Scottish National Party
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
Information from the ICO about the processing of data by political parties to communicate their message and promote democratic engagement can be found here.
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 £7,500. 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?
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:
- 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.
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.
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 less than £500 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 £7,500, 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 £7,500. When donations are to one of our local organisations, the reporting threshold is £1,500.
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. You will be given access to https://my.snp.org to allow you to access your data.
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.
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.
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.
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
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