Who we are
We are the Rochester and Strood Conservative Association (“we”/”us”/”our”), and we are a part of the Conservative and Unionist Party, commonly known as the Conservative Party (The Party). As such we are a part of the “wider Conservative family” referred to in the Privacy Notice published on the national party’s website, and this Privacy Notice should be read in conjunction with that, available at www.conservatives.com/privacy. We process data and comply with the standards as set out in that policy.
In addition to the principles laid out on the national party’s website, we have included additional privacy terms which cover our independently developed website. These can be found below in the “Policy Additions”.
This document outlines how Rochester and Strood Conservatives processes and manages personal data and:
• Identifies the data controller.
• Explains the lawful basis for processing personal data.
• Outlines the personal data held and processed.
• Outlines the scope of the special category personal data held and processed.
• Outlines the process of Subject Access Requests.
1. Data Controller
The Data Controller is Rochester and Strood Conservatives
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 contact Rochester and Strood Conservatives.
3. Lawful basis for processing
All processing is carried out by consent or either under the legitimate interest of Rochester and Strood Conservatives, or public interest. These cover processing to conduct casework, campaigning and communication. Where processed under the lawful basis of a task carried out in the public interest, it is to support or promote democratic engagement. This includes fundraising activity in order to support democratic engagement.
4. Data sources
Data held is that provided by you when you contact us and correspondence with third parties in response to cases taken up on your behalf. If you do not wish for us to contact you by telephone please do not provide this information. The Register of Electors that councils provide to authorised persons under the Representation of the People Act is also used for electoral purposes.
5. Data Security
Personal data is stored electronically and securely. We ensure that our service providers comply with the same high standard that we do, and are in the UK.
6. Special category data
Special category data will be processed under the lawful basis indicated in section 3, as is permitted in clauses 22, 23 and 24 of schedule 1 of the Data Protection Act, covering political parties and elected representatives.
7. Transferring your data outside of the European Economic Area
Some 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 the transfer of your data outside of the EEA takes place we will make sure 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 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.
Legally it is not permitted to transfer certain types of data, such as Electoral Register Data, outside of the EEA, and we honour that obligation.
8. Data retention policy
Personal data will be held for no longer than necessary. Some types of data may be held for longer than others. Typically the maximum retention is two election cycles. Review of the data held will occur in each election cycle to determine whether it should be maintained or put beyond use.
9. Subject Access Requests
Subject Access Requests are dealt with in line with the guidance given by the Information Commissioner’s Office (ICO):
1. We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
2. We will respond within 28 calendar days once we have confirmed it is a legitimate request.
3. Data subjects have the right to the following:
a. To be told whether any personal data is being processed
b. To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people.
c. To be given a copy of the information comprising the data, and given details of the source of the data where this is available.
10. Will we share your data with anyone else?
If you have contacted us about a personal or policy issue, your data may be passed on to a third-party in the course of dealing with your enquiry, such as local authorities, government agencies, public bodies, health trusts, regulators, and so on. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the basis upon which they were originally intended.
We may need to share your data with a third party, such as the police, if required to do so by law.
Data may also be shared with entities of Political Party associations, federations, branches, groups and affiliates in order to assist you or maintain contact with you 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, and recognising the need of politically related engagement in wider support of democratic engagement.
11. Data Rights
At any point you 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 our office refuses your request under rights of access, we will provide you with a reason why. You have the right to complain.
12. Making a complaint
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 ICO are:
Information Commissioner’s Office,
If you have any questions about the data held please contact Rochester and Strood Conservatives via the contact information on this website.
Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.
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 and/or post a notice on this website.
– Updates included a change in the page structure and standardisation of the policy with that of the Conservative Party.
Rochester and Strood Conservatives use a different website provider from that used by the main Conservative Party. We are responsible for the management, hosting and running key components of this Website.
Our Website runs from a single unified platform called “WordPress”. This provides us with a wide range of tools – e.g. analytics, user registration, commenting, database management, e-commerce and payment processing. The platforms and services we use comply with the Data Protection Act 2018, and the following provisions are applicable to our website only.
WordPress.com (Automattic Inc.)
WordPress.com is an Opensource platform provided by Automattic Inc. which allows us to build, run and host this Website.
Place of processing: USA.
20i.com (20i Ltd.)
STACK is a hosting platform provided by 20i.com. that allows us to host and run our website.
