This document outlines how Better Brexit processes and manages personal data and:
- Identifies the data controller.
- Explains the lawful basis for processing personal data.
- Outlines the personal data held and processed.
- Outlines the scope of the special category personal data held and processed.
- Outlines the process of Subject Access Requests.
- DATA CONTROLLER
The Data Controller is Voter Consultancy Ltd.
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 contact Voter Consultancy Ltd. by any of the methods set out below.
- LAWFUL BASIS FOR PROCESSING
All processing is carried out by consent, under the legitimate interest of Kanto Systems and/or Voter Consultancy Ltd, or public interest. These cover processing to conduct casework, campaigning and communication. Where processed under the lawful basis of a task carried out in the public interest, it is to support or promote democratic engagement, including fundraising activity in order to support democratic engagement. Processing may also be carried out for one or more of the purposes set out in the following table:
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To deliver our products/services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about products or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
- DATA SOURCES
Data held is that provided by you when you contact us and correspondence with third parties in response to cases taken up on your behalf. The Register of Electors that councils provide to authorised persons under the Representation of the People Act is also used for electoral purposes. You may also provide data to us if you interact with us on social media such as Facebook or Twitter, and in such case, you should consult the privacy terms and options for those services.
- DATA SECURITY
Personal data is stored electronically and securely. We ensure that our service providers comply with the same high standard that we do, and are in the UK.
- SPECIAL CATEGORY DATA
Special category data will be processed under the lawful basis indicated in section 3. In relation processing for a task carried out in the public interest, such processing is permitted under clauses 22, 23 and 24 of schedule 1 of the Data Protection Act, where the client is a political party or elected representatives. For other clients, data will be processed based on consent and/or contractual provisions.
- TRANSFERRING YOUR DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Some service providers are located outside of the European Economic Area (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.
- The transfer is to an organisation that complies with the EU-US Privacy Shield.
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.
- DATA RETENTION POLICY
Personal data will be held for no longer than necessary. Some types of data may be held for longer than others. Typically the maximum retention is two election cycles. Review of the data held will occur in each election cycle to determine whether it should be maintained or put beyond use.
- SUBJECT ACCESS REQUESTS
Subject Access Requests are dealt with in line with the guidance given by the Information Commissioner’s Office (ICO):
- We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
- We will respond within 28 calendar days once we have confirmed it is a legitimate request.
- 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.
- WILL WE SHARE YOUR DATA WITH ANYONE ELSE?
If you have contacted us about a personal or policy issue, your data may be passed on to a third-party in the course of dealing with your enquiry, such as local authorities, government agencies, public bodies, health trusts, regulators, and so on. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the basis upon which they were originally intended.
We only share your data with non-affiliated third parties if required to do so by law.
Data may also be shared with entities of Political Party associations, federations, branches, groups and affiliates in order to assist you or maintain contact with you in support of democratic engagement, where they are affiliated with our client who is the data controller.
Your personal data is only used as outlined here and within your reasonable expectations based on the nature of the communication, and recognising the need for politically related engagement in wider support of democratic engagement.
Cookies are small text files placed on your device when you visit our website. They allow us to make the website easier to use, to provide you with a more personalised experience, to guard against malicious activities and to ensure any login feature functions correctly. They do not collect personal information about you.
You can remove or block cookies by changing the settings in your browser, but the functionality of the website may be adversely affected.
- OTHER WEBSITES
- CUSTOMISED ADVERTISING
We use advertising to show advertisements on various websites as well as advertisements on search engine results pages. This drives traffic to our website but also enables us to show specific advertisements to users who have visited our website. Information about how Google uses personal information for ad personalisation is available here, and you can manage your preferences of advertisement personalisation by following the steps set out here. Information about advertisement preferences on Facebook can be found here, and for Twitter here.
- 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.
- 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 – you also have the right to be subject to the legal effects of automated processing or profiling.
- 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.
- 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 ICO are:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
If you have any questions about the data held please contact our Data Protection Officer:
77 Victoria Street
London SW1H 0HW
Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.
We retain the right to update this policy at any time. If there are changes that significantly impact your rights, we will contact you in advance.