This privacy notice relates to the personal data processed by Harwich & North Essex Conservative Association (HNECA). The Association is Registered Data Controller with the Information Commissioner’s Office (ICO) under the registration number Z1365421.
1. Who is the Data Controller?
The Data Controller is Harwich & North Essex Conservative Association.
2. Contact
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, please contact:
Write to - HNECA, Unit C2 East Gores Farm, Salmons Lane, Colchester, CO6 1RZ
E-mail - NorthEssex@conservatives.team
3. Lawful basis for processing
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.
4. Data sources
Data held is that provided by you when you contact us and via third parties. 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):
ï When data is shared with us from the wider Conservative Party;
ï Indirectly from publicly accessible sources or other public records, including the full electoral register to which the Party is legally entitled under the Representation of the People Act;
ï 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.
5. Data Security
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.
6. Special category data
Special category data will be processed under the lawful basis indicated in section 3, as is permitted in clauses 22, 23 and 24 of schedule 1 of the Data Protection Act, covering political parties and elected representatives.
7. Transferring your data outside of the European Economic Area
The EU GDPR adequacy decision means that data can continue to flow between the UK and the European Economic Area (EEA). Some service providers are located outside of the EEA and therefore it may be necessary to transfer your personal data outside of the EEA. Where the transfer of your data outside of the EEA takes place we will make sure that it is protected in the same way as if the data was inside the EEA, and it only occurs with your consent.
We will use one of the following safeguards to ensure this:
- Where the European Commission has issued an adequacy decision determining that a non-EEA country or organisation ensures an adequate level of data protection.
- A contract is put in place with the recipient of the data obliging them to protect the data to the same standards as the EEA.
Legally it is not permitted to transfer certain types of data, such as Electoral Register Data, outside of the EEA, and we honour that obligation.
8. Data retention policy
Personal data will be held for no longer than necessary. Some types of data may be held for longer than others.
9. Subject Access Requests
We will request verification of the identity of any individual making a request, ask for further clarification and details if needed and respond within one calendar month once we have confirmed it is a legitimate request. In accordance with ICO guidelines, we keep a log of Subject Access Requests that contains details of the request, including that which can identify you personally, indefinitely.
Data subjects have the right to the following:
- To be told whether any personal data is being processed;
- To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people;
- To be given a copy of the information comprising the data, and given details of the source of the data where this is available.
10. Will we share your data with anyone else?
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.
11. Data Rights
At any point you have the following rights:
- Right of access – You have the right to request a copy of the information held about you.
- Right of rectification – You have a right to correct data held about you that is inaccurate or incomplete.
- Right to be forgotten – In certain circumstances you can ask for the data held 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 object – You have the right to object to certain types of processing, such as direct marketing.
- Right to object to automated processing, 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.
- Right to judicial review: If our office refuses your request under rights of access, we will provide you with a reason why. You have the right to complain.
12. 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
Website - https://ico.org.uk/concerns/
Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.
This website itself is supported technically by Bluetree Website Services, who share a Privacy Policy with the Conservatives that can be found at: www.conservatives.com/privacy
We retain the right to update this policy at any time.