Amended GDPR Policy Dated: 17th February 2021
www.jeremyhagon.co.uk – Promoted by Jim Musk on behalf of Jeremy Hagon, all at Unit C2 East Gores Farm, Colchester, CO6 1RZ.
This privacy notice relates to the personal data processed by Colchester Conservative Association (CCA) and Harwich & North Essex Conservative Association (HNECA). The Associations are a Registered Data Controller with the Information Commissioner’s Office (ICO) under registration numbers Z8990515 (CCA) and Z1365421 (HNECA).
Who is the Data Controller?
The Data Controllers are Colchester Conservative Association and Harwich & North Essex Conservative Association.
What information do we collect?
The types of personal information that we may collect about you include:
- Date of birth
- Contact Details (e.g. address, email address, phone number, mobile number)
- Communication Preferences
- Electoral Register Data
- Demographic data
- Opinions on topical issues
- Issues that you raise with us
- Family connections
- Commercially available data
- Publicly available data
We may also collect special categories of information such as:
- Political Opinions
- Voting intentions
How we collect data
We collect data about you in the following ways:
Provided by you (Directly):
- In person, when you speak to one of our representatives or volunteers
- Through a telephone call, either where you call us or we call you
- On paper, such as if you return a printed survey or a reply slip on a leaflet
- Digitally, such as if you interact with the Party online via our website or social media
- When you offer or ask about volunteering, or take part in party activities
- When you enter into a transaction with the Party, such as donating or joining
- When you consent to receiving marketing emails etc
- When you attend a conference or campaign event
Third Party Sources (Indirectly):
- When data is shared with us from the wider Conservative Party
- Indirectly from publicly accessible sources or other public records, including the full electoral register to which the Party is legally entitled
- On social media platforms, where you have made the information public, or you have made the information available in a social media forum run by the Party
We collect data with the intention of using it primarily for political activities.
How we use your information and why we are allowed to use it:
How your data is used is protected by law and we only use your data where we have an acceptable reason for doing so. The reasons we process your data are:
- In pursuit of an activity that supports or promotes democratic engagement (Public Interest), or
- When it is our legal duty (legal obligation), or
- When you provide consent (consent), or
- In order to fulfil a contract with you (contract), or
- When we have a legitimate interest (legitimate interest).
The law restricts the processing of what is termed “special categories of personal data”. The work of the Conservative Party, and the wider Conservative Party, is deemed to be of substantial public interest and therefore we are permitted to process special categories of personal data relating to your political opinions and voting intentions.
Our legitimate interests:
Our objective is to promote our values and to elect Conservative Candidates at every level of government across the Colchester and Harwich & North Essex Parliamentary Constituencies. In order to do this we rely upon the support of our members, donors, volunteers and supporters. We rely on being able to communicate and engage with the Electorate and those eligible to vote.
As a member: If you join CCA or HNECA we have a legitimate interest in processing your data and contacting you about all aspects of your membership including information about your entitlements as a member and about CCA or HNECA events; either by post or by electronic means. CCA and HNECA are run by our members and therefore we have a legitimate interest in member engagement and retention. If you do not renew your membership with CCA or HNECA we will continue to send you information about the Conservative Party, including information on how to rejoin, for a reasonable period after your membership lapses. We also have a legitimate interest to retain your data after your membership lapses, as well as a legal duty to keep a record of the financial transaction.
As a donor: If you donate money to CCA or HNECA then we have a legitimate interest in processing and retaining your information and to send you marketing about our fundraising activities; either by post or by electronic means. We justify this because our activities are funded by donations. For donations over certain thresholds we also have a legal obligation to report it to our regulator, the Electoral Commission, who will publish certain details on their website.
As a volunteer: If you volunteer for CCA or HNECA or enquire about volunteering for the Party, and are not a member, we have a legitimate interest in processing and retaining your information and contacting you about volunteering opportunities. We justify this because of the vital function that volunteers perform both during and outside of elections.
If you attend an event: If you attend one of our events and are not a member of the Party, we have a legitimate interest in retaining your information and to send you marketing about future similar events which we think might be of interest to you; either by post or by electronic means. We have a legitimate interest in inviting people to our events in order to raise vital funds for CCA or HNECA and have determined that attendees would expect to receive such communications from us.
Much of the work of CCA or HNECA is conducted by the wider Conservative Party. For this reason we have a legitimate interest in sharing certain personal information with the wider Party when it is necessary for our campaigns or activities.
Whilst a lot of our political activities are considered to be tasks carried out in the public interest, we also have a legitimate interest to carry out these tasks. We justify this due to our defined objective as a political party.
You will always have the opportunity to opt out of receiving any messages from the CCA or HNECA or to exercise any of your legal rights.
We are committed to respecting your rights over your data and in some circumstances we will have a legitimate interest to continue to process your data even where you have exercised one of your rights. For example if you request that we stop processing your data for purposes of direct marketing then we justify keeping a record of this request in order to ensure that your wishes are respected.
Data Processed with your Consent
Where we use consent as our legal basis for processing your data, or process special categories of your data on the basis of your explicit consent, you have the right to withdraw your consent at any time. This does not affect our right to process your data before you decide to withdraw your consent.
Who we share your data with:
We will never sell your data but sometimes it is necessary to share your information, either within the wider Conservative Party. Data is only ever shared where we have a justification and when the law allows us to do so.
We share data with:
- The wider Conservative Party
- Elected representatives
- Regulatory bodies
Where we share data with the wider Conservative Party we ensure that the recipient of the data agrees that they will use the data only for the purposes for which it was provided and will take necessary measures to ensure its security. Members of the wider Party receive training on data protection.
How we protect your data:
The security of your data is paramount to the Party and as such we ensure that appropriate technical and organisational measures are in place to protect it. We constantly review our measures to ensure that your data is protected from any threats that may emerge.
Your rights over your data
Right of access to your data
You have the right to request a copy of your personal information that we hold. This is commonly known as a Subject Access Request.
We follow the ICO’s “Subject Access Code of Practice” when dealing with requests for access to personal data. You can read this code by visiting https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdf
Right of rectification of your data
You have the right to request that inaccurate or incomplete information that we hold about you is corrected.
Right to be forgotten
In certain circumstances you can ask for the data we hold about you to be erased from our records. When we do so, we keep the bare minimum of your information in order to continue to respect your wishes when your personal data is next provided to us by a local authority, which is at least annually.
Right to restriction of processing
You have the right to request that we restrict the processing of your data where you are contesting the accuracy of the data or when the data has been unlawfully processed.
Right to data portability
You have the right to have the data we hold about you transferred to a third party organisation and you can ask that we provide it in a machine readable format.
Right to object
You have a right to opt out of your data being used for direct marketing.
If we process your data on the basis of “legitimate interests” or “a task carried out in the public interest” then you have the right to object to us using your data in that way. This right is not absolute and we may continue to process your data if we can demonstrate compelling legitimate grounds for the processing.
Automated individual decision-making, including profiling
We may use computer software to make decisions about you or to create a profile about you. You have the right not to be subject to such a decision or to that profiling where it creates legal effects concerning you or where it significantly affects you.
Contacting us about Data Protection:
If you have any questions about this policy or for more information about how we use your data or would like to exercise any of your rights you can contact our Data Protection Officer at:
CCA / HNECA, Unit C2 East Gores Farm, Salmons Lane, Colchester, CO6 1RZ
Phone: 01376 562862
Making a complaint
If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom.
The contact details for the Information Commissioner’s Office are:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Phone: 0303 123 1113