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
- 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.
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.