This Privacy Policy sets out how we handle, store, and process personal data which we collect or which is provided to us.
Collecting your information
We collect personal information from a variety of sources. Most often, you will provide us your personal information directly by:
- Completing a form on our website
- Responding to an email from us
- Signing up to attend an event hosted by us
- Filling out a form provided by a NHA Party representative, for example at an event
- Having a conversation on the doorstep, phone, or online with a NHA Party representative
- Interacting with us on social media
- Applying for a job, or signing up to volunteer
- Donating
We also obtain information from other sources, including:
- The electoral register
- Publicly available information, including census data and election results
- Estimates of other personal information, such as information linked to the area where you live
- Information derived from successful or unsuccessful efforts to contact you
Special Category Data
According to the Data Protection Act, “special category data” includes more sensitive data such as your political opinions. The NHA Party will sometimes need to process such data.
The types of personal data we may collect about you
We may collect a range of personal data about you depending on your relationship with the party:
Members and Subscribers |
Members of the public |
Staff and volunteers |
Donors |
Name |
Name |
Name |
Name |
Contact details |
Contact details |
Contact details |
Contact details |
Date of birth |
Date of birth |
Date of birth |
Date of birth |
Diversity monitoring data including: Gender, ethnic origin, religious beliefs, information about disabilities, sexual orientation |
Gender |
Diversity monitoring data including: Gender, ethnic origin, religious beliefs, information about disabilities, sexual orientation |
Communication preferences |
Communication preferences |
Communication preferences |
Communication preferences |
Information about financial transactions with the Party |
Phone call recordings |
Phone call recordings |
Phone call recordings |
|
Information about financial transactions with the Party |
Family details |
Information about financial transactions with the Party |
|
Topics you are interested in |
Topics you are interested in |
Topics you are interested in |
|
Your attendance and engagement with Party events |
Your attendance and engagement with Party events |
Your attendance and engagement with Party events |
|
Your political opinions and opinions on Party policies |
Your political opinions and opinions on Party policies |
Your political opinions and opinions on Party policies |
|
Photographs |
Information about your home, lifestyle and social circumstances |
Photographs |
|
Data from marked electoral registers |
We only use data from external sources if they are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources.
We may also collect information when you interact with the party’s website and social media pages, 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, share it with our elected representatives and/or contact you in future. Examples of the way we may use your data include to:
Members and Subscribers |
Members of the public |
Staff and volunteers |
Donors |
Contact you regarding your membership |
Contact you to canvass for support |
Contact you regarding your employment / application |
Contact you regarding your donation |
Conduct fundraising activities |
Understand your views |
Verify your identity and right to work |
Verify your eligibility to donate |
Process surveys you have participated in |
Process surveys you have participated in |
Monitor diversity |
Tell you about our fundraising campaigns |
Tell you about policies, campaigns, events, or individuals who may be of interest to you |
Tell you about policies, campaigns, events, or individuals who may be of interest to you |
Process payments |
Respond to queries you raise with us |
Respond to queries you raise with us |
Respond to queries you raise with us |
Respond to queries you raise with us |
|
Administer applications for membership, volunteering roles, or elected roles |
|||
Manage our site and services |
If you have provided us with your email, mobile phone number or landline phone number and we have a legal basis to use them. We may contact you to promote causes and campaigns that we support, such as by sending you an email, online advert, or a text message.
You may opt out of communications with us at any time.
Legal basis
We use a variety of lawful bases to process your personal data and this section explains this in more detail.
Type of data |
Legal basis for gathering and processing |
Personal details including names and addresses, as well as political opinions |
GDPR Article 6(e) Public Interest (Legal Basis) GDPR Article 9(2)(g) processing is necessary for reasons of substantial public interest (Condition for processing). |
Ethnicity, religion, gender, disabilities and sexual orientation |
GDPR Article 6(a) Consent (Legal Basis). GDPR Article 9(2)(a) Consent (Condition for Processing). |
Household data |
GDPR Article 6(a) Consent |
Data related to financial transactions |
GDPR Article 6(c) Legal Obligation |
Personal data about our members and supporters including name and contact information |
GDPR Article 6(b) For the purpose of entering into a contract. GDPR Article 6(a) Consent. |
Voter’s telephone numbers |
GDPR Article 6(a) Consent GDPR Article 6(f) Legitimate Interests |
Photographs |
GDPR Article 6(a) Consent |
Personal data related to complaints and queries |
GDPR Article 6(f) Legitimate Interests |
Personal data related to attending NHA Party events |
GDPR Article 6(b) For the purpose of entering into a contract |
Usernames/ Social Media handles |
GDPR Article 6(a) Consent |
Personal data related to recruitment and employment including contact details |
GDPR Article 6(b) For the purpose of entering into a contract |
Record Management
The NHA Party will monitor its databases and ensure that we retain the minimum amount of personal data in order to fulfil its purposes.
When we might disclose your data
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes set out in this Policy.
We may share your data with third parties to perform services on your behalf and to help promote the NHA Party by serving you advertisements and content online about our politicians, campaigns and policies we think you might be interested in. Types of third parties who may have access to your personal data include:
- Third Party IT System Suppliers who may host your data on their systems and may need some level of access to resolve technical concerns
- Printers and digital advertising suppliers to print off and send out campaign materials
- Event venues, who may need your information for security purposes, or seating requirements
- The Electoral Commission for publication of donation information in line with regulatory requirements
- The Police in relation to security of specific events
- Solicitors, counsel and claimants in relation to legal matters
- Statutory agencies and/or the police in relation to safeguarding or member welfare concerns
- Social Media Providers
- Confidential Waste Providers
- Volunteers working on behalf of the NHA Party
We may disclose your personal information:
- to the extent that we are required to do by law
- in connection with any ongoing or prospective legal or safeguarding proceedings
- in order to establish, exercise or defend our legal rights (including providing information to others for the purpose of fraud prevention and reducing credit risk)
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such or authority would be reasonably likely to order disclosure of that personal information
We will never sell or share your personal information with other organisations for their direct marketing purposes without your explicit consent.
Transferring data outside the European Economic Area (EEA)
Occasionally, in order to meet the purposes defined in this Policy, we may need to transfer personal information you submit to us to countries or jurisdictions outside the EEA.
In each case, we ensure that our suppliers provide adequate protection for the confidentiality and security of this information and the rights of data individuals in connection to the transfer of their personal data.
Specific safeguards are in place to govern this sharing, including ensuring that relevant suppliers include standard contractual clauses agreed by the European Data Protection Board for international transfers within their contracts.
The measures listed above have been agreed as appropriate by the Information Commissioner’s Office.
Your rights
You have a number of rights under Data Protection law including:
- The right to be informed about the collection and use of your personal data e.g. via this privacy Policy
- The right to access your personal data, also known as a subject access request (this allows you a right to your data, but not data related to other individuals)
- The right to have any inaccurate personal data rectified, or completed, if it is incomplete
- The right to have your personal data erased in certain circumstances (subject to the Party’s overriding legitimate interest, as outlined previously)
- The right to request the restriction or suppression of their personal data in certain circumstances
- The right to data portability – to obtain and reuse your personal data for your own purposes across different services
- The right to object to our use of your information in certain circumstances e.g. for marketing or profiling purposes
If you would like to do any of these things or raise any other concern about how we use your information, please contact us.
We follow the ICO’s Code of Practice when dealing with requests for access to personal data, which you can find here:
https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdf
Full information on your rights under the Data Protection Act can be found from the following link: