PRIVACY POLICY AND COOKIE NOTICE

This policy was last updated on Thursday 17 May 2018. Any updates will be posted to this version of the policy.

INTRODUCTION

The Liberal Democrat Friends of Palestine (“LDFP”) 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 your personal data
  • Why the LDFP is allowed to use your information in this way
  • The circumstances under which we may share your personal data or disclose it to others
  • Additional details about cookies and technical information
  • Data retention policies
  • Your rights over personal data
  • How to contact us

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. And where “the Party” is referenced it refers to the Liberal Democrats.

This Notice applies to all personal data processed by the LDFP about its members 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.

LDFP MAY COLLECT PERSONAL DATA FROM YOU VIA MEANS SUCH AS:

  • 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 fill in a form on a website or interact with LDFP online
  • When you offer or ask about volunteering, or take part in party activities
  • When you enter into a transaction with LDFP, such as donating, joining, purchasing a product or paying for an event
  • Indirectly from other public records or sources, including the full electoral register, through our relationship with the Party, who are legally entitled to access it
  • 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 LDFP

We may collect personal data about you such as:

  • Name
  • Contact details (e.g. email address, address, telephone / mobile number)
  • Date of birth
  • Future communication preferences
  • Information about your financial transactions with the Party
  • Racial or ethnic origin
  • Family details
  • Political opinions
  • Religious or other beliefs
  • Other demographic information
  • Information about your home (e.g. whether it is a flat or house)
  • Issues you raise
  • Topics you are interested in

We may also collect information when you interact with LDFP digitally, such as by visiting our website or communicating with one of our social media channels. 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 collect information about you from other public sources, such as the Land Registry, Companies House or other commercially available sources. We only do so where those sources are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources. This may include, for example, checking the eligibility of a potential donor and may include additional data to that above, such as:
  • Lifestyle and social circumstance
  • Goods or services purchased
  • Charities you support

HOW WE MAY USE YOUR PERSONAL DATA

We may use your personal data to further our objectives, share it with Liberal Democrat elected representatives and/or contact you in future. Examples of the way we may use your data include to:

  • Contact you to canvass for political support
  • Understand your views and issues important to you
  • Process surveys you have participated in
  • Tell you about policies, campaigns or individuals that may be of interest to you
  • Respond to queries that you raise with us
  • Administer offers or applications to volunteer for LDFP or to become, remain or cease being a member of or candidate of the Liberal Democrats
  • Conduct fundraising activities, including checking your eligibility to donate
  • Manage our sites and services

For more specific information about how we use your data for these activities, and the legal basis on which we rely to process your data in this way, please see the ‘Why LDFP is allowed to use your information in this way’ section of this Notice.

If you have provided us with your email, mobile phone number or landline phone number and we have a legal right to use them for such purposes, we may use that information to 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.

You may opt out of communications from us at any time – simply click on an unsubscribe link in an email from us to stop receiving them, email info@LDFP.org and we will remove you from all of our communications.

Depending on how and why you provide us with your personal data it may be shared within the Liberal Democrats (i.e. between local, regional and national parts of the Party and with the Party’s elected representatives) or with companies that provide services to LDFP (“service providers”).

The main service providers that we may share your personal data with is our email provider Mail Chimp.

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).

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 LDFP IS ALLOWED TO USE YOUR INFORMATION IN THIS WAY

The Liberal Democrats are a registered national political party in the UK; whose work is designed to promote its values and to engage UK citizens in the democratic process.

LDFP is an Associated Organisation (AO) of the Liberal Democrats. AOs are groups of party members that share, or support, a particular identity and are approved by the Liberal Democrat’s Federal Board.

Accordingly, the Party and LDFP’s work is considered to be of substantial public interest. Because of that public interest basis, the Party and LDFP are entitled to process sensitive personal data which relates to your political opinions, and your personal data more generally, for the purposes of enabling us to perform our work effectively. Specifically, that processing may include using those aspects of your personal data to help us to plan and execute political campaigns, canvass for your support (such as by visiting or calling you), raise funds, and perform casework that relates to you and your local community.

You do have rights to ask us to stop processing your data for these purposes. 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 e-mail (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 legitimate interest in holding your data in that way.

Finally, where we have received your personal data in the various ways described above, we may continue to hold it as part of our records after the relevant processing has stopped. We hold data in this way because we have a legitimate interest in doing so. Specifically, where you have been a member or a volunteer (or have otherwise engaged with us such as by attending a conference or event, or by responding to a survey or questionnaire) we have a legitimate interest in holding your personal data to help us to monitor the numbers and the diversity of people who engage with us, as well as a legitimate interest in making sure that we can follow up any complaints or grievances which you may raise (or which people may raise about you).

THE CIRCUMSTANCE UNDER WHICH WE MAY SHARE YOUR PERSONAL DATA OR DISCLOSE IT TO OTHERS

LDFP 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 (e.g. between local, regional and national parts of the party) and the Party’s elected representatives. It may also be shared with those who provide services to LDFP and the Party (“service providers”).

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 our service providers may be based outside of 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 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 some cases, this may result in your personal data becoming public.

In particular, the Party and its 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.

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.