Northern Independence Party
Privacy Notice – Public / Supporters / Partners
Who We Are
The Northern Independence Party (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
The Northern Independence Party’s registered office is at 10 Houghton Avenue, Warrington, WA2 7EQ, and we are a political party registered in England and Wales. We are registered on the Information Commissioner's Office Register of Data Controllers (registration number pending), and act as the data controller. Our designated Compliance Officer for the organisation is our compliance manager, we can be contacted at [email protected], while our address and telephone number can be found at the foot of this notice.
Scope of this Notice
This notice is written to satisfy our commitment to your Right to be Notified of our policy around processing data collected. It is specifically for members of the public (including those that visit our website), those that have chosen to support the party and 3rd party businesses that we deal with on a day-to-day business.
Information That We Collect
The Northern Independence Party processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than already specified in this notice.
The personal data that we collect from is: -
- Name
- Date of Birth
- Home and Business Address
- Personal Email
- Business Email
- Home Telephone Number
- Work Telephone Number
- Mobile Telephone Number
- Financial details
- IP address
- Political Opinions (we recognise this is a type of special category data, please see section below)
We collect information in the below ways: -
- Face to Face
- Telephone
- Cookies
- In writing
- When canvassing/campaigning both by phone and in person
- Data provided with the Electoral Register which includes whether you have voted (but not data on who you have voted for)
- Demographic data
NB as a political party recognised by the Representation of People Act (1918) and the Political Parties Elections and Referendums Act (2000) we have the right of access to the Electoral Register.
How We Use Your Personal Data & Legal Basis for Processing
We take your privacy very seriously and will never disclosure, share or sell your data without an appropriate legal basis such as when we are required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time. The purposes and reasons for processing your personal data are detailed below: -
Party Management: (Supporters): We collect your personal data using performance of a contract or to provide our services and to manage your account with us.
Party Strategy (Supporters/Public) We collect and store your personal data under the lawful basis of our Legitimate Interests of Public Interest and using the additional basis of Public Task required for processing Special Category (political opinion) data. We use this data to help us ensure that our strategy and manifesto supports the views of the majority of our supporters and those we seek to represent.
Funding: (Supporters/ Public) We collect and store your personal data as part of our process to generate financial support for the party. Where we do so using email / SMS we do so using your explicit consent. Where we process this data using any other method (i.e. postal / campaigning face to face) we do so under Legitimate Interests (see section on Legitimate Interests) and using the Special Categories lawful basis of Substantial Public Interest.
Credit Reference: (Supporters/ Public): We share your personal data with a credit reference agency and provide us with financial background checks prior to you commencing services or funding with us. We do so using the Legal Obligation lawful basis.
Events: (Supporters/ Public): As part of the legitimate interests of the Party in running events that may be of interest to members of the public or it’s donors and with your explicit consent where any more sensitive special categories data may need to be collected.
Research: (Supporters/ Public): We undertake research and focus groups to improve our knowledge of the voting electorates’ opinions to help with Party strategy, We do so on the basis of our Legitimate Interest and for Special Category data (such as political opinion) on Substantial Public Interest.
Dealing with Enquiries/Complaints (Supporters/ Public): We do this using Legitimate Interests and/or under legal obligation (depending on the nature of the enquiry/complaint). Communication of this nature may be direct with us, or over any of our Social Media Channels.
Subcontractor Management (3rd parties): We collect your personal data using performance of a contract to enable such a service to operate. (see Sharing and Disclosing your Data section of this notice)
Marketing Initiatives (Supporters/ Public): We collect and process your personal data using consent (or explicit consent) or to provide marketing information
Processing Job applications/CV’s (Supporters/ Public) We collect this information to assess your suitability to work with us on the basis of Legitimate Interests
Your Rights
You have the right to access any personal information that The Northern Independence Party processes about you and to request information about: -
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure.
Legitimate Interests
Where we rely on this lawful basis we do so having conducted a Legitimate Interests Assessment (LIA) to ensure that the purposes we use to justify this processing is the most appropriate and least intrusive method, and that our legitimate interests do not override the rights and freedoms of those whose data we are processing.
Sharing and Disclosing Your Personal Information
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. The Northern Independence Party uses third parties to provide the below services and business functions, however all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
- Our Accountants for Accountancy purposes
- Our supporter relationship manager partners to manage your account with us
- Google for our Communications
- Our funding partner (GoFundMe)
- Accounting Software for financial management
- Party Management Software for our coordination of party business and supporters
- Email Services – for communications
- Cloud Software – for document storage
- Private Message Boards – for Party organisation and discussion
Special Category Data (formerly sensitive data)
The UK GDPR identifies certain types of data as sensitive (Special Category) such as political opinions, religious beliefs, philosophical beliefs, race etc and we apply additional security measures to ensure that this data is protected to a higher degree. We also employ Access Control measures to ensure that only those with a legitimate requirement has access to that data.
Social Media
We also use various social media channels to provide support and answers any questions you might have. We never add anyone’s personal data into any social media channel or use their audience or category advertising features, however we act as joint controllers as they determine how your data is managed once you engage with us on each channel.
Transfer of your data outside the UK/EU
Our internal systems do not involve the transfer of your data outside of the UK, however some of our partners use servers based in the US. We take all reasonable steps to protect this data and conform with the requirement to have a written agreement in place to ensure your rights under the UK GDPR are respected and that transfers are conducted using security measures to protect your data.
Security/Safeguarding Measures
We take your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: -
- SSL, encryptions, authentication, access control
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to The Northern Independence Party, however, as this information is required for us to provide you with our services, we will not be able to offer some of our products or services without it.
Profiling
We undertake very basic forms of profiling (such as demographics). We do not buy data, and we do not combine your data with any other data sourced. We are also careful not to make inferences with regard to your data and especially around the special category of Political Opinions.
How Long We Keep Your Data
We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. We keep unsuccessful CV’s/job applications/interview notes for 6 months before securely destroying them.
Where you have consented to us using your details for direct marketing, we will keep such data until you withdraw your consent, although we do refresh consent periodically
Lodging A Complaint
The Northern Independence Party only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Compliance Manager
The Northern Independence Party
James Thornbury
e. [email protected]
t. 07951 780 789
Information Commissioners Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Email – via their website – www.ico.org.uk