Privacy Policy

Privacy Policy and Cookie Notice

This policy was last updated on 7th June 2018.

Introduction

Liberal Democrats for Seekers of Sanctuary (LD4SOS) respect individuals’ rights over their

personal data. We are committed to ensuring that people are treated fairly in everything we

  1. This Privacy and Cookie Notice (“Notice”) outlines:

 How we may collect personal data about you

 How we may use your personal data

 Why LD4SOS 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 LD4SOS 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.

LD4SOS 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 LD4SOS online

 When you offer or ask about volunteering, or take part in activities on behalf of

LD4SOS

 When you enter into a transaction with LD4SOS, such as donating, joining,

purchasing a product or paying for an event

 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 LD4SOS

We may collect personal data about you such as:

 Name

 Contact details (e.g. email address, address, telephone / mobile number)

 Future communication preferences

 Information about your financial transactions with the Party

 Racial or ethnic origin

 Issues you raise

 Topics you are interested in

We may also collect information when you interact with LD4SOS 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 place one or more cookies on your

device. For further details on this, see below.

How we may use your personal data

We may use your personal data to further our objectives, 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 join or volunteer for LD4SOS 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 LD4SOS 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, call us on 0113 2179636 or email

ld4sos5@gmail.com 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 LD4SOS

(“service providers”).

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 LD4SOS 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.

LD4SOS 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 LD4SOS’s work is considered to be of substantial public interest.

Because of that public interest basis, the Party and LD4SOS 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.

Similarly, you may from time to time give us your consent to send you communications by email

(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 circumstances under which we may share your personal data or disclose

it to others

LD4SOS 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 LD4SOS 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 some of our service providers are 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, currently £500, 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.

Additional details about cookies and technical information

A cookie is a small text file placed on your device when you visit a website. You can accept

or decline cookies through your browser settings or other software. Find out more about

cookies.

When you visit one of our websites, we may place one or more cookies on your device.

These are for purposes which include:

 Improving your experience of visiting the site, including providing personalised

content

 Gathering information you have submitted via the site

 Processing requests for information or action that you have made through the site

 Processing login requests

 Enabling your activity in one place to be used to decide on what information, if any,

to present to you in other places

 Gathered statistical information about the usage of the site

 Ensuring the smooth operation of online services

 Remembering whether or not you have been shown a cookie notification message on

an earlier visit to the site

 To make sure online adverts you may receive from us are relevant to your interests

By using our website, you are consenting to our use of cookies in accordance with this

Notice. If you do not agree to our use of cookies, then you should set your browser or other

software settings accordingly.

We may provide links to third party organisations with whom we have affinity arrangements,

such as an online retailer. In such cases additional cookies may be placed to facilitate this

arrangement and the third parties may also gather personal data about you in line with their

own privacy policies. If a third party shares any personal data gathered in this way with

LD4SOS, it will be made clear in its own privacy policy.

We also provide options to share content on social media which may result in your being

directed to the social media network’s own systems. If you proceed with this, those networks

may gather personal data about you in line with their own privacy policies. On our website or

in other digital communications we may also use technologies variously described as web

beacons, pixel tags, clear gifs or tracking pixels to provide us with information about how

people have navigated through the site or responded to the communication.

LD4SOS takes the protection of your information very seriously. We store your personal data

in a password protected encrypted files on computers that are separately password

protected. People working or volunteering on behalf of LD4SOS only have access to the

information they need.

Data retention policies

We only keep your personal data for as long as required to meet the purposes set out in this

Notice, unless a longer retention period is required by law. For example, this may include

holding your data after you have ceased to engage with LD4SOS (such as by resigning or

ceasing to be a member) where we have a legitimate interest in doing so, such as to enable us

to respond effectively to grievances that may arise after you cease to engage with us.

The exact details of this are set out in the Party’s Data Retention Policy and all the above is

subject to your legal rights, such as to have data in certain cases deleted or corrected, as set

out below.

Your rights over personal data

You have legal rights over any of your personal data that we hold.

Right of access

You may, at any time, request access to the personal data that we hold which relates to you

(sometimes called a subject access request).

This right entitles you to receive a copy of the personal data that we hold about you. It is not

a right that allows you to request personal data about other people, or a right to request

specific documents from us that do not relate to your personal data.

Right to rectification and erasure

You may, at any time, request that we correct personal data that we hold about you which

you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do

not believe that we need to continue retaining it (sometimes called the right to be forgotten).

