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Privacy Policy

  

We are the Wigan Conservatives Federation (The Federation), a Federation and an accounting unit of the Conservative and Unionist Party, commonly known as the Conservative Party (The Party). Wigan Conservatives Federation is a Registered Data Controller with the Information Commisioner's Office (ICO) under registration number Z196002X. This is the privacy policy of the Wigan Conservatives Federation and not just our website www.wlmconservatives.com. This privacy policy does not apply to our councillors or our MP, who have their own privacy policies. We retain the right to update this policy at any time. If there are changes that significantly impact your rights, we will contact you in advance.

We are happy to make this policy available in other accessible formats such as braille. If you wish to obtain a copy in an accessible format please contact our Data Protection Officer at office@wlmconservatives.com
 

This privacy policy covers activities and processing where Wigan Conservatives Federation is the data controller.

Where we act as a data processor for the Conservative and Unionist Party, we will abide by the privacy policy of the Conservative and Unionist Party.


The Conservative and Unionist Party is Registered as a political party with the Electoral Commission under registration PP52 and a Registered Data Controller with the Information Commissioner’s Office (ICO) under registration number Z5909711. The privacy policy of the Conservative Part is available at https://www.conservatives.com/privacy. The Wigan Conservatives Federation privacy policy follows the principles enshrined in the privacy policy of the Conservative Party.


This Privacy Policy has been created in order to demonstrate the Federation’s commitment to the protection of your data and to be transparent in how we deal with it.

The Federation will process your data in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

This privacy policy was published on 12th November 2020.

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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 you can contact our Data Protection Officer at:

Data Protection Officer

111 Bolton Road

Ashton-in-Makerfield

Wigan

WN4 4AD

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You may contact us by e-mail at office@wlmconservatives.com

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What information do we collect?

The types of personal information that we may collect about you include:

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  • Name
  • Date of birth
  • Contact Details (e.g.      address, email address, telephone number, mobile number, social media)
  • Communication Preferences
  • Direct Marketing Preferences
  • Electoral Register Data (
  • Demographic data
  • Occupation 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

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We may also collect special categories of information such as:

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  • Political Opinions
  • Voting intentions
  • Racial or ethnic origin
  • Religious views

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How we collect data

We collect data about you in the following ways: 

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Provided by you (Directly):

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  • 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 the Party online via our      website or social media platforms
  • When you offer or ask about      volunteering, or take part in party activities
  • When you enter into a      transaction with the Party, such as donating, joining, purchasing a      product or paying for an event
  • When you consent to      receiving marketing emails etc
  • When you attend a conference      or campaign event

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Third Party Sources (Indirectly):

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  • When data is shared with us      from the Conservative Party
  • Indirectly from publicly      accessible sources or other public records, including the full electoral      register to which the Party is legally entitled
  • 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
  • From commercial      organisations with whom we have a contract guaranteeing full data      protection compliance.
  • CCTV, if you visit a      building operated by us.
  • The Party is legally      entitled to, and receives, the electoral registration records of all      electors in the United Kingdom by Councils across the United Kingdom as      per The Representation of the People (England and Wales) (Amendment)      Regulations 2002.  We receive an updated version of these every time      an update is published, which is usually every month.
  • We collect data with the      intention of using it primarily for political activities.
  • The Conservative Party uses      the data that we collect about you in order to build a picture of you and      the United Kingdom electorate. 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.


How we use your information 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:

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  • In pursuit of an activity      that supports or promotes democratic engagement (Public Interest), or
  • When it is our legal duty      (legal obligation), or
  • When you provide consent      (consent), or
  • In order to fulfil a      contract with you (contract), or
  • When we have a legitimate      interest (legitimate interest).

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The law restricts the processing of what is termed “special categories of personal data”. The work of the Wigan Conservatives Federation is deemed to be of substantial public interest and therefore we are permitted to process special categories of personal data relating to your political opinions and voting intentions.

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The list below lists examples of how we use your data and our justification and legal basis for it.

        Bold - Purpose

        Italic - Legal Basis and justification


Canvass Political Support

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to identify Conservative supporters

Send you messages about our campaigns and policies, including via social media adverts

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to inform the electorate about what the Conservative Party is doing

Contact you about issues or queries that you have told us about

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to engage with the electorate

Process and record voting intentions and political opinions

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to understand the electorate and identify Conservative supporters

Send you surveys and process your responses

In pursuit of an activity that supports or promotes democratic engagement

Process your application for membership and administration of your membership

Contractual necessity and our legitimate interest in engaging with our membership base

Send you information by post about fundraising activities to support the Party

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to raise funds for the Party.

Process your donation and checking your eligibility to donate

We have a legitimate interest to process your donation and a legal duty to check your eligibility to donate amounts of more than £500

Assess suitability of prospective members and donors using publicly available sources

We have a legitimate interest to ensure that our members and donors will not bring the Party into disrepute

Send you electronic messages about our campaigns

When you sign up to receive emails from the Conservative Party you are providing us with your consent to process your data for these purposes

Identifying potential supporters using commercially available modelled data

In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to identify Conservative supporters

Conduct anonymised market research

We have a legitimate interest to get a sense of general political opinion across the UK


Our legitimate interests:

Our objective is to promote our values and to elect Conservative candidates at every level of government, or when we campaign in referenda. In order to do this we rely upon the support of our members, donors, volunteers and supporters. We rely on being able to communicate and engage with the United Kingdom Electorate and those eligible to vote.

