PRIVACY POLICY AND COOKIE POLICY
This privacy policy sets forth how James Cleverly processes and manages personal data in his campaign to become leader of the Conservative and Unionist Party, and this policy works in conjunction with his policy as a Member of Parliament. James Cleverly is the data controller, and only his staff, under his direction, will process personal data.
1. Data Controller
The Data Controller is James Cleverly for leader campaign.
2. Contact
If you have any questions about this policy, require more information about how we use your data, or would like to exercise any of your rights contact: Info@jamescleverly.com
3. Lawful basis for processing, source, sharing and security
All processing is carried out under one of the following lawful bases: By consent, under legitimate interest or public interest. The primary purpose of the processing of personal data is to build engagement as part of the process to be elected as leader of the Conservative & Unionist Party (the ‘Party’), to communicate with members of the Party and the wider public, then if elected leader to promote democratic engagement with the public as leader. Where processed under the lawful basis of a task carried out in the public interest, it is to support or promote democratic engagement, and may be used for fundraising activity.
The Personal Data collected arises from what is provided by you. Some personal data may also arise from you participating in a survey or petition. If you do not wish for us to contact you by telephone, please do not provide your number. Personal data obtained in this way may be combined with information from the Party, or related entities that support Conservative aims or the Party, and where legally permitted it may be used in conjunction with the Register of Electors that councils provide to authorised persons under the Representation of the People Act, and this will then be used for electoral purposes.
To comply with other legal obligations, your personal data may be passed on to a third-party if legally required such as to the police or regulators like the Information Commissioner. Personal data may also be shared with third party service providers, any such third parties that we may share your data with are obliged to keep your details securely, and use them only for the basis upon which they were originally intended.
Unless otherwise specified, personal data may also be shared with James’ political party, entities such as his political party association, federation, branches, groups and affiliates in support of democratic engagement.
Your personal data is only used as outlined here and within your reasonable expectations based on the nature of the communication, recognising the need of politically related engagement in wider support of democratic engagement.
Personal data is stored electronically and securely using industry standard software.
OPT-OUT & UNSUBSCRIBE – You are always able to opt-out of receiving communications. Users may opt-out of receiving any or all communications from us by contacting us or selecting the ‘Unsubscribe’ option on emails sent to you.
4. Special category data
Special category data will be processed with your consent: Provision of your personal data that is special category relating to the leadership campaign will seek your consent at the point at which you provide it.
Where appropriate given the connection to the Party and potentially the role as a Member of Parliament then it may also be processed under the lawful basis as permitted in clauses 22, 23 and 24 of schedule 1 of the Data Protection Act, covering political parties and elected representatives.
5. What We Collect & Transferring your data outside of the European Economic Area
When you sign up for communications, use our website or communicate with us in any way, including attending any event we organise, we may collect certain Personal Data that can be used to identify you. Any data that does not enable you to be identified is not be considered Personal Data.
Device Information - When you use our Website, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address. For more information, please refer to our Cookie Declaration.
Information we obtain from third parties - We may receive information about you from third party service providers (such as Google Analytics or social media platforms like X or Facebook), who collect this information through our social media or from interaction with our Websites in accordance with their own privacy policies.
Aggregated Anonymised Data - The information we collect from you may be combined with information provided by others, but only in an anonymised format, to produce aggregated anonymised data sets for research purposes. Such Aggregated Data is not considered to be Personal Data as it does not reveal your identity.
The EU GDPR adequacy decision means that data can continue to flow between the UK and the European Economic Area (EEA). Some service providers may be located outside of the EEA and therefore it may be necessary to transfer your personal data outside of the EEA. Where the transfer of your personal data is outside of the EEA, it will be subject to contractual terms to ensure 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 UK or European Commission has issued an adequacy decision determining that a non-EEA country or organisation ensures an adequate level of data protection, but always ensuring it meets UK requirements.
• 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.
6. Data retention policy
Personal data that is held, will be reviewed after the leadership election process, and will either be put beyond use or data subjects will have the option to remain part of Party’s contact database to remain informed of Party Policy and democratic engagement, and this will ensure it is not processed for longer than is necessary.
7. Subject Access Requests
We will request verification of the identity of any individual making a request, to ensure we protect the data subject’s personal data and only release information to those entitled to it. We may ask for further clarification to properly understand a request to enable a response within one calendar month, but the time for a reply only starts once we have confirmed it is a legitimate request that is clearly understood by us. In accordance with ICO guidelines, we keep a log of Subject Access Requests that contains details of the request, and personal data is part of that.
8. Data Rights
Data Subjects 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 we refuse your request under rights of access, we will provide you with a reason why. You would then have the right to complain in certain circumstances to the Information Commissioner.
9. Making a complaint
If you are unhappy with the way that we have processed or handled your personal data, then you have a right to complain to the Information Commissioner’s Office (ICO). The contact details for the ICO are:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• Telephone: 0303 123 1113
• Website: https://ico.org.uk/concerns/
We retain the right to update this policy at any time. Please periodically review these terms.
10. Cookies
We may use ‘cookies’ to enhance the users’ experience. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Declaration.