Please note that we may ask you to verify any new data that you provide to us and may take

our own steps to check that the new data you have supplied us with is accurate. Further, we

are not always obliged to erase personal data when asked to do so; if for any reason we

believe that we have a good legal reason to continue processing personal data that you ask us

to erase we will tell you what that reason is at the time we respond to your request.

Right to restrict processing

Where we process your personal data on the legal basis of us having a legitimate interest to

do so, you are entitled to ask us to stop processing it in that way if you feel that our

continuing to do so impacts on your fundamental rights and freedoms or if you feel that those

legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of

that personal data and want us verify its accuracy; (b) where it has been established that our

use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to

process your personal data (and would otherwise dispose of it) but you wish for us to

continue storing it in order to enable you to establish, exercise or defend legal claims.

If for any reason we believe that we have a good legal reason to continue processing personal

data that you ask us to stop processing, we will tell you what that reason is, either at the time

we first respond to your request or after we have had the opportunity to consider and

investigate it.

Right to opt out of processing relating to your political opinions

You may, at any time, write to us to ask us to cease processing your personal data which

relates to your political opinions (such as how you have voted in the past, and things that you

have told us about how you are likely to vote).

Please note that these requests can only be made about data which relates to your political

opinions; they will not affect our right to use other aspects of your personal data.

Right to portability

Where you wish to transfer certain personal data that we hold about you, which is processed

by automated means, to a third party you may write to us and ask us to provide it to you in a

commonly used machine-readable format.

Right to stop receiving communications

Wherever possible, we will provide you with a choice about how we can contact you to share

information about LD4SOS. You can opt out of communications at any time by contacting us

by the methods described below.

Email

If you provide us with your email address and indicate that we may do so (e.g. by subscribing

to an email distribution list) we may send you further information about LD4SOS in the

future. These communications will take the form of e-mails promoting us and our work.

You can request that you cease to receive these kind of communications from us at any time.

The easiest way to do so is to use the unsubscribe link provided at the bottom of any e-mail

messages that we send to you. You can opt out of communications at any time by contacting

us on ld4sos5@gmail.com It may take several days for requests submitted this way to

become effective.

SMS messages

If you provide your mobile phone number, we may call or send you text messages if you have

given us permission to do so. You may request to stop receiving SMS messages at any point.

You can stop receiving SMS text messages by following the instructions to opt out provided

within that text message.

Post and telephone

We may contact you by post or telephone using information provided to us through the

electoral roll and other legitimate sources of contact information for the purposes of

campaigning, notifying you of our values and policies, and checking your eligibility to

donate.

We will respect any registration you hold with the Telephone Preference Service except

where you have opted in to receive communications from us. Further, even if you are not on

the Telephone Preference Service register you may ask us to stop making calls to you by

telling one of our operators when we call you.

General

While all of our direct marketing communications contain details of how you can stop

receiving them in the future you can either follow those instructions (such as using the

unsubscribe link in an email or telling a telephone caller) or ask us directly using the contact

details below. If you do the latter, please provide us with full details of the telephone

numbers, postal addresses, email addresses and so on to which you wish us to stop sending

communications to in order to help us deal with your request quickly and accurately.

We will process any requests to stop receiving communications as quickly and

comprehensively as is practical although there may in some cases be further communications

already on their way to you which cannot be stopped.

If you ask us to stop sending you information (e.g. by email, post, phone or SMS text), we

may keep a record of your information to make sure we do not contact you again, up until the

normal retention period for that type of data. See our retention policy above for details.

Please note that this right to stop communications does not apply to emails that we send to

you that are a necessary part of us providing a service to you (such as messaging you about

your status as a member or a volunteer) or us notifying you about how your personal data is

being used.

Exercising your rights

You may exercise any of these rights by contacting us using the details below and providing

the necessary details for us to be able to identify the relevant data and to act on your request

accurately.

When you contact us making a request to exercise your rights we are entitled to ask you to

prove that you are who you say you are. We may ask you to provide copies of relevant ID

documents to help verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise

and, where relevant, why it is that you are exercising it. The clearer and more specific you

can be the faster and more efficiently we can process the request. If you do not provide us

with sufficient information then we may delay actioning your request until you have provided

us with additional information (and where this is the case we will tell you).

How to contact us

If you have any queries regarding the information set out here, if you wish to exercise any of

your rights set out above or if you think that it has not been followed, please contact:

LD4SOS

11 Aspen View

Whinmoor

Leeds

LS14 2FF

ld4sos5@gmail.com

0113 21796362

You can also use these contact details, marked for the attention of the Chair of LD4SOS, if

you wish to lodge a formal complaint about any matter covered above.