Purpose
  • The use of CVs and applications for selection in parliamentary and other candidate selection processes to ensure these are being carried out in line with the Rule Book. The use of wider publically available information to ensure any representative adheres to the Rule Book and wider Labour Party values.
Information
  • Name, contact details, previous education and work experience and any other information provided within a CV and wider application. Special category data where monitoring forms are completed alongside an application – this includes ethnicity, sexual orientation and whether you consider you have a disability. Due diligence may also be carried out on any publically available information, such as social media posts, directorships, any available media history, property and financial holdings, misconduct, any publicly available special category information (e.g. political opinion, trade union membership, criminal offences).
Source
  • Provided by you to the Labour Party as part of a selection process. Publically available information, usually online.
Legal Basis
  • Necessary for performance of a Contract and within the Labour Party’s Legitimate Interests to ensure a candidate fulfils the Rule Book criteria. Where special category data is processed, this is processed using a mixture of both previously listed legal bases, as well as the additional condition of having been made public by the data subject.

Policy Development

Purpose
  • To allow members and supporters to provide views and feedback on key Labour Party policy areas.
Information
  • Name and email addresses of Labour Policy Forum users and individuals who submit policy ideas online or via email and survey results.
Source
  • Provided by you as a member or supporter.
Legal Basis
  • As part of the Legitimate Interests of the Labour Party to receive member and supporter views on policy areas to inform the wider Party.

Dealing with your enquiry, complaint, safeguarding or member welfare concern

Purpose
  • To allow the Labour Party to effectively deal with any enquiry, complaint, safeguarding or member welfare concern you or others may have. This includes whistleblowing.
Information
  • Name, contact email, telephone number and nature of the enquiry or complaint, potentially voice recordings from telephone calls made. Personal data of complainants, respondents and witnesses. This may also cover inadvertent processing of political opinion data if you are a member of the Labour Party.
Source
  • Provided by you and others via our website, social media channels, telephone or in writing. Potentially provided by another organisation that we have contacted about a complaint you have made and who gives us your personal information in its response or a complainant may refer to you in their complaint correspondence. This information is also in the public domain.
Legal Basis
  • As part of the Legitimate Interests of the Labour Party. This will only be carried out in a way that balances the rights and interests of individuals against the Legitimate Interests of the Labour Party. Further information about how this balance is assessed can be obtained by contacting the Labour Party’s Data Protection Officer.

Managing Events, Endorsements and Conference Ballots

Purpose
  • To allow the Labour Party to effectively run events and manage endorsements. To allow internal ballots to be run as part of Labour Party Conference.
Information
  • Name, contact email and telephone number, postcode and nature of the event you are attending. Potentially some more sensitive information on health requirements, should they be required, e.g. for ensuring appropriate accessibility to events and dealing with dietary requirements and personal information required by police for ensuring secure events including date of birth, town of birth, address, passport number, drivers licence details. Photographic images and CCTV may also be taken at event.
Source
  • Provided by you via our website or an email we sent to you, via an event booking site, telephone or in writing or by you during the event itself.
Legal Basis
  • As part of the Legitimate Interests of the Labour Party in running events that may be of interest to members and supporters, and what is constitutionally set out in the Labour Party Rule Book (Contract). Where special category data is required, we gather this with your Consent.

Dealing with rights of data subject requests

Purpose
  • To allow the Labour Party to respond to requests under the Data Protection Act for members and supporters to exercise their rights, e.g. to access their own data, request erasure of data, object to processing etc.
Information
  • Name, contact email and telephone number, nature of data subject request and proof of ID where required to verify your identity.
Source
  • Provided by you via our website, social media channels, via email, telephone or in writing.
Legal Basis
  • The Labour Party are legally obliged under the Data Protection Act to respond to data subject requests

Communications with members and supporters

Purpose
  • To ensure appropriate ongoing communications with you in relation to your relationship with the Labour Party, and for constitutional and fundraising purposes.
Information
  • Individuals name, email, contact numbers and financial data and communications history of all current, former and deceased Labour Party members, supporters and National Policy Forum members.
Source
  • Provided by the member or supporter. If you are an affiliated supporter, your affiliate organisation may have provided this information to us.
Legal Basis
  • The Labour Party must contractually (Contract) fulfil the obligations set out in the Rule Book for some communications.

Marketing and providing information on the work of the Labour Party

Purpose
  • To allow members and sponsors to be kept up to date via newsletters, briefings and other communications that may promote the aims of the Labour Party, including providing political messages on social media.
Information
  • Name, contact email, telephone number, geographic information (postcode/constituency), your interests and Consent status on willingness to receive this type of information.
Source
  • Provided by the member or supporter directly through, e.g., an online form on the Labour Party website.
Legal Basis
  • Some members and supporters may have signed up to receive marketing updates from the Labour Party using Consent and Legitimate Interest (depending on channel of communication).

Managing data breaches

Purpose
  • To be able to assess any impact on members or supporters of a data breach involving personal data held on Labour Party systems or on third Party systems.
Information
  • Any information relating to an individual that may have been breached, including information relating to members or supporters.
Source
  • From internal sources, from members or supporters who become aware of a breach or from any organisation that may have reported this data breach to the Labour Party.
Legal Basis
  • The Labour Party are legally required under the Data Protection Act to respond to data breaches appropriately.

Managing Expenses

Purpose
  • To allow expenses generated in your role as member or supporter to be reimbursed by the Labour Party.
Information
  • Name, address, contact details and bank account details of members and supporters.
Source
  • Provided by you as part of completing expenses forms.
Legal Basis
  • As part of the performance of a Contract to which the member or supporter is Party i.e. the Contract of membership or becoming a supporter.

Special Category Data

The Labour Party will sometimes need to process more sensitive data 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 compiles in the course of working with members and supporters. We also process this as part of the day-to-day running of a political party.  When processing this data, the Labour Party does so within the constitution, as set out in the Rule Book and also to administer any request made directly by you. Our internal membership system has safeguards in place, such as access management, which ensures your data is kept safe.

Where there is any possibility that use of this information would have a significant impact on your privacy or your rights under the Data Protection Act, a separate risk assessment will take place (“Data Protection Impact Assessment”) to ensure that all such risks are minimised. Where we cannot mitigate a high risk to you any further, we may seek advice from the ICO but we will not share your personal information with them.

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.  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 notice for Labour Party Members (“Young Members”) aged 14-17. 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.

Why it’s necessary for the Labour Party to use your personal data

In order to manage its members and supporters, the Labour Party needs to collect some personal data from you and other sources (as detailed above).  Without this information, the Labour Party would be unable to carry out these necessary functions.  At all times, the Labour Party will only use the minimum amount of your information required to be able to manage members and sponsors appropriately, and we take steps to periodically delete data we no longer need.

When we might disclose your personal 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 and proportionate for the purposes set out in this notice.

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 and conference services, who may need your information for security purposes, or seating requirements
  • The Police in relation to security of specific events
  • Respondents, NEC members, solicitors, counsel and claimants in relation to legal matters including disciplinary cases
  • Statutory agencies and/or the police in relation to safeguarding or member welfare concerns
  • Affiliated Trade Unions and Socialist Societies
  • Confidential Waste Providers
  • Volunteers working on behalf of the Labour Party

We may also 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.

Profiling and automated decision-making

The 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 does not carry out any automated individual decision making about members.  It does however carry out profiling including matching data from different sources for the purposes of profiling the wider general electorate, of which a member will also be part of.

We have developed a Profiling Notice which provides more information about how we use data for these purposes, which you can find here.

Transferring data outside of the European Economic Area (EEA)

Occasionally, in order to meet the purposes defined in this notice, 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 keep your data

Personal data that we process for any purpose will not be kept for longer than is necessary for that purpose.   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)

Some examples of how long we retain membership data are as follows:

  • Investigation into conduct of a member or elected official: This will be kept for the lifetime of the individual under investigation, in order to safeguard the wider public, uphold membership rules and defend any future claims through the courts;
  • 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.
  • Disciplinary outcome (e.g. expulsion): This will be kept for the lifetime of expelled individual, in order to safeguard the wider public, uphold membership rules and defend any future claims through the courts.
  • Call notes: indefinitely where this relates to disciplinary action and 15 years after cessation of membership for all other notes.
  • Self-declared equalities data: Seven years after end of membership.

Your information rights

You have a number of rights under data protection laws including:

  • The right to be informed about the collection and use of your personal data e.g. via this privacy notice
  • 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
  • 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 using the details below.

I want to know what information you hold about me

I want you to delete information you hold about me

I want you to change information you hold about me

I have another question about my data

 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) 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:

https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdf

Full information on your rights under the Data Protection Act can be found from the following link:

https://ico.org.uk/your-data-matters/

Contact information

If you want to know any more about how we use your information, or to raise a data protection complaint, you can get in touch with the Labour Party’s Data Protection Officer (the designated “expert” in data protection) using the following information:

Email: [email protected]
Post: Data Protection, Governance & Legal Unit, Labour Party, Southside, 105 Victoria Street, London, SW1E 6QT

If you have a wider membership query, you can contact our Membership Team here:

By post: The Labour Party Labour Central, Kings Manor Newcastle upon Tyne NE1 6PA
By telephone: 0345 092 2299
Please note, calls to this number are charged at a local rate from landlines and mobiles and will be included in any mobile minutes you have.


Contact information for the national offices

To get in touch with the Scottish or Welsh Labour Party please visit their websites or use the details below.

Scottish Labour Party 290 Bath Street Glasgow G2 4RE
Welsh Labour 1 Cathedral Road Cardiff CF11 9HA

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 notice 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 the Data Protection Officer via [email protected]

Changes to our Privacy Policy

This privacy notice 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 notice in the future will be posted on this page, so please check from time to time to see if there are any changes.