This policy was last updated on 5 April 2022.
The Liberal Democrats (“the Party”) respect individuals’ rights over their personal data. We are committed to ensuring that people are treated fairly in everything we do. This Privacy and Cookie Notice (“Notice”) outlines:
- How we may collect personal data about you, how we may use that data, why we are allowed to use the data in that way
- Who we may share your data with and transferring your data outside of the UK and European Economic Area
- Additional details about cookies and technical information
- Data retention
- Your rights over your personal data
- Contact details
Where this Notice refers to ‘personal data’ it is referring to data about you (or other living people) from which you (or they) could be identified – such as name, date of birth or contact details.
This Notice applies to all personal data processed by the Party about its members, supporters, staff, volunteers, donors, suppliers and professional contacts and members of the public. This includes data gathered via third parties, such as social media sites, and which is therefore also covered by their own Privacy Policies.
How we may collect personal data about you, how we may use that data, why we are allowed to use the data in that way
The Liberal Democrats collect and process personal data from members of the general public, our members, supporters, staff, volunteers and donors.
The Party may collect personal data from you via a variety of means depending on your relationship with the party:
MEMBERS OF THE PUBLIC
- Indirectly from other public records or sources, including the full electoral register which the party is legally entitled to
- Indirectly, via a third-party data broker in order to make predictions about the likelihood that you may be open to the values of the Lib Dems
- Indirectly via a software tool used to predict your first language for producing written materials in other languages
- Indirectly via marked Electoral Registers or the census
Data profiling & data analytics
We may also analyse and make predictions on the data we hold about you. This process is commonly known as data profiling. More information about how we use data profiling can be found here.
MEMBERS AND SUPPORTERS
Any of the above purposes that apply to members of the general public, and in addition
- Digitally when you sign up to be a member/supporter or participate in surveys/petitions online
- 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
- Via WhatsApp/SMS if you are a member of a party WhatsApp/SMS group or if you text us
- Information about attendance at Party events
In addition, we may collect information about you from other public sources, such as the Land Registry and Companies House in order to verify your eligibility to make a donation to us.
Additional information regarding the use of personal data
We only use data from external sources if they are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources.
We may also collect information when you interact with the party’s website and social media pages, this may include additional data to that above, such as:
- Your IP address
- Your device, browser or operating system
- Details of the links that you click and the content that you view
- Your username or social media handle
- Any other information you share when using third party sites (e.g. sending a tweet or using the Like function on Facebook) We may also place one or more cookies on your device. For further details on this, see below.
If you have provided us with your email, mobile phone number or landline phone number and we have a legal basis to use them. We may contact you to promote causes and campaigns that we support, such as by sending you an email, online advert, or a text message.
We will respect any registration you hold with the Telephone Preference Service (TPS) except where you have opted in to receive phone calls on that number from us.
Who we may share your data with and transferring your data outside of the UK and European Economic Area
The Party will not sell your personal data to third parties.
Depending on how and why you provide us with your personal data it may be shared within the Party (i.e. between local, regional and national parts of the party and with our elected representatives) or with companies that provide services to the Party (“service providers”). For more information on service providers, please seelibdems.org.uk/data-sharing./p>
We may use service providers to undertake processing operations on our behalf to provide us with a variety of administrative, statistical, advertising and technical services. We will only supply service providers with the minimum amount of personal data they need to fulfil the services we request. We oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, protecting your personal data including not using it for any purpose other than providing us with an agreed service or fulfilling their legal obligations – and their commitments to assisting us to help you exercise your rights as a data subject.
With your consent, service providers may hold personal data about you in order to facilitate the provision of future services or financial transactions to which you have agreed, such as a payment processor retaining your payment details in order to process agreed future payments from you.
Please note that some of our service providers are based outside of the UK and the European Economic Area (the “EEA”). Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld – in almost all cases we do this by ensuring that the agreements between us and our chosen service providers contain what are called the ‘model clauses’ that oblige them to treat your personal data as if they themselves were based in the UK or the EEA.
In addition, we may share your personal data with third parties when we are required to do so by law (for example, with the Police where they ask us to assist them with their investigations).
In particular, the Party and our candidates are required to submit records, including personal data, of donations above certain thresholds to the relevant regulatory authority. In some cases, some of these donation details are made public. For more details about this, please contact us.
However, save for the limited circumstances noted above, we will never pass your personal data to any unrelated third parties unless you have given us your permission to do so. For example, where you have signed a petition and are clearly informed that this petition will be presented to a third party.
Why the Party is allowed to use your data in this way
Access to the full Electoral Register
As a registered national political party in the UK, The Liberal Democrats is entitled to a copy of the full Electoral Register under the Representation of the People Regulations 2001. The full Electoral Register is different to the open Electoral Register as it contains details of all voters in the UK, including those who have opted out of the open register. We do contact voters outside of election periods, however, we will honour Opt Outs for this type of communication upon request. During Parliamentary election periods, we are also permitted to send 1 Freepost mailing to all voters under Section 91 of the Representation of the People Act 1983.
Legal basis for processing your data
The UK GDPR and Data Protection Act 2018 provides a list of reasons that an organisation may use to permit them to process personal data. These reasons are known as ‘Legal Basis.’ Please refer to the tables above which give the details on our legal basis for processing your data.
You do have rights to ask us to stop processing your data for these purposes, and you can read details about those rights here. In addition to the above, we may also process your data for other purposes where you ask us to, or enter into a relationship with us that requires us to.
For example, if you choose to join us as a volunteer we will need to process your personal data to record that you have given us your support in this way. A contract will be put in place between you and us and we will process your personal data to the extent that we need to in order to fulfil our obligations under that contract.
Similarly, you may from time to time give us your consent to send you communications by email (or similar mediums) which promote our work. Where you do that we will use your details to send you those kinds of communications until you tell us otherwise. Should you ever ask us to stop sending those kinds of communications we will hold your details on file to ensure that we respect that request – we justify that retention on the basis that we have a legal obligation in holding your data in that way.
We will only hold data about you if we have a legal basis for doing so. If we find that we no longer need your data for the purpose it was acquired, or we can no longer establish a legal basis for holding your data we will delete it as soon as possible.
Additional details about cookies and technical information
A cookie is a small text file placed on your device when you visit a website. You can accept or decline cookies through your browser settings or other software. For more information about cookies, see Information Commissioner’s Office’s Cookies Information
When you visit one of our websites, we may place one or more cookies on your device. These are for purposes which include:
- Improving your experience of visiting the site, including providing personalised content Gathering information you have submitted via the site
- Processing requests for information or action that you have made through the site
- Processing login requests
- Enabling your activity in one place to be used to decide on what information, if any, to present to you in other places
- Gathered statistical information about the usage of the site
- Ensuring the smooth operation of online services
- Remembering whether or not you have been shown a cookie notification message on an earlier visit to the site
- To make sure online adverts you may receive from us are relevant to your interests.
We also provide options to share content on social media which may result in your being directed to the social media network’s own systems. If you proceed with this, those networks may gather personal data about you in line with their own privacy policies. On our websites or in other digital communications we may also use technologies variously described as web beacons, pixel tags, clear gifs or tracking pixels to provide us with information about how people have navigated through the site or responded to the communication.
The Party takes the protection of your information very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the information provided to the Party is stored securely once we receive it. People working or volunteering on behalf of the Party only have access to the information they need, and the web servers are stored in a high-security environment that is kept under 24-hour guard. The Party may store your personal data on secure servers either on our premises or in third-party data centres.
Click on the following link to learn more about our Cookies Policy and see a list of cookies used on this website.
We only keep your personal data for as long as required to meet the purposes set out in this Notice, unless a longer retention period is required by law. Where we collect and hold your details as part of our public task work, this may also include retaining those details for as long as you remain a registered voter in the UK.
Where permitted by law, we may also save personal data for archiving purposes in the public interest, including historical research. This may involve passing such data to third parties who run historical archives. For further information on what we consider for archiving under historical importance, please contact firstname.lastname@example.org or write to us: Liberal Democrats, 1 Vincent Square, London, SW1P 2PN
In addition to the retention periods set out in this Notice, we have a Retention Schedule which is available by contacting us by email or post. All of the above is subject to your legal rights, such as to have data in certain cases deleted or corrected, as set out below.
Your rights over your personal data
You have legal rights over any of your personal data that we hold.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (sometimes called a subject access request).
This right entitles you to receive a copy of the personal data that we hold about you. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (sometimes called the right to be forgotten).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is accurate. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
Right to Restrict Processing
Where we process your personal data on the legal basis of us having a legitimate interest to do so, you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify its accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
If for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
You have the right to object to the Liberal Democrats processing your personal data. You have the absolute right to object to the processing of your personal data for direct marketing purposes.
Right to Object
You also have the right to object to personal data we process under the lawful basis of ‘Public Task’ or ‘Legitimate Interests’ (see our table of Legal Basis for more information). However, this right is not absolute. If you want to object to your data being processed under the lawful basis of ‘Public Task’ or ‘Legitimate Interests’ you must give specific reasons why you are objecting to the processing of your data. These reasons should be based upon a specific situation.
We can refuse to comply with your request if:
- We can demonstrate compelling legitimate grounds for the processing,
- The processing is for the establishment, exercise or defence of legal claims.
If we are satisfied that we do not need to comply with the request, we will let you know.
Right to Opt Out of processing relating to your political opinions
You may, at any time, write to us to ask us to cease processing your personal data which relates to your political opinions (such as how you have voted in the past, and things that you have told us about how you are likely to vote).
Please note that these requests can only be made about data which relates to your political opinions; they will not affect our right to use other aspects of your personal data.
Right to Object to automated decision making, including profiling
You have the right to object and Opt Out of automated decision making and profiling at any time.
Right to stop receiving communications
While all of our direct marketing communications contain details of how you can stop receiving them in the future you can either follow those instructions (such as using the unsubscribe link in an email or telling a telephone caller), visit libdems.org.uk/optout, or ask us directly using the contact details below. If you do the latter, please provide us with full details of the telephone numbers, postal addresses, email addresses and so on to which you wish us to stop sending communications to in order to help us deal with your request quickly and accurately.
1 Vincent Square
We will process any requests to stop receiving communications as quickly and comprehensively as is practical although there may in some cases be further communications already on their way to you which cannot be stopped.
If you ask us to stop sending you information (e.g. by email, post, phone or SMS text), we may keep a record of your information to make sure we do not contact you again, up until the normal retention period for that type of data. See our retention information above for details.
Please note that this right to stop communications does not apply to emails that we send to you that are a necessary part of us providing a service to you (such as messaging you about your status as a member or a volunteer) or us notifying you about how your personal data is being used.
In addition, the right to stop communications does not apply to the Election Address that we are permitted to send to you during certain elections.
If you provide us with your email address and indicate that we may do so (e.g. by subscribing to an email distribution list or by ‘opting in’ through the membership page) we may send you further information about the Party in the future. These communications will take the form of emails promoting us and our work.
You can request that you cease to receive these kinds of communications from us at any time. The easiest way to do so is to use the unsubscribe link provided at the bottom of any e-mail messages that we send to you. You can also do so at any time by visiting libdems.org.uk/optout. It may take up to a month for requests submitted this way to become effective on our systems.
If you provide your mobile phone number, we may call or send you text messages if you have given us permission to do so. You may request to stop receiving SMS messages at any point.
You can stop receiving SMS text messages by following the instructions to opt-out provided within that text message. You can also do so by at any time by visiting libdems.org.uk/optout. It may take several days for requests submitted this way to become effective on our systems.
Post and telephone
We may contact you by post or telephone using the information provided to us through the electoral roll and other legitimate sources of contact information for the purposes of campaigning, notifying you of our values and policies, and checking your eligibility to donate.
We will respect any registration you hold with the Telephone Preference Service except where you have opted in to receive communications from us. Further, even if you are not on the Telephone Preference Service register you may ask us to stop making calls to you by telling one of our operators when we call you.
If you provide us with your email address or telephone number we may use it to ensure online adverts you receive from us are relevant to you. These communications will take the form of online adverts promoting us and our work.
You can opt-out of online advertising at any time by visiting libdems.org.uk/optout. It may take several days for requests submitted this way to become effective on our systems. We will have to share your data with relevant service providers. You may still receive online advertising from time to time where providers are unable to remove you from lists or their systems do not permit exclusion lists.
Exercising your rights
You may exercise any of these rights by contacting us using the details below and providing the necessary details for us to be able to identify the relevant data and to act on your request accurately.
When you contact us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can process the request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
The Liberal Democrats appointed a Data Protection Officer (DPO). The DPO is responsible for overseeing the data protection standards within the party and making recommendations where necessary. The DPO reports to the CEO, Senior Management Team on a regular basis and Federal Party Audit and Scrutiny Committee every 6 months. The DPO reports to the Federal Party Board through the CEO.
If you have any queries regarding the information set out here, if you wish to exercise any of your rights set out above or if you think that it has not been followed, please contact:
1 Vincent Square
You can also use these contact details, marked for the attention of the DPO, if you wish to lodge a formal complaint about any matter covered here.
Changes to the Privacy Notice
This policy was last updated on 5 April 2022. Any updates will be posted to this version of the policy. If you wish to see a previous version of the policy, or have any other questions, email email@example.com
This policy will be reviewed at a minimum time period of once every six months.