Last updated: 29.05.2019
- Overview and Data Controller
Ed Davey MP for Kingston & Surbiton is the controller of your personal data collected through this Website, and when we contact you about his Campaign for the position of leader of the Liberal Democrats. Ed Davey MP employs staff in his Parliamentary Office to collect and process data on his behalf, henceforth known as (“the Office”, “we”, “us” or “our”).
Ed Davey MP is a member of the Liberal Democrats (“Liberal Democrats”) and is running for leadership of that party, as part of that process we intend to reach out to members of the Liberal Democrats letting them know about his vision for the party’s future (the “Campaign”).
• when you access and visit: edforleader.org (the “Website”);
• when we contact you about the Campaign, including, without limitation, by telephone, mail or online; or
• when we otherwise promote the Campaign.
- Overview and Data Controller
- What information can we collect?
- How is your personal data collected?
- How and why do we use and share your personal data?
- For how long do we keep your personal data?
- International Data Transfers
- Your Rights
- Contact Details
This Website is not intended for children and we do not knowingly collect data relating to children.
3. What information can we collect?
What is personal data?
What types of data we collect from you when you use the Website?
The personal data we collect from you may include:
- Identity Data which includes your full name.
- Contact Data which includes your phone number, e-mail address and postal address.
- Financial Data which includes your bank account and payment card details.
- Transaction Data which includes details about any donations from you, for example, the amount donated.
- Technical Data which includes your IP address, your login data and browser type and version.
- Usage Data which includes information about how you use the Website.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties.
4. How is your personal data collected?
Information you give to us
When you use the Website to: make a donation, request campaign materials be sent to you, participate in social media functions, contact us by email or by post, complete a webform, post a comment, provide us with your contact information or report a problem with the Website, we may collect, store and use the personal data that you disclose to us.
When we contact you by phone, post or online we may also collect, store and use the personal data you disclose to us during such communications. For example, where you make a donation over the phone, we will collect store and use your Financial Data to process that donation.
It is important that the personal data we hold about you is accurate and current. If you want to update the information you have previously given to us, please contact us.
Automated technologies or interactions
Each time you use our Website we will automatically collect your personal data including Technical Data and Usage Data. We collect this data using technologies such as cookies or other similar tracking technologies.
We use this personal data for several different reasons. Firstly, we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor aggregate online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.
Please refer to our Cookies Policy for further details.
Third parties or publicly available sources
We may also receive personal data about you from various third parties, and public sources, such as: analytics providers, advertising networks and search information providers.
5. How and why do we use and/or share your personal data?
Lawful basis for processing your information
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
● Where you have asked us to do so, or consented to us doing so;
● Where we need to do so in order to perform a contract, we have entered into with you;
● Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; or
● Where we need to comply with a legal or regulatory obligation.
Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.
Activity Examples of the types of personal data we may collect Lawful basis for processing
To process your donation, including managing your payments Identity Data, Financial Data and Transaction Data Your consent
Necessary for our legitimate interests (to keep records updated and to analyse how you use the Website)
Necessary to comply with legal obligations (to inform you of any changes to the Website terms and conditions)
To contact you by telephone or send you mail. Identity Data, Contact Data and Marketing and Communications Data Necessary for our legitimate interests (to develop the Campaign)
|Activity||Examples of the types of personal data we may collect||Lawful basis for processing|
|To process your donation, including managing your payments||Identity Data, Financial Data and Transaction Data||Your consent|
|To contact you by telephone or send you mail.||Identity Data, Contact Data and Marketing and Communications Data||Necessary for our legitimate interests (to develop the Campaign)|
|To send you E-mail Marketing (as defined below)||Identity Data and Contact Data||Your consent|
|To send you Online Marketing (as defined below), including sending you personalised content via third party websites.||Identity Data, Contact Data, Usage Data and Technical Data||Necessary for our legitimate interests (to develop the Campaign)|
|To administer and protect the Campaign and this Website (including troubleshooting, data analysis and system testing)||Identity Data, Contact Data and Technical Data||Necessary for our legitimate interests (for running the Campaign, provision of administration and IT services, network security)|
|To use data analytics to improve the Website||Technical Data and Usage Data||Necessary for our legitimate interests (to develop the Campaign)|
We may use your personal data to send you electronic mail marketing communications (“E-mail Marketing”) about the Campaign.