Place of processing: UK
How we secure your data
Rochester and Strood Conservatives will always do our best to keep your personal data safe. We use safety protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising of personal data where suitable, and we monitor our systems for possible vulnerabilities and attacks, such as brute force and anti-virus protections on our website.
Even though we try our best, we cannot guarantee the security of information. However, we will notify all victims of, and the suitable authorities about data breaches. We will also notify you if there is a threat to your rights or interests. We do everything we reasonably can to prevent security breaches and we will assist authorities should any breaches occur.
If you are a candidate or sitting councillor and have an online account with us, note that you have to keep your username and password secret – never share your personal data with anyone. If you forget your password or believe that someone may have access to your account without your permission, please click the “Forgotten Password” button on the log in screen. Alternatively you can contact us to request a new password at: firstname.lastname@example.org.
Online payments including donations and event registration
When someone donates to us online we may need some additional information about them.
If you donate more than £7,500 to the Party via the website, we are obliged under the Political Parties Elections and Referendums Act 2000 to report such a donation to the Electoral Commission, who will publish the fact that you have made a donation over £7,500. For more information, please see http://www.electoralcommission.gov.uk/
Under the Political Party Elections and Referendums Act 2000 (PPERA) you must be on the electoral register in the UK excluding the Channel Islands and the Isle of Man in order to make a donation of more than £500.
Online Polls, Surveys and Q&A Informational Sites
From time to time, Rochester and Strood Conservatives may host online polls, surveys and question and answer (Q&A) functions on our website. The data you provide in response to questions asked on these sites will be retained by Rochester and Strood Conservatives in accordance with the provisions of the Data Protection Act 2018 and related legislation. We will use the data you provide to:
- improve our understanding of political life in Rochester and Strood;
- compile and provide anonymous statistics about voters in Rochester and Strood;
- facilitate our operation as a political party; and
- help the Party in developing policies to include in manifestos for elections.
For Q&A functions, we may also use your responses to provide you with tailored information on the relevant subject area.
In addition we may also ask you for your contact details such as your email address. This is entirely optional, and by entering your contact details you agree to receive communications from us, from which you can opt-out using the “unsubscribe” link at the bottom of each email we send.
Where we require your email address for a specific purpose, we will give you clear options on how you want us to use this information.
We will not share your details with anyone outside the Conservative Party. In addition we may use your responses in the survey to keep you informed about issues that matter to you.
If you participate in online polls, surveys or Q&A’s, we collect your Internet Protocol (IP) address in addition to your answers. This data will be used by us and our agents to help validate the results and to help in preventing multiple entries from individuals.
A cookie may also be placed on your system after participating in a poll or survey. No identifiable information will be stored in this cookie, they are simply to prevent duplicate entries.
Web Beacons and Tracking Links
The Rochester and Strood Conservatives may use Web beacons (also known as pixel tags and clean GIFs). These involve graphics that are not apparent to the user, and which do not provide us with any data about individuals. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites.
These are primarily used for statistical analysis purposes, in conjunction with cookies. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
Our website provides Social Plug-ins of Facebook.com. When you visit one of our sites with Social Plug-ins (recognisable by a white F on a blue tile, a blue F on a white tile or a thumb up sign) your browser establishes a direct connection to the servers of Facebook. The content of the plug-in will be transferred to your browser and displayed on the website. The information that you visit our website is now transferred to Facebook.
If you are logged on in Facebook during the visit on our website, Facebook adds this information to your private Facebook profile. Nothing is posted to your wall without your consent. If you are interacting with one of the social plug-ins, e.g. make a comment, this information will also be transferred to Facebook. In addition, other information such as your IP address, browser and other parameters may be transferred to Facebook and stored there.
In case you do not wish such a data transfer, please log out of Facebook before you enter our website.
We cannot influence this data collection and data transfer by the Facebook plug-ins. Please see Facebook’s privacy statements for more information on the purpose and extent of data collection by Facebook, as well as how they further process and use your data there, and your related rights and setting options for protecting your privacy: (https://www.facebook.com/privacy/explanation).
More information is also available at www.youronlinechoices.eu.
When a user comments on a news article on our website, the name, email and website will not be stored as a cookie on the user’s browser unless they click the consent checkbox to “save my name, email and website in this browser…”
If a user selects this option, a cookie file will be placed on their computer to remember this selection. We do not obtain any personal data from this cookie.
If a user does not select the consent checkbox, then the name, email and website will need to be entered manually each time the user wishes to leave a comment.