What personal data do we collect? 

We collect and using the following personal data: 

• Title, first name, last name, preferred name(s), email address, post code, home address (and old home addresses), telephone number(s), date of birth, gender; 
• Polling number, polling district, ballot box number, polling place name, road group, polling place address, polling place post code, local authority; 
• Political opinion, voting intention and, if gathered, scales from 1-10 of voting intention for Labour and other political parties where 10 is most likely to vote in that direction; 
• Notes about you collected during our campaign based interactions with you;  
• Campaigns we have been running where your information was used within the campaign and whether you interacted with us; 
• Any communications we have with you which may be over email, telephone or face to face; 
• Any personal data you volunteer in any free text fields in any paper-based or digital polls, surveys, questionnaire or webforms that are captured at the national, local, branch or ward level by any part of the Labour Party where you have provided enough information to be able to identify you; 
• Depending on how you may have interacted with any physical or digital locations managed by Labour, we may collect publicly available information on websites inc. Companies House, Land Registry, news and broadcast media or historical publications etc.; 
• Depending on how you may have interacted with any digital campaign locations managed by Labour, we may collect and use, or have used on our behalf, any personal data, language /or and behaviour within the public domain such as social media posts (X, Meta platforms, YouTube etc.);  
• If you have disclosed these to us in the course of our campaigning, we may know you political affiliation(s), opinion and/or opinion(s) on various societal concerns and improvements, all of which may be at a national or local level, including policy ideas you may have and how you submitted them;  

• Estimated data from third-party companies regarding lifestyle, employment, income, and property which is aggregated (also known ‘aggregated data’) but we are unable to use this to directly identify you; and 
• Pseudonymous and anonymous data we have created from your personal data but we and others are unable to use this data to directly identify you. 

Related areas of personal data collection: 

• Information related to any donations you make to Labour (also see our Donors Privacy Notice) 
• Information you provide in relation to surveys and questionnaires you may complete (also see our Surveys Privacy Notice); and 
• Where applicable, CCTV footage of you, image and videos you have allowed us to take of you as an ‘Endorser’ to Labour  (also see our Endorsers Privacy Notice). 

Where do we get your personal data? 

We may collect personal data in a variety of ways and at a variety of times throughout our interactions with you. 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. Here is the list of ways we will collect your personal data from you: 

• From the Electoral Register (indirect data collection); 

• The ‘Marked Register’ data (the record of whether or not people on the electoral register voted at a given election, which is available for political parties to purchase) (indirect data collection); 
• The ‘Full Electoral Register’ (which is everyone that is registered to vote unless you are registered anonymously) which also includes your home address;  

NOTE: although you may have opted out of the open register it does not affect whether political parties get access to your data or not i.e. even if you have opted out, we will still have a copy of your data from the open register. 

• From yourself via email, telephone or face to face communications we have with you (direct data collection); 
• Demographic data about you from our commercial supplier (Experian), and BT Osis (indirect data collection) 
• Data on political opinions we have collected from you on the doorstep, phone or via other methods of capturing data directly from you (direct data collection); 

• Online or physical surveys, questionnaires or polls you have answered or completed for us where you may or may not have had the option to tell us who you are, or you may have chosen to remain anonymous (direct data collection); and 
• Publicly available data from areas such as census data (indirect data collection). 

NOTE: 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. 

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

NOTE: For most of the uses of your personal data, we are not required to get your consent from you.  

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 perform our activities of democratic engagement with you. [From the Data Protection Act 2018: “The term “democratic engagement” is intended to cover a wide range of political activities inside and outside election periods, including but not limited to: democratic representation; communicating with electors and interested parties; surveying and opinion gathering, campaigning activities; activities to increase voter turnout; supporting the work of elected representatives, prospective candidates and official candidates; and fundraising to support any of these activities“]	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), also known as “Public Task”. And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To allow Labour staff, volunteers and other members of the Labour Party carry out political campaigning with the general electorate data we hold which includes engaging with voters as part of the democratic process, face-to-face canvassing and “Get out the vote” on election days. I.e. this may mean we have printed your information so that people who are knocking doors are able to know who you are and whether you have positively engaged with Labour in the past or now; it may also mean your personal data is securely accessible on our canvasser’s digital devices for short periods whilst walking the streets and knocking on doors.
For us to identify and distribute the most effective political campaign messaging to a demographic or geographic area you belong to or where you may be located [NOTE: this is generally aggregated data we have purchased and usually is not able to directly identify you]	Our legal basis for profiling is a mixture of both Legitimate Interests (GDPR Article 6 (f)) and Public Task (GDPR Article 6(1)(e)) in order to engage with voters and send them messages which they are likely to be interested in. And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To inform our campaign targeting and demographic modelling activities through profiling of your data from any location we may legally correct your personal data [NOTE: for further information please see our Profiling Privacy Notice].
To respond to you when you have engaged with us or any campaign material whether via social media, generic digital campaign locations on websites which may be polls, surveys and/or questionnaires, or email or SMS (text) distribution lists you are legitimately on that either we already hold or a partner on our behalf holds already where they have a lawful basis to do so.  send you marketing material either in the post, via email or text (SMS). [NOTE: this is for commercial benefit to help the goals of Labour and not for directly related to political campaigning activities where we are not required to gain your consent.]	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). [Depending on how you interact with us the lawful basis may be in accordance with UK GDPR Article 6.1(e), also known as “Public Task”.] And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To send you marketing material either in the post, via email or text (SMS). [NOTE: this is for commercial benefit to help the goals of Labour and not for directly related to political campaigning activities where we are not required to gain your consent.]	The consent you have provided us for this use of your personal data in accordance with UK GDPR Article 6.1(a). And, The consent you have provided us for this use of your special categories of personal data in accordance with UK GDPR Article 9.2(a).
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).

NOTE: For further information on how political parties may use your personal data from the Electoral Register as specified by the UK regulatory body for data protection, the Information Commissioner’s Office, you can access this information by clicking here. 

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? 

NOTE: We never sell your personal data. 

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. An electoral roll database management service provider; 

2. Digital communications and storage service providers; 

3. If applicable and you have interacted with them, online polling, survey, questionnaire or web-form platform providers; 

4. Labour’s digital campaign team of designers and physical printing facilities and external print organisations; 

5. Any department or unit within the Labour Party with an authorised level of secure access to electoral register data; 

6. If initiated by you and where relevant and agreed by you or your representative, Labour Candidate(s) or MP’s or their office staff (both of which are separate data controllers although this Privacy Notice will be relevant for any work you do with them); 

7. If initiated by you and where relevant and agreed by you or your representative, your Constituency Labour Party (CLP) or local Labour groups or affiliated organisations (all of which are separate data controllers although this Privacy Notice will be relevant for any work you do with or for them); 

8. If initiated by you and where relevant and agreed by you, media organisations which may include news media and journalists who represent specific and relevant views; 

9. If initiated by you and where relevant and agreed by you, charities, charitable causes or individual families which have the possibility of being positively impacted from your contact and engagement with them (if agreed, any further uses of your personal data will be in line with their privacy information and Labour takes no liability for any use of your personal data in how they use your personal data); and 

10. If applicable, with Police, Law Enforcement Agencies, Healthcare Services including the NHS, Adult Services, Children Services, Local Authority Designated Officers (LADO), charities, charitable organisations or agencies or any other safeguarding related institutions or organisation(s), solicitors, legal counsel and/or claimants. 

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. Personal data that we use 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. 

Unless you specifically tell us otherwise, we will retain your personal data in all locations where it is currently held or until such a time it is no longer tenable to keep your personal data for any reason.  

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; 
• 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); and 
• 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. 

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. 

Last modified: 05 March 2024.