Privacy policy — scottish national party

SCOTTISH NATIONAL PARTY PRIVACY POLICY The Scottish National Party is an unincorporated membership organisation. It is also a registered political party regulated by the Electoral

Commission. It exists to promote Scottish Independence and all other Scottish interests. We are committed to the protection of your data. This policy has been created so that we are

transparent about how your data is dealt with. The Data Protection Act 2018 and the General Data Protection Regulation (GPPR) recognise the importance of democratic engagement in the course

of electoral activities. “Democratic engagement” legally covers a wide range of political activities inside and outside election periods, including: democratic representation; communicating

with electors and interested parties; surveying and opinion gathering; campaigning activities; activities to increase voter turnout; supporting the work of elected representatives and

candidates; and fundraising for any of these activities. Political parties require to compile personal data on people’s political opinions. This is permitted in the public interest as long

as appropriate safeguards are in place. This privacy notice provides information about those safeguards. As a political party we also have a number of legitimate interests in pursuing our

policy and electoral aims, including engaging with the electorate on our policy agenda and retaining support, volunteering and membership. We have a Data Protection Officer who can be

contacted in the following ways: mail: Gordon Lamb House, 3 Jackson’s Entry, Edinburgh, Scotland EH8 8PJ tel: 0800 633 5432 email: [email protected] Information from the ICO about the

processing of data by political parties to communicate their message and promote democratic engagement can be found here. This Privacy Policy is available in other accessible formats such as

Braille. If you wish to obtain a copy in an accessible format, please contact our Data Protection Officer. THE DATA WE PROCESS We process the personal data of every person on the electoral

register in Scotland. It is part of our role as a registered political party to encourage involvement in political processes, as well as to promote our political aims. We process political

opinion information about the electorate, if this is provided to us directly by you or if it is publicly available. For example, we will identify individuals who are known supporters of

other parties because they are elected politicians. We also process the personal data, including political opinion data, of our members, donors, supporters and volunteers for the same

purposes. Your data, including political opinion data, will not be made publicly available unless this is required by law such as in the case of donors whose donations are above £11,180. It

will never be sold to third parties. In some circumstances, it is provided to third parties to assist us in carrying out our tasks. This is done under a legal contract with specific

provisions about what can be done with the data, along with obligations relating to confidentiality and security. For example, we share the address data for the electorate to suppliers who

print election addresses. WHAT INFORMATION DO WE COLLECT? _VOTERS _ The SNP receives the full electoral registration records of all electors in Scotland annually. We also receive updates

every time they are published, which is usually every month. Political parties are supplied with the “full electoral register”, including details for voters who have opted-out of the “open

register”. These records are sent to us by your local Electoral Registration Officer and can be used by us for the purpose of democratic engagement. The Electoral Registration Officer

provides us with your: * Name * Address * Date of Birth (if you are under 18) * Electoral registration number (which allows us to know where you will vote at elections and referendums) *

Postal vote status * Information on whether you voted in an election or referendum (not how you voted) From this information, we allocate an internal identification number. If we contact you

to canvass your voting intentions or other political opinion information, and you provide us with that information, then we will record that against your record. This is so that we can: *

decide whether we send you our campaigning materials; * select what campaigning material we send to you and which messages we put on it; and * evaluate whether we think you are likely to

vote and for whom you will likely vote for during an election or a referendum. _MEMBERS _ You provide us with your name and contact information when you sign up as a member. You are

allocated a membership number and the ability to access your membership account where you can update your contact details and provide us with your preferences in relation to how we contact

you. We will store historic contact details about you from when you became a member. This data is processed to provide you with our membership services. If you have made a payment online, we

do not store any financial information from that transaction which is dealt with by a third party. We may process some bank details if you have provided them for direct debit processing.

From time to time we will send you member’s updates including information about the SNP, your local constituency, fundraising and campaigning. As a member you have access to your own account

details in www.my.snp.org and you can update your contact preferences at any time. We recognise that by becoming a member of the SNP, the data we hold is data revealing your political

opinion. We may also store information about your opinion on topical issues and interests that you have. This is to understand the matters and issues that are likely to be of relevance and

significance to you and better inform our future policies. _DONORS _ If you provide a financial donation to the SNP, we will process your personal data to administer that donation. We also

have to comply with our legal obligations as a regulated political party and to process your personal data. For donations of £500 or less to the central party, we create a record of your

donation on our database. For donations over £500, we must check that you are registered to vote and appear on an electoral register. We must store your name and address. For donations over

£11,180, we must report the name and the amount of the donation to the Electoral Commission for inclusion in their public registers. We also report donations which added together over the

course of the year amount to £11,180. When donations are to one of our local organisations, the reporting threshold is £2,230. _SUPPORTERS_ When you sign up online to become a supporter of

the SNP, or to one of our campaigns, we will create a record of your support on our database. We may contact you further on matters of interest and use your postcode and other information to

tailor the communication. _VOLUNTEERS _ When you sign up online to volunteer to assist the SNP, we will create a record on our database setting out how you wish to help. _EVENT ATTENDEES_

