THIS POLICY
This Privacy Policy tells you how and why the Social Democratic Party (SDP) collects, stores and uses personal data; explains the lawful bases for the collection and use of personal data; outlines your rights under the relevant data protection legislation; and details how to make a query or complaint regarding the SDP’s use of personal data.
Personal data means any information that can directly or indirectly identify a living person.
The relevant data protection legislation is the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).
The SDP’s Privacy Policy was last updated in September 2024. It may change in future so please check back from time to time.
WHO WE ARE
In this Privacy Policy, the words ‘we’, ‘us’, ‘our’ or ‘the party’ refer to The Social Democratic Party (SDP), a political party registered with the Electoral Commission, registration number PP243.
In accordance with UK data protection law, we are a Data Controller and accountable for the way we process personal data.
We are registered with the Information Commissioner’s Office (ICO), registration number: ZA900533.
CONTACTING US ABOUT DATA PROTECTION
If you have any questions about this Privacy Policy or would like more information about how we collect, store or use personal data, please contact us on:
E-mail: info@sdp.org.uk
Post: Social Democratic Party, 272 Bath Street, Glasgow, G2 4JR
Telephone: 0141 354 1512
HOW WE COLLECT PERSONAL DATA
Direct provision
Personal data is provided directly to us by Members and Supporters of the party.
Members are those who have paid a fee and joined the party.
Supporters are those who have provided their contact details to us in order to receive communications from the party.
Members and Supporters may provide their data in a number of ways, including:
- filling in a form on our website (https://sdp.nationbuilder.com/)
- contacting us by phone, post, e-mail or direct message on social media
- communication with any party officer or member
The data provided may include:
- Names and contact details
- Addresses
- Marketing preferences – e.g. opting-in to receive communications
- Credit / debit card information – this is encrypted and not accessible to party officers
- Political opinions – e.g. provided by members commenting on proposed policy motions.
Additional data generation
To the data provided directly by Members and Supporters, we may generate and add the following data:
- Ward and constituency details based on the postal address provided
- Record of attendance at party events
- Value of donations to the party
Electoral Register
As a political party we are provided with access to the electoral register by local authorities for the purposes of canvassing and promotion.
HOW WE USE PERSONAL DATA
We use personal data for the sole purpose of conducting Party Business.
Party Business is defined as legitimate activities that support the goals and objectives of the Social Democratic Party (SDP).
Examples of Party Business that require the use of personal data include membership administration, event ticketing, fundraising, candidate selection and nomination, and communicating party news and other relevant information to Members and Supporters with their consent.
OUR LAWFUL BASES FOR USING PERSONAL DATA
Under UK data protection law, we must have a “lawful basis” for collecting and using personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website:
Which lawful basis we rely on may affect your data protection rights which are listed at the end of this Privacy Notice.
Our lawful bases for the collection and use of personal data are:
Legitimate Interest
- Creation and maintenance of records for membership management purposes such as recording membership terms and payments, producing and sending welcome packs and renewal notices.
- Communication with Members about essential party business, e.g. leadership elections.
- Administration of internal party posts and election candidates.
Consent
- We provide information to Members and Supporters about:
- party news such as meetings, events, campaigns, announcements, internal elections, internal party officer posts, requests for election candidates and volunteers, requests for donations and relevant content sharing.
- third party campaigns, organisations, or content that we generally endorse (e.g. proportional representation), or events where prominent SDP members are due to speak.
- Communication with Members about anything other than essential membership administration matters or events they have registered to attend is carried out on the basis of consent.
- All communication with Supporters is carried out on the basis of consent. If a Supporter opts out of receiving digital communication, their data will simply be deleted and they will receive no further communication from the party.
- The party communicates primarily by e-mail because it is cheap, fast and scalable. For reasons of cost, efficiency and reliability, postal communication is limited to essential items such as welcome packs, renewal letters, and leadership ballot papers.
A Member may exercise their right under GDPR to opt out of digital communications.
If they do so, they may proactively access members-only party news by logging in to this webpage:
https://sdp.nationbuilder.com/member_news
However, it is hard for us to provide the full benefits of membership to those who opt out of digital communication as it is not feasible to provide Members with regular updates on party news via post.
We implore our members not to opt out of receiving e-mails from us.
Legal Obligation
- Recording and reporting information on donations to the party. See the section on DONORS AND DONATIONS for details.
Contract Fulfilment
- Management of bookings and communications about party events, e.g. the annual conference.
- Provision of services under the membership contract e.g. membership welcome pack and party newsletters.
Public Interest (promoting democracy)
- Canvassing political opinions, for example seeking Members’ feedback on policy. Political opinions are classed as ‘special category’ data under data privacy legislation and our processing of this data is in accordance with Article 9 (g) of GDPR which states that “processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law…”
- Administration of candidate selection and nomination processes, e.g. verification of signatures on candidate nomination forms.