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As a member: If you join the Conservative Party, and thus Wigan Conservatives Federation, we have a legitimate interest in processing your data and contacting you about all aspects of your membership including information about your entitlements as a member and about Federation events; either by post or by electronic means. The party is run by its members and therefore we have a legitimate interest in member engagement and retention. If you do not renew your membership with the Party and Wigan Conservatives Federation we will continue to send you information about the Conservative Party and Wigan Conservatives Federation, including information on how to rejoin, for a reasonable period after your membership lapses. We also have a legitimate interest to retain your data after your membership lapses, as well as a legal duty to keep a record of the financial transaction.

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As a donor: If you donate money to the Wigan Conservatives Federation or Party then we have a legitimate interest in processing and retaining your information 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 to our regulator, the Electoral Commission, who will publish certain details on their website. 

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As a volunteer: If you volunteer for the Party or enquire about volunteering for the Party, and are not a member, we have a legitimate interest in processing and retaining your information and contacting you about volunteering opportunities. We justify this because of the vital function that volunteers perform both during and outside of elections.

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If you attend an event: If you attend one of our events such as Party conference or one of the Federation’s social or campaign events, and are not a member of the Party, we have a legitimate interest in retaining your information and to send you marketing about future similar events which we think might be of interest to you; either by post or by electronic means. We have a legitimate interest in inviting people to our events in order to raise vital funds for the Wigan Conservatives Federation and the Party and have determined that attendees would expect to receive such communications from us.

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Much of the work of the Party is conducted by the Conservative Party. For this reason we have a legitimate interest in sharing certain personal information with the Party when it is necessary for our campaigns or activities.

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Whilst a lot of our political activities are considered to be tasks carried out in the public interest, we also have a legitimate interest to carry out these tasks. We justify this due to our defined objective as a political party.

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You will always have the opportunity to opt out of receiving any messages from the Conservative Party or the Wigan Conservatives Federation or to exercise any of your legal rights.

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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.


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.


Who we share your data with:

We will never sell your data but sometimes it is necessary to share your information, either within the wider Conservative Party or 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.

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We share data with: 

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  • The Conservative Party
  • The wider Conservative Party
  • Business associates and      professional advisers
  • Suppliers
  • Service providers
  • Financial organisations –      such as credit card payment providers
  • Political organisations
  • Elected representatives
  • Regulatory bodies
  • Market researchers
  • Healthcare and welfare      organisations
  • Law enforcement agencies

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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.


Transferring your data outside of the European Economic Area

Some of our service providers are located outside of the European Economic Area (EEA) and therefore it may be necessary to transfer your personal data outside of the EEA. Where we do transfer your data outside of the EEA we will make sure that it is protected in the same way as if the data was inside the EEA.

We will use one of the following safeguards to ensure this:

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  • Where the European      Commission has issued an adequacy decision determining that a non-EEA      country or organisation ensures an adequate level of data protection.
  • 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.
  • The transfer is to an      organisation that complies with the EU-US Privacy Shield.

We are not permitted to transfer Electoral Register Data outside of the EEA.


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. Whilst we do not set finite periods for data retention we use several factors to determine whether we need to hold onto the data. Factors we take into consideration are:

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  • Retention periods as      required by law – for example the Conservative Party is under a statutory      duty to retain financial information for a period of 6 years,
  • 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,


Cookies

We use cookies on our website to analyse how visitors use our site. We use this information to improve our website and provide the best experience to visitors.

When you visit our website each visitor is offered the choice whether to accept or decline these cookies. We process cookies, as highlighted above.


Log Files and Statistics

We use IP addresses, URLs of requested resources, timestamps and HTTP user-agents to analyse trends, administer the system and gather broad demographic information for aggregate use. In addition to this we use Google Analytics, a web analytics service provided by Google, Inc ("Google"). Google Analytics uses cookies, to help analyse how visitors use our site. The information generated by the cookie about the use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for the Conservative Party and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your Web browser, however please note that if you do this you may not be able to make full use of our website. By using this website, after agreeing to use cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above.


How we protect your data:

The security of your data is paramount to the Wigan Conservatives Federation 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.


Your rights over your data

Right of access to your data

You have the right to request a copy of your personal information 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

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Right of rectification of your data

You have the right to request that inaccurate or incomplete information that we hold about you is corrected.

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Right to be forgotten

In certain circumstances you can ask for the data we hold about you to be erased from our records. When we do so, we keep the bare minimum of your information in order to continue to respect your wishes when your personal data is next provided to us by a local authority, which is at least annually.

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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.

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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.

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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.

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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.


Making a complaint

You can make an informal or formal complaint directly to us by:

Writing to us:

Data Protection Officer

111 Bolton Road

Ashton-in-Makerfield

Wigan

WN4 4AD

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Emailing us:

office@wlmconservatives.com


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:

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  • Information Commissioner’s      Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
  • Telephone: 0303 123 1113
  • Website: https://ico.org.uk/concerns/

Promoted by Michael Winstanley on behalf of the Wigan Conservatives Federation, both at at WLM Conservatives, PO Box 806, Wigan, WN1 9WL.

  • Privacy Policy

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