Privacy Policy

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 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”.

We will, at all times, process your data in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and related legislation.

Data Protection and Privacy Policy

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.

2. Contact

If you have any questions about this policy, for more information about how we use your data, or would like to exercise any of your rights, please contact us at:

3. How the law protects your data

How we use your data is protected by law and we are only permitted to process your data where we have an acceptable reason for doing so. The lawful reasons we process your data are:

  • Processing is necessary for the performance of a task carried out in the public interest (public task – democratic engagement), or
  • When it is our legal duty (legal obligation), or
  • When you provide consent (consent), or
  • To protect your vital interests (vital interests), or
  • To fulfil a contract with you (contract), or
  • When we have a legitimate interest (legitimate interest).

Some types of sensitive personal data are given extra protection under the law; information about your race, ethnicity, sexual orientation, sex life, religious or philosophical beliefs, criminal record, trade union membership and political opinion is “special category” data under data protection legislation and we will only process this data where we have a lawful reason to do so. The work of the Conservative Party, and the wider Conservative Party, is deemed to be of substantial public interest and therefore we are permitted to process special category personal data relating to your political opinion insofar as it is necessary for the purposes of our political activities.

Where we have identified “legitimate interest” as our lawful reason for processing your data we conduct a balancing test in order to determine whether our legitimate interests to process your data are overridden by your interests, rights and freedoms. For more information about our legitimate interest balancing tests please contact our Data Protection Officer.

4. How we use your information

We process data with the intention of using it primarily for the broad purpose of our political, campaigning and fundraising activities.

The full list and examples of how we commonly use your data, the typical categories of data that we might process and our justification and legal bases for doing so can be found in Section 4 of the Conservative Party Privacy Policy

5. Data sources

Your personal data can come from a number of sources, the main sources we collect your data from – including but not limited to:

Provided by you (Directly):

  • 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, a petition, a reply slip on a leaflet or if you write to us
  • Digitally, such as if you fill in a form on a website or interact with the Party online via our websites or social media platforms
  • When you consent to our use of cookies and similar technologies (such as our Facebook Pixel)
  • When you offer or ask about volunteering, or take part in party activities
  • When you enter into a transaction with the Party, such as becoming a member, donating, purchasing a product from our online shop or paying to attend an event
  • When you consent to receiving electronic marketing (we never buy in email addresses)
  • When you attend an event

Third-Party Sources (Indirectly):

  • When data is shared with us from the wider Conservative Party
  • The full electoral register and marked registers to which the Party is legally entitled as per The Representation of the People (England and Wales) (Amendment) Regulations 2002 and the Representation of the People Regulations 2001 in Scotland.  We receive an updated version of these from local authorities every time an update is published, which is usually every month.
  • Social media platforms and other technology providers (for instance, when you click on one of our Facebook ads or watch one of our Instagram or Youtube videos)
  • Publicly available information such as media history, news reports, web searches etc
  • Public records or sources such as Companies House, Land Registry etc
  • CCTV, if you visit Conservative Party Headquarters or one of our regional offices
  • Data brokers and data analytics companies – such as Experian
  • Royal Mail
  • Telephone Preference Service
  • Market research organisations
  • Due diligence and screening organisations

6. Data Analytics and Profiling

Like many organisations we use data analytics to try and understand the people that we seek to represent and make best use of our limited resources. The Conservative Party uses some of the data that we collect about you to make an educated prediction about your lifestyle. We use automated means to analyse this variety of data and collate it (sometimes referred to as “profiling”). We combine personal data about electors (which is provided by local authorities to all political parties under electoral statute) with data from canvassing, the marked register of electors, from external data analytics and research partners, data brokers (such as Experian), opinion polling partners, fulfilment channels such as mail/telephone/Facebook, public bodies such as the Office for National Statistics, etc. This data is then used by CCHQ to inform how and whether we contact you, for example by:

  • Understanding the matters and issues that are likely to be of relevance and significance to you (e.g. if we think you may have children we may send information about our education policy)
  • Deciding whether we send you our campaigning materials, or materials about how you can support the Conservative party.
  • Identifying target audiences for particular issues and appeals for financial support
  • Selecting what material we send to you
  • Evaluating whether we think you are likely to vote and for whom you will likely vote for during an election or a referendum

We also use analytics to perform analysis of individual and aggregated data (for example, we might combine individual data relating to voting intention and details about the constituency) to provide us with competitive insight into the political landscape and general trends, and to allow us to better understand the electorate as a whole.