- Planning and running election campaigns, e.g. deciding where to field candidates, where to hold events, putting out requests for volunteers, and delivering campaign materials to registered voters.
DATA SHARING
We will never sell your personal data.
We will not share your personal data with third parties without your permission, unless we:
- are required to do so by law
- need to do so in order to protect somebody’s vital interests
- need to do so in order to exercise, establish or defend our legal rights
DATA STORAGE
The party uses the data management system NationBuilder for all aspects of membership administration, including sending bulk e-mails to the membership, receiving and recording donations, and taking bookings for party events.
- All membership and supporter records are created and stored centrally and securely on the NationBuilder platform.
- NationBuilder allows delegated access to the regional branches and county level groups. This access is restricted to membership data in their geographic area.
- Only authorised personnel in the party HQ or regional branches can send bulk e-mails to the membership.
- The NationBuilder system joins electoral geography to membership data, adding each member’s Westminster constituency, devolved parliament and local government information to their membership record.
- NationBuilder participates in the EU-US Data Privacy Framework, and provides tools and functionality designed to ensure GDPR compliance.
DATA PROTECTION
We take the security of the data we hold very seriously, and as such employ a number of security procedures to keep data safe.
Access to data
- Access to personal data is restricted to designated party officers either at party HQ or in the branch network. This is managed on a strict need-to-know basis, meaning nobody has access to data they don’t need.
- All those who access membership data are required to sign the Data Protection Form and attend data protection training.
- Authorised users are instructed to use data extracts strictly in accordance with this Privacy Policy, not to pass them to other party members or third parties, not to use them for any other purpose than party business, and to delete them upon completion of the task for which they were requested.
Financial data
- The SDP via its NationBuilder system does not hold detailed financial information on members.
- Credit / debit card information such as cardholder’s name, card issuer, card numbers or expiry date, provided by Members via Nationbuilder is encrypted and cannot be read by party officers.
- The only information visible to party officers is the fact that a member used a credit / debit card to pay for a membership subscription, donation or event ticket on a certain date and the amount paid.
Registration with the Information Commissioner’s Office
- The Social Democratic Party is registered with the Information Commissioner’s Office (ICO).
- This means we are legally required to report all suspected data breaches and all improper and/or unlawful uses of this data to the ICO for investigation.
- The ICO has the power to both investigate and prosecute an individual responsible for any breaches of data protection which may result in substantial fines.
DONORS AND DONATIONS
- The SDP, like every UK political party, is obliged under UK electoral law to report all large donations and loans (currently at or above £11,180 p.a.) and the name of the donor to the Electoral Commission who will make this information public via regular reporting.
- Donations below £500 p.a. are not covered by the rules and do not need to be recorded, aggregated or reported to the Electoral Commission.
- Donations between £500 and £11,179 have some reporting requirements to the Electoral Commission but the name of donor is not disclosed.
- The value of donations made by Members and Supporters is stored in NationBuilder and can be accessed by authorised party officers via a membership report.
- The party advises anyone wishing to donate more than £500 and in the large donation category to read the Electoral Commission guidance:
DATA RETENTION
- Membership data is kept on a perpetual basis until a member resigns or dies.
- When membership lapses, membership data will be retained for reasonable time-period before being deleted, usually after 2 years.
- When Supporters opt out of receiving e-mails, their data is removed from the system.
USE OF PERSONAL DATA AND DATA ANALYTICS FOR POLITICAL CAMPAIGNING
We are provided with access to the electoral register for the purposes of canvassing and promotion. We only use this information for:
- Verifying signatures on candidate nomination forms
- Planning and organising campaigns, which may include bulk postal communications or door-to-door leaflet delivery
- Calculating campaign budgets.
As stated above, the only data processing that we currently engage in is adding electoral geography – i.e. wards and constituencies – to our membership and supporter records.
We do not currently use personal data or sophisticated data analytics to target voters using methods such as those described in the ICO’s 2018 report Democracy Disrupted?
https://ico.org.uk/media/2259369/democracy-disrupted-110718.pdf
Should we do this in future, we will update this Privacy Notice accordingly.
We may place targeted advertisements using the demographic data stored on social media platforms, but we have no direct access to this data.
YOUR RIGHTS
Your rights under UK data protection law include:
- Right of access– You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
- Right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure– You have the right to ask us to delete your personal information in certain circumstances.
- Right to restriction of processing– You have the right to ask us to restrict the processing of your information in certain circumstances.
- Right to object to processing– You have the right to object to the processing of your personal data in certain circumstances.
- Right to data portability– You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
- Your right to withdraw consent – When we use consent as our lawful basis for data use, you have the right to withdraw your consent at any time.
To make a data protection rights request, please contact us using the contact details on page 1 of this Privacy Policy. If you make a request, we must respond to you without undue delay and in any event within one month.
More information on your data protection rights and the exemptions which may apply can be found on the Information Commissioner’s Office website:
HOW TO COMPLAIN
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
LAST UPDATED: 28 September 2024
