This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal data. We may update this Policy from time to time without notice to you, so please check it regularly.
The provision of your personal data to us is voluntary. However, without providing us with your personal data, you will be unable to (as appropriate) sign a petition / statement, make a donation or receive updates about the campaign.
- We collect information about you:
(1) When you give it to us DIRECTLY
You may give us your personal data in order to sign a petition, when you share information about a petition from our website on Facebook, Twitter and/or via email, when you contact us by phone, email or post, and/or when you donate money to us.
(2) When you give it to us INDIRECTLY
Your information will also be provided to us when you follow us or otherwise interact with on or via Twitter, when you like and/or join our page on Facebook or interact with us in other ways on or via Facebook.
- What information do we collect?
We may collect, store and use the following kinds of personal data:
(1) We will typically hold your name and contact details, including telephone number and e-mail address. However, we may request other information where it is appropriate and relevant, for example
- Details of your Constituency Labour Party / university Labour Club, Trade Union, and any position(s) you hold in these;
- Whether you wish to sign a petition in a personal or official capacity;
- Your bank details or debit/credit card details (if donating to the campaign);
- Details of your activity within the campaign, for example whether you are prepared to volunteer, submit motions to your Labour Party / Trade Union, and the outcome of any such campaigning activity
(2) any communication preferences you give; and/or
(3) any other information shared with us as per clause 1
- How and why will we use your personal data?
Personal data, however provided to us, will be used for the purposes specified in this Policy or in relevant parts of the website.
We may use your personal information to:
(1) Enable you to participate in the campaign by publicly supporting our statement / petition;
(2) Send you information about our work, campaigns, organisations and any other information, products or services that we provide (this will not be done without your consent);
(3) Provide you with the services, products or information you have requested;
(4) Handle the administration of any donation or other payment you make via credit/debit card, cheque, standing order or BACS transfer;
(5) Collect payments from you and send statements and/or receipts to you;
(6) Conduct research into the impact of our campaigns;
(7) Deal with enquiries and complaints made by or about you relating to the website or us in general;
(8) Make petition submissions to third parties, where you have signed the petition and the third party is a target of the campaign to which the petition relates; and/or
(9) Audit and/or administer our accounts.
- Communications, updates, fundraising
Where you have provided appropriate consent, we will contact you by telephone and e-mail, with targeted communications to let you know about our events and/or activities that we consider may be of particular interest; about the work of Labour 4 Clause 4; and to ask for donations or other support.
- Donations and other payments
- Security of and access to your personal data
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff and volunteers.
- Your rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following rights:
(1) Right to be informed – you have the right to be told how your personal information will be used. This Policy and any other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
(2) Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we have 40 days to comply. As from 25 May 2018, we will have 30 days to comply.
(3) Right of erasure – as from 25 May 2018, you can ask us for your personal information to be deleted from our records.
(4) Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
(5) Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
(6) Right to data portability – to the extent required by the General Data Protection Regulations (“GDPR”) where we are processing your personal information (i) under your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact or (iii) by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
To exercise these rights, please send a description of the personal information in question using the contact details in section 12 below. You can also unsubscribe from our email list by sending an e-mail with the subject “UNSUBSCRIBE” to firstname.lastname@example.org.
Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we reserve the right to ask for (i) personal identification and/or (ii) further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance or please contact us using the details in section 12 below.
You are further entitled to make a complaint about us or the way we have processed your data to the Information Commissioner’s Office (“ICO”). For further information on how to exercise this right, please see the guidance here. The contact details of the ICO can be found here.
- Lawful processing
We are required to have one or more lawful grounds to process your personal information. Only four of these are relevant to us:
- Personal information is processed on the basis of a person’s consent
- Personal information is processed on the basis of a contractual relationship
- Personal information is processed on the basis of legal obligations
- Personal information is processed on the basis of legitimate interests
We will ask for your consent to use your information to send you electronic communications such as newsletters and and fundraising emails, and if you ever share sensitive personal information with us.
(2) Contractual relationships
Most of our interactions with supporters are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you purchase merchandise online.
(3) Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
(4) Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent.
Achieving our purposes
These include (but are not limited to) promoting socialist policies within the Labour Party, including the campaign for the Labour Party to restore the pre-1995 clause 4 part 4.
Publicity and income generation
- Conventional direct marketing and other forms of marketing, publicity or advertisement
- Unsolicited messages, including campaigns, newsletters, and fundraising appeals
- Analysis, targeting and segmentation to develop and promote or strategy and improve communication efficiency
- Personalisation used to tailor and enhance your experience of our communications
- Maintenance of suppression files
- Processing for historical, scientific or statistical purpose
Purely administrative purposes
- Responding to enquiries
- Delivery of requested products or information
- Communications designed to administer existing services including administration of petitions and financial transactions
- Thank you communications and receipts
- Maintaining a supporter database and suppression lists
Financial Management and control
- Processing financial transactions and maintaining financial controls
- Prevention of fraud, misuse of services, or money laundering
- Enforcement of legal claims
- Reporting criminal acts and compliance with law enforcement agencies
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
- Data retention
In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.
In the event that you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
- Policy amendments
- Updating information
You can check the personal data we hold about you, and ask us to update it where necessary, by emailing us at email@example.com.
We are not required by law to have a “Data Protection Officer” – however we have a Data Protection Manager.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by emailing the Data Protection Manager at firstname.lastname@example.org.