Examples of categories of data that we typically analyse are: political affiliation, political opinions and preferences, likelihood to vote, attitudes, geodemographic and socioeconomic characteristics.

We undertake these analyses as we have a legitimate interest to identify potential Conservative voters and supporters. Indeed, it also allows us to behave accordingly should voters request that we don’t contact them, for example. Where our profiling processes special category data relating to your political opinion we consider that this is necessary for the purposes of our political activities and therefore permitted in accordance with Article 9(2)(g) GDPR – substantial public interest – DPA 2018, Schedule 1, Part 2, Paragraph 22 Political Parties.

Our analytics and profiling does not replace the direct contact that we make with individuals – these activities supplement our traditional campaigning methods such as canvassing and conducting surveys.

We have determined that this kind of profiling, and any decisions that are based solely on that profiling, is unlikely to create legal or significant effects for you. Where such decisions create legal or similarly significant affects you have the right not to be subject to that decision and you can exercise that right by contacting our Data Protection Officer. You can also contact us at any time and exercise your right to object and ask that we do not process your personal information for this purpose.

7. 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 that they are based in the UK.

8. 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 appropriate 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 UK and the EEA.

If we are unable to rely on one of the appropriate safeguards when transferring data outside the EEA, we may rely on a derogation for specific situations under Article 49 GDPR in order to transfer your data outside of the EEA. This may be necessary for example to fulfil a contract that we have made with your or if you give us permission to do so.

9. How long we retain your data for

We retain your information in accordance with the CCHQ Data Retention Policy and Data Retention Schedule. We constantly review the data that we hold and regularly consider its relevance and our need to hold onto it. We use several factors to determine our retention periods. Factors we take into consideration are:

  • 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 documented business requirement for 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,

If you require more detailed information on how long your data will be kept for please contact us via our Data and Privacy form (below).

10. Data Rights

This section explains about your data subject rights you have. You can exercise any of these rights by contacting our Data Protection Officer or Data Protection Team.

Your Data RightsExplanation
Right to be informedYou have the right to be informed about the collection and use of your personal data. CCHQ provides this in the form of privacy notices and/or privacy information at the point of collection or within one month of obtaining your data.  We may not provide privacy information where you either already have such information or it would involve a disproportionate effort to provide such information.
Right of access to your dataYou have the right to request a copy of your personal information that we hold. This is commonly known as a Subject Access Request.
Right of rectification of your dataYou have the right to request that inaccurate or incomplete information that we hold about you is corrected.
Right to be forgottenIn 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. There is some data that must be retained by law and other data that we may have a legitimate interest to retain
Right to restriction of processingYou 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.
Right to data portabilityYou 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. Information is only within the scope of the right to data portability if it is personal data that you have provided to us.
Right to objectYou have an absolute right to object to your data being used for direct marketing, including profiling for direct marketing purposes – we mark your data clearly with a “no processing” label. 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.
Automated individual decision-making, including profilingWe 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.

11. 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.

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 Information Commissioner’s Office are:

  • Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
  • Telephone: 0303 123 1113
  • Website:

If you have any questions about the data held please contact Rochester and Strood Conservatives via our Data and Privacy form (below).

Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.

This website itself is self-supported by the Rochester and Strood Conservatives and carefully chosen 3rd Parties who unequivocally abide by the Privacy Policy of the Conservative Party as a minimum standard.

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.

This privacy policy was last updated on 6 August 2022.

Policy Additions

The Rochester and Strood Conservatives are responsible for the management, hosting and running key components of this Website. The platforms and services we use comply with the Data Protection Act 2018, and the following provisions are applicable to our website only.

How we secure your data

We 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 anonymisation and pseudonymisation 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 any 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 login screen and change your password immediately.

Alternatively you can contact us to request a new password at

Online payments including donations and event registration

When someone donates to us online we may need some additional information about them.

Payments are processed online through PayPal and not directly through our website. This means that a donor can benefit from the security offered by PayPal when making their online donation. You can view PayPal’s privacy policy here. We never collect or process your payment information, such as credit card numbers and expiry dates, directly.

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

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 Plugins of When you visit one of our sites with Social Plugins (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 plugins, 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: (

More information is also available at

Request a Data Subject Access Request (DSAR)

If you wish to make a Data Subject Access Request, please complete the form below.

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To help us find and provide you with the information, please provide as much detail as possible regarding the information you wish to access (for example, where and by whom information is believed to be held, specific details of information required; dates covering the period of time you are interested in.)
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