- Contacting us about data protection
- What data do we collect?
- The purposes for which we process individuals’ personal data
- How we collect data
- How we use your data and why we are allowed to use it
- Our legitimate interests
- Data processed with your consent
- Who we share your data with
- How long we retain your data for
- How we protect your data
- Your rights over your data
- Making a complaint
- Changes to this policy
The provision of your personal data to us is voluntary. However, without providing us with your personal data, your use of our services or your interaction with us may be restricted. For example, you would not be able to donate to, or volunteer for, RSLC.
The purpose of the RSLC is to persuade individuals to support Rory Stewart in his bid to become prime minister.
RSLC is not responsible for the data privacy practices of other websites which are linked to the RSLC website.
2. 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 (such as to withdraw consent to electronic direct marketing) you can contact email@example.com or call 07929 873234. Alternatively, please use campaign office address: Rory Stewart Leadership Campaign, 602, 50 Broadway, London, SW1H 0RG.
3. What information do we collect?
The types of personal data that we may collect about you include:
- Date of birth
- Contact Details (e.g. address, email address, telephone number, mobile number, social media)
- Communication Preferences
- Direct Marketing Preferences (e.g. interest in the progress of Mr Stewart’s campaign or preparedness to donate)
- Electoral Register Data
- Demographic data
- Financial transaction data
- Opinions on topical issues
- Issues that you raise with us
- Family connections
- IP address, cookies and other technical information that you may share when you interact with our website
- Commercially available data – such as consumer, lifestyle, household and behavioural data
- Publicly available data
We may also collect special categories of information, only where it is lawful under data protection law, such as:
- Political Opinions
- Voting intentions
- Reasons for individuals’ support of Mr Stewart
- The type of volunteer work individuals are interested in
- Details of an individual’s organisation and his or her role there
4. The purposes for which we process individuals’ personal data
- providing individuals with services, products or information requested
- providing further information about RSLC’s work and activities (only where they have provided consent if this amounts to electronic direct marketing)
- to answer individuals’ questions/ communicate with them in general
- to process individuals’ donations
- to allow individuals to volunteer for RSLC; and
- to satisfy applicable legal/ regulatory obligations.
5. 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
- When you offer or ask about volunteering, or take part in party activities
- When you enter into a transaction with the Rory Stewart Leadership Campaign, such as donating or joining.
- When you consent to receiving marketing emails etc
Third Party Sources (Indirectly):
- Indirectly from publicly accessible sources or other public records
- 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 Rory Stewart Leadership Campaign.
- From commercial organisations with whom we have a contract guaranteeing full data protection compliance.
The Rory Stewart Leadership Campaign collects data with the intention of using it primarily for political activities.
The Rory Stewart Leadership Campaign uses the data that we collect about you in order to build a picture of you. We use automated means to analyse this variety of data and collate it (sometimes referred to as “profiling”). For example we may combine electoral register data, commercially available modelled consumer data and publicly available data from the land registry in order to make a prediction about your lifestyle and habits. We do this in order to:
- understand the matters and issues that are likely to be of relevance and significance to you and better inform our future policies if our predictions are incorrect,
- decide whether we send you our campaigning materials,
- select what campaigning material we send to you and which messages we put on it,
- evaluate whether we think you are likely to vote and for whom you will likely vote for during an election or a referendum,
We have determined that this kind of automation and profiling does not create legal or significant effects for you. Nor does it affect the legal rights that you have over your data.
6. How we use your data 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:
- When it is our legal duty (legal obligation) e.g. to submit relevant individuals’ names to the Register of Members’ Financial Interests if they donate over £1,500; or
- When you provide consent (consent) e.g. to send email updates about the progress of the campaign or email requests for donations; or
- In order to fulfil a contract with you (contract) e.g. in relation to volunteering activities.
- In case of vital interests (vital interest) e.g. in case of a medical emergency suffered by an individual on the campaign trail.
The table below lists examples of how we use your data and our justification and legal basis for it.
7. Our legitimate interests
GDPR allows RSLC to collect and process individuals’ personal data if necessary to achieve RSLC’s or a third party’s legitimate interests.
Our legitimate interests to encourage Conservative Party MPs and Members to support Mr Stewart’s bid to become leader of the Conservative Party and Prime Minister.
Where RSLC processes personal data in reliance on legitimate interests, we consider and balance any potential impact on individuals and their rights under data privacy law, and will not process personal data in reliance on this lawful basis where relevant legitimate interests are overridden by the impact on relevant individuals.
In order to achieve our legimitate interests we rely upon the support of our members, donors, volunteers and supporters.
As a donor: If you donate money to the Rory Stewart Leadership Campaign then we have a legitimate interest in processing and retaining your data 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 the Registrar.
You will always have the opportunity to opt out of receiving any messages from the Rory Stewart Leadership Campaign 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.
8. 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.
9. Who we share your data with
Data collected by the RSLC will be shared with the Conservative Party.
We will never sell your data but sometimes it is necessary to share your data, either with the Conservative Party, or with our service providers and data processors. 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
- Other MPs (where individuals write to their MPs asking them to support Mr Stewart’s campaign)
- The Register of Members’ Financial Interest
- Business associates and professional advisers
- Service providers e.g. website and social media providers such as Nation Builder and Atalanta.
- Financial organisations – such as credit card payment providers
- Political organisations
- Elected representatives
- Regulatory bodies
- Market researchers
- Healthcare and welfare organisations
- Law enforcement agencies
Where we use a service provider to process your data on our behalf we will ensure that this processing is governed by a legally enforceable contract which sets out their responsibilities for protecting your data and your rights.
Where we share data with the wider Conservative Party we ensure that the recipient of the data signs an undertaking 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.
10. How long we retain your data for
We constantly review the data that we hold and regularly review its relevance and our need to hold onto it. We use several factors to determine whether we need to hold onto the data. Factors we take into consideration are:
- Retention periods as required by law
- The purpose for which the data was provided or obtained,
- Our legitimate interests in holding onto your data,
- Whether holding onto your data will infringe your rights over your data,
- Legal and regulatory obligations that may require reference to your data
However, in general, RSLC retains personal data for 6 years from collection unless it is still required in relation to the purpose for which it was collected; or, if before that date the underlying purpose or lawful basis is no longer valid, or if an individual validly exercises his or her right of erasure, the personal data will be securely deleted at that point.
Log Files and Statistics
12. How we protect your data
The security of your data is paramount to the Rory Stewart Leadership Campaign 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.
13. Your rights over your data
Right of access to your data
You have the right to request a copy of your personal data 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 data 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.
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.
14. 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
- Telephone: 0303 123 1113
- Website: https://ico.org.uk/concerns/
15. Changes to this Policy
RSLC may update the Policy from time to time, and will contact individuals directly where reasonable to do so about such updates and by placing an updated notice on its website.