Who we are
Our website address is: http://www.lennyrolles.org.uk.
The below is copied verbatim and owned by the Labour Party and retrieved from taken from https://labour.org.uk/general-electorate-and-donors-privacy-policy/ on 1 February 2024. Sections of this will apply to Lenny Rolles as the Labour Party Candidate for the Kent and Medway Police and Crime Commissioner election and in terms of data gathering and retention.
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:
Members and Supporters
Young Members (including if you are an under 18 member)
Cookie Policy
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 dataprotection@labour.org.uk 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:
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/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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 dataprotection@labour.org.uk
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.
Privacy Notice – for all casework and GBC correspondence and communications (Data Protection, GDPR and other data and information handling)
Introduction
This notice is provided within the context of the changes required by the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA). (This is an interim or draft notice for the moment until confirmed)
This document will therefore be subject to ongoing review to ensure it continues to align with the requirements of all applicable legislation.
Service description
In order for the elected councillors of Gravesham Borough Council (“the council”) to receive and process your request for assistance or respond to your enquiry, it is necessary to collect, store and process personal data necessary to provide you with relevant information, services or support.
What information we hold
In order to provide this service, councillors may need to process some personal information. This will generally include your name, address and contact information together with details of your problem or concern.
It may be necessary to collect what GDPR has classed as special category of data including race or ethnic group, sexuality and sexual life, religious or philosophical beliefs, trade union membership, genetic and biometric data, physical or mental health, as well as criminal convictions.
Where we get your information from
Councillors get your personal information from you, other constituents, groups or members of the public in relation to matters which they have been asked to pursue in the interests of individuals and groups who live in their ward.
How will your personal information be used
Your personal information will be included as part of details of cases of interest, as part of information provided by signatories on petitions, responses to questionnaires and contact details for the purpose of communicating news and updates.
Who we will share your personal information with
If you have contacted your councillor about a personal or policy issue, they may pass your personal data on to a third-party in the course of dealing with your request or query. This could be local authorities, government agencies, public bodies, health trusts and regulators. They may also pass your information to council officers in Gravesham Borough Council, Kent County Council or the Member of Parliament or other such bodies, individuals, charities, or companies including third parties in order to allow them to investigate the matter.
Any third parties with whom councillors may share your data are obliged to keep your details securely, and to only use your data for purposes already communicated to you.
If you specifically ask councillors not to disclose information identifying you to other third parties it is necessary for them to contact, they will try to respect that. However, it must be noted that it may not be possible to progress a matter for you on an anonymous basis.
We will not pass personal details of constituents who contact councillors to anyone else unless required to do so by law or where this is in connection with a criminal investigation.
The councillors will never sell your data. However, they may share some of your personal information with third parties to:
- help prevent fraud. Your information may be shared with credit reference agencies and other companies for use in credit decisions. Credit agencies may record these searches, but that will not affect your credit standing
- pursue people or companies who owe money. Your information may be shared with debt collection agencies
help business partners, suppliers and sub-contractors to deliver any contract the councillors enter with them or you, on your behalf
- help the councillors if they need additional professional or legal advice on a matter relating to you.
- improve and optimise the performance of websites and social media accounts. Analytics and search engine providers that councillors use can collect your data when interacting online. However, they will aggregate and anonymise the information, meaning individuals will not be personally identifiable
- work out if a grant was successful in achieving its aims. This could be funding from a government or a grant from a local, regional or national organisation such as Sport England and National/Heritage Lottery Fund. However, they will aggregate and anonymise the information, meaning individuals will not be personally identifiable
The lawful basis for collecting and processing your information
Councillors may use your information in dealing with your requests when you ask them to pursue a matter on your behalf. Local authorities’ councillors can process your personal information to carry out tasks under the lawful bases of ‘legitimate interests’ basis and/or ‘consent’ (Article 6 of GDPR).
The legal bases relied on for processing personal information in relation to responding to requests from constituents are:
-consent or explicit consent of the constituent making the request (or any other relevant persons where this is appropriate)
necessary in pursuit of the councillor’s legitimate interests as an elected representative and those of their constituents; and it is assessed these interests override any privacy intrusion involved in processing personal data about other individuals
-discharging functions as an elected representative for the purpose of responding to requests from constituents where this is permissible, without explicit consent
Additional lawful basis for processing other categories of data
Some of the information that is collected is classified as special category personal data or personal data consisting of criminal convictions and offences (including alleged offences).
In order to process special category of data, the councillors needs to have an additional lawful basis to above. In this instance, special category of data is processed for exercising specific rights of the council under the Data Protection (Processing of Sensitive Personal Data) (Elected Representatives) Order 2002.
Where the council collects and process criminal convictions information, it is done lawfully under the provisions of the Data Protection Act 2018 (DPA)2[2]. (The DPA 2018 – Part 2, paragraph 5, 1 and 2 and paragraph 6, 1and 2 – supplements the GDPR by providing the legal basis for processing criminal convictions and offences. In the Council’s case, as a ‘public authority’ and when it is in the public interest to do so).
If you provided personal information about someone other than yourself, we may need to check the facts with that other person. If you ask the councillors to take action on behalf of a friend or relative, they may need to contact that person to confirm that they are happy for them to act on their behalf. If you feel it would not be appropriate for the councillors to contact the other person, you should discuss this at the point of giving this other person’s information.
Ward news and events
Your local councillor would like to send you information about ward news and events, but they will not use your contact details to do this unless you have said that you would like to be sent this information.
If you have said that you would like this information, but later change your mind, you have a right at any time to let us know if you no longer wish to be sent this information.
If you wish to receive or stop receiving this information, please contact your local councillor.
How long do we keep your personal information
We will process your personal data until your matter has been resolved and will store electronic data and paper records for a period of 3 years or 6 months after your complaint has been finalised.
This is to allow your councillor to build up case history and to return to your records should further matters arise.
Your rights
The Data Protection Act 2018 in conjunction with the General Data Protection Regulation (GDPR) grant you a number of rights including the right to:
- ask us to provide you with copies of personal information we hold about you at any time, known as a Subject Access Request
- object to the use of your personal information for certain type of processing, such as direct marketing or automated processing, including profiling
- ask us to delete, update and correct any out-of-date or incorrect personal information that we hold about you free of charge
- opt-out at any time where you have given consent and to have your data erased where you have given consent
- You are entitled to receive a copy of your records free of charge and within a month. For more information on how we process your personal information and how to make a subject access request, please contact the councillor directly.
In certain circumstances access to your records may be limited, for example, if the records you have asked for contain information relating to another person.
If you wish to exercise any of these rights, you should contact the councillor using the contact details provided above.
You have the right to be told if we have made a mistake whilst processing your data and we will self-report breaches to the Information Commissioner.
Further information
If you would like to know more about how we use your information, please contact the councillor directly.
Complaints
You also have the right to complain to the Information Commissioner’s Office, at:
The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone number: 0303 123 1113 or 01625 545745
(based on Medway Council page and used/edited under permission under the Shared Service arrangement)
Contains public sector information licensed under the Open Government Licence v3.0.