Privacy Notice for the National Policy Forum

What personal data do we collect? 

The National Policy Forum (NPF) plays a crucial role in the development of the Labour Party’s policy platform to support the new Labour Government and build towards the next General Election.  

The NPF consists of around 200 representatives drawn from across the Labour movement and the country, who consult with the general public, members, affiliates, experts and stakeholders to hear their views on key policy areas. 

Below is a list of personal data we may collect when you engage with the National Policy Forum (NPF) although not all categories will be relevant for capture from everyone who engages. 

There may also be times when you have volunteered this information and when you have the opportunity to opt-out of providing certain pieces of information at various times: 

  • Title, first name, preferred first name, last name, email address, post code, home address, telephone number(s), date of birth, and gender; 
  • Labour Membership Number and therefore your political opinion; 
  • Ethnicity, whether you have a disability, any membership to a trade union, socialist society or any affiliated groups, your electoral roll number, and if applicable photo ID or other requested ways to verify your identity; 
  • Any roles and responsibilities you have as a Labour Member (e.g. MP, PPC, CLP Secretary, Local Councillor etc.); 
  • Any communications we have with you which may be over email, telephone or face to face; 
  • 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; 
  • Availability information which may include location information, dietary requirements and any accessibility requirements you may have; 
  • Possibly your job title, name of your business or employer, industry sector, and work address; 
  • Audio/Visual recordings, photographs, images and any videos recorded within any interviews you have with us or you are conducting that we are (and you may be) recording; 
  • Any personal data you volunteer in any free text fields in any paper-based or digital surveys, questionnaire or webforms or emails that that you complete in relation to the NPF; 
  • Personal information related to the Equality Act 2010 inclusive of data known as ‘Protected Characteristics’ (age, disability, gender reassignment, marriage or civil partnership (in employment only), pregnancy and maternity, race, religion or belief, sex, sexual orientation); 
  • Personal information related to our internal equality and diversity monitoring policy (geographical location, organisation, socio-economic class, caring responsibilities, educational background); and 
  • Aggregated data, and pseudonymous and anonymous data we have created from your personal data but we are unable to use to directly identify you. 

Information on ‘Special Category’ personal data: 

The Labour Party will sometimes need to process more sensitive data known under the Data Protection Act as “special category data”. For the regulator’s definition and further information on what is meant by “special category data” you can access it on the Information Commissioner’s Office (ICO) website by clicking here

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. We also use this as part of the day-to-day running of a political party.  When using 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. 

Where do we get your personal data? 

We will 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 may collect your personal data from you: 

  • From yourself when you engage with the National Policy Forum in any capacity including through website and email policy submissions, and in-person and online events (direct data collection); 
  • From yourself if you become a National Policy Forum (NPF) representative (direct data collection); 
  • From yourself when you became a Labour Member or when you renew your membership (direct data collection); 
  • From yourself via email, telephone or face to face communications we have with you (direct data collection); and 
  • From any photographs/video taken by any individual representing Labour as a photographer or videographer during any National Party Forum gatherings or events (indirect data collection). 

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

We may use your personal data for the following purposes and on the following lawful bases. Not all purposes for using members personal data will be relevant to all members all of the time.  

NOTE: We do not sell your personal data to any third parties. 

Purpose for using personal data Lawful basis for using 
To process your interest in the National Policy Forum (NPF) and to review any items you have submitted. The lawful basis we shall be relying 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. 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 register you as an NPF contributor or representative, manage your NPF contributions / membership and communicate with you about all relevant matters over email, text (SMS) or by post e.g. policies, NPF ballots, campaigns, events, Conference, fund-raising, party updates etc. 
To identify you as the originator of an NPF submission or as an expert who has provided an opinion which will be circulated with NPF representatives. 
To allow the Labour Party to check your eligibility to participate in and administer the NPF ballot process for relevant NPF ballots, as determined by the Labour Party’s National Executive Committee (“NEC”), including sending electronic ballots. 
To keep you informed and updated about the National Policy Forum which includes sending a newsletter to you and inviting you to events and meetings. 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). 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 ensure the Labour Party rule book is being followed in how all communications and actions by all NPF members, attendees and those who manage the NPF, are conducted and to take action necessary action where this is not the case. 
To remove you from the NPF based on the policy of not accepting or tolerating violent or discriminatory language. 
To share your contribution and NPF membership details and relevant contact details, or access to them, with relevant MPs, Labour Candidates, Labour Staff, Local Labour Organisers, other Labour Members (who are authorised via internal protocols), and other NPF contributors and NPF members for the purpose of NPF functions and requirements. 
Where you have specifically indicated to us as appropriate to do so, share personal data with a relevant affiliated organisation 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. 
To provide you with NPF related training that is of assistance to you as a contributor or member of the NPF. 
To help us develop Labour policy and documentation based on your views and opinions and any communications you have with us. 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 conduct polls, petitions and ballots within the NPF. 
To conduct investigations into concerns or complaints about electoral fraud, financial fraud, criminality, safeguarding issues, welfare issues, inappropriate behaviour displayed toward members of the public or other Members, or any other activities which may cause or have the possibility of causing harm to others, either about you, where you may have been harmed, or where you are assisting us or acting as a witness. Where relevant, based on the outcome of investigation, we will also administer membership suspensions and expulsions based on the investigation. 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). 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 18 – Safeguarding of children and of individuals at risk; and Paragraph 19 – Safeguarding of economic well-being of certain individuals, of the Data Protection Act 2018. 
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). 

If you have interacted with the Labour Party 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 the Labour Party, a Data Processing Agreement, in accordance with UK 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 membership, communications and storage providers; 
  1. Pre-approved online balloting, survey, questionnaire or web-form platform providers; 
  1. Pre-approved digital campaign designers and physical printing organisations; 
  1. Any department or unit within the National Labour Party with an authorised level of access to the NPF folders or digital system; 
  1. If 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 the NPF do with them where you have been directly involved); 
  1. If relevant to your Constituency Labour Party (CLP) or local Labour Candidate or MP’s office your data will be made accessible to them (all of which are separate data controllers although this Privacy Notice will be relevant for any work the NPF do with them where you have been directly involved); 
  1. If relevant, venues, hotels, travel companies and any other concierge services;  
  1. If relevant and agreed by you, media organisations which may include news media and journalists who represent specific and relevant views; 
  1. If 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 
  1. If applicable and within the right conditions, 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). 

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 the Labour Party 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’.  

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 and deleted at appropriate times so we retain the minimum amount of data possible when you are an NPF representative and further reduced when you are no longer a member. 

On the basis of keeping people safe from any harm, and our legitimate interest in knowing who has or has not been a participant of the NPF in the past when there may be future safeguarding or legal concerns or requests for information, we retain all personal data we have captured from you. 

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

Where you do submit a right to deletion request, we will delete you from any and all locations we hold your personal data where it would mean we may make contact with you again (outside of our copy of the Electoral Register, and outside of when you make contact with us) although we will retain your information if: 

  • It has been, or is being used within a complaints, disputes or grievance process by Labour and we may need to evidence this in the future to defend legal claims; 
  • We need to keep it to comply with a legal obligation; 
  • Erasing your data would prejudice scientific or historical research; 
  • There is information associated with your data which is of a safeguarding concern to yourself or others; 
  • Erasing will mean we lose our logs of when you made any data protection rights requests; and/or 
  • Erasing will mean we are unable to understand if you have been a member in the past.  

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: 24 February 2025.