You will only receive E-mail Marketing from us if you have provided us with your consent. In most cases we will have obtained your consent in one of the following ways:
• by telephone, when we call you to tell you about the Campaign (during any such call we will make it clear to you that you are being asked to provide your e-mail for the purpose of enabling us to send you E-mail Marketing before you give your e-mail address to us); or
• when you complet a form online in which you subscribe to receive E-mail Marketing from us.
In the event that we ever wish to provide your data to a third party – we will obtain your express opt-in consent before providing your personal data to any third party for its own marketing purposes.
Opting Out of Marketing
To unsubscribe from receiving E-mail Marketing, please click on the unsubscribe link that will feature at the bottom of any marketing email you receive, or contact us directly and let us know that you no longer wish to receive E-mail Marketing.
We may use your personal data to provide you with online marketing which relates to the Campaign (“Online Marketing”). Online Marketing includes all forms of online marketing (other than E-mail Marketing), for example, sending/displaying personalised content via your social media accounts reminding you of, and encouraging you to support, the Campaign.
We rely on our legitimate interest of developing and promoting the Campaign to process your personal data for the purpose of sending you Online Marketing.
Although we do not rely on your consent to process this personal data, you will most likely receive Online Marketing where you have provided us with you e-mail address and given your consent for us to send you E-mail Marketing. Where we collect your e-mail address for the purposes of sending E-mail Marketing to you, we will also make clear that it is likely to be used for the purposes of helping to target Online Marketing.
However, where you are a member of the Liberal Democrats, we may also send/target Online Marketing using other personal data we have been provided with, such as your postcode.
Telephone and Mail Marketing
Where you are a member of the Liberal Democrats, we are likely to be provided with, and granted permission to use, your name, telephone number and postal address so that we can contact you to remind you of your right to vote for a new leader of the Liberal Democrats and to promote the Campaign. We may therefore call you to speak about the Campaign, or send you post about the Campaign.
Where you are not a member of the Liberal Democrats, but have offered your personal data to us online, such as your postal address or your telephone number, we may also contact you by telephone or mail in the same fashion.
We rely on our legitimate interest of developing and promoting the Campaign to process your personal data for the purpose of contacting you in this way.
Sharing your personal data
Depending on how and why you provide us with your personal data we may share it in the following ways:
• with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below) and
• with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.
We may also disclose your personal data to third parties in the following events:
• if we were to incorporate a company for the purpose of carrying out the Campaign, in which case we would disclose your personal data to that company;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly sets out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of the categories or service providers we use:
• Analytical providers;
• Payment processors; and
• Website developers and hosts.
Links to third-party sites
6. For how long do we keep your personal data?
We will hold your personal data on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
The Office takes the protection of your information very seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords. Where we have given you a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. International Data Transfers
Although we do not think it is likely that we will be required to transfer your personal data outside of the European Economic Area (“EEA”), whenever we do transfer your personal data outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• Where we use certain service providers, we may use specific contracts approved by the European Commission which gives personal data the same protection it has in Europe; or
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
By submitting your personal data, you agree to the terms of such transfers. If you would like more information about how the mechanism via which your personal data is transferred, please contact us.
9. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. 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.
You can exercise this right at any time by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your 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 (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to me, and we may take our own steps to check that the new data you have supplied us with is right. 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.
You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
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 that data’s 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.
Please note that 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.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your 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.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party, we are happy to consider such requests.
Your Right to object to processing
You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by contacting us and telling us which communications you would like us to stop sending you.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to 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 us to 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 deal with your 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).
10. Contact Details
You may also lodge a complaint with our lead supervisory authority, the Information Commissioner, or your local supervisory authority about any aspect of our handling or processing of your personal data. We would, however, appreciate the chance to address your concerns before you approach any supervisory authority, so please contact us in the first instance.