When you sign up to attend our conferences and events, we will store your contact information on our database. _SNP WEBSITE USERS_ When you interact with our website and provide us with your

details, this will be stored to allow us to communicate with you on subjects you are interested in following your preferences. _CCTV_ The SNP uses CCTV to ensure the safety of its staff and

the security of its offices. We hold footage for 28 days and then delete it. We have signs and we make staff and visitors aware that their images are being recorded as they enter our

office. WHO WE SHARE YOUR DATA WITH We will never sell your data but sometimes it is necessary to share your data to provide you with information or carry out our functions as a political

party, including: * * Business associates and professional advisers * Mailing houses, such as Critiqom * Email software providers, such as MailChimp, Marketing Cloud and SendGrid * Cloud

service providers such as Microsoft, Google and Salesforce * Elected representatives/local candidates and activists * Regulatory bodies and law enforcement agencies when required for

investigations Data will only be shared where appropriate legal contract and security safeguards are in place. HOW LONG WE RETAIN YOUR DATA FOR We continuously review the data we hold,

review its relevance and consider our need to hold onto it. We retain information obtained from an Electoral Registration Officer and other information associated with those individuals for

up to 18 months on our live system after a person ceases to be on the electoral register. When a voter’s details are removed as a result of a register update, we retain the details but mark

them as a ‘Deleted record’ until the next annual update of the register, which we usually process in January. We require to hold this data until the next annual update to enable us to match

up data from one annual update to another annual update. This, paradoxically, includes matching voters on our system who have asked that we do not process their data. If we did not hold this

information, we could not respect their right not to have their data processed. It is also part of the Information Commissioner’s advice for Political Parties that there is a statutory

right to send an electoral address to voters as part of the democratic process, and this includes those who have asked for their data not to be processed by political parties. Voter’s basic

details obtained from Electoral Registration Officers, but not any voting intention or history, is retained on our archive system for up to 10 years. This is because we may need to check if

a donation by way of bequest is permissible, and legislation does not currently allow us to access all of the old electoral registers. COOKIES A cookie is a tiny text file stored on your

computer. We may use technology to track the patterns of behaviour of visitors to our site. This can include using this “cookie” file stored on your computer. You can usually modify your

browser to prevent this from happening. We may store the internet address you connect to our computer with, the time and date you connected, browser information and the pages you visited.

This information is used only to provide us with a statistical breakdown of our site usage and to monitor site security. _Log Files and Statistics_ We use IP addresses, URL’s of requested

resources, timestamps and HTTP user-agents to analyse trends, administer the system and gather broad demographic information for aggregate use. In addition to this we use Google Analytics, a

web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies, to help analyse how visitors use our site. The information generated by the cookie about the use of

our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our website,

compiling reports on website activity for the SNP and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties

where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may

refuse the use of cookies by selecting the appropriate settings on your Web browser. However, please note that if you do this you may not be able to make full use of our website. By using

this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. HOW WE SECURE YOUR DATA We ensure that appropriate technical and

organisational measures are in place to protect your data. We regularly review our measures to ensure that your data remains protected from any threats that may emerge. YOUR RIGHTS IN

RELATION TO YOUR DATA You have rights over the processing of your personal data and the SNP is committed to complying with your requests where possible. Please use the contact details above

to make any request and we will do our best to deal with your request without undue delay and, in any event, within one month of the request being received. We can extend this deadline by

another two months if we believe it is necessary to do so because of complexity, but we will advise you of this extension and our reasons for requiring it. _RIGHT TO OBJECT TO MARKETING_:

You have the right to ask us to stop contacting you by addressed correspondence for the promotion of political messages. Political parties retain the right to send you an election address as

this is for the purpose of democratic engagement. You may still receive unaddressed leaflets and newsletters. _RIGHT TO OBJECT TO THE PROCESSING OF POLITICAL DATA_: You have the right to

request in writing that we stop processing political opinion data about you. _RIGHT OF ACCESS TO YOUR DATA_: You have the right to request a copy of your personal information that we hold

and information about how we process that data. This is commonly known as a Subject Access Request. _RIGHT OF RECTIFICATION OF YOUR DATA_: You have the right to request that inaccurate or

incomplete information that we hold about you is corrected. _RIGHT TO BE FORGOTTEN_: In certain circumstances you can ask for the data we hold about you to be erased from our records. _RIGHT

TO RESTRICTION OF PROCESSING_: You have the right to request that we restrict the processing of your data where you are contesting the accuracy of the data or when the data has been

unlawfully processed. _PROFILING_: If we have information about your voting intentions and history of voting, which you have either provided to us or which is publicly available, we will

place you in a category based on how likely we think it is that you will vote for the SNP. You have the right to object to that. _MAKING A COMPLAINT_: If you are unhappy with the way that we

have processed or handled your data then please contact our DPO and we will do our best to resolve your issue. If you remain unhappy you have a right to complain to the Information 

Commissioner’s Office (ICO). mail: ICO, Wycliffe House, Water Lane, Wilmslow SK9 5AF tel: 0303 123 1113 website: https://ico.org.uk/concerns/