[UPDATED: May 6, 2020]
We respect the privacy of every person who visits our website www.toriesincomms.org (the “Website”) and who uses the services that we provide and/or promote on our Website (our “Services”).
1. Purpose of this Policy
2. Who are we?
The Website and our Services are provided by Conservatives in Communications (“we”, “us” or “our”). We are an independent and informal industry network. Conservatives in Communications is the data controller of your personal information.
3. How to contact us?
4. What personal information do we collect and how do we use it?
We collect and receive personal information using different methods:
- Personal information that you provide to us
- Personal information which we gather from publicly available sources
- Personal information received from third parties.
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us deliver our Services; (iii) help us improve the Services and develop our network; (iv) send you marketing communications; (v) carry out requests made by you on the Website; (vi) comply with any applicable law; and (vii) use as otherwise required or permitted by law.
In particular, but without limitation, we use your personal information for the following purposes:
A. Fulfilment of Services.
We collect and maintain personal information that you voluntarily submit to us during your use of the Website and/or our Services, for example when you email us to get involved or you register to attend one of our events. We use the information that you have provided to us so that we can fulfil the supply of Services to you.
B. Gathering your feedback.
From time to time we will ask you to provide feedback about Conservatives in Communications or our Services in the form of a voluntary survey.
Where you take part in a survey which includes questions on diversity and inclusiveness, we may collect the following personal data:
We use this information to help us improve our network and offering. We also use your feedback to monitor the quality of our Services and to assist with the future direction of Conservatives in Communications. Survey responses will be aggregated and depersonalised before survey results are shared with any third parties or published.
C. Email marketing and communications.
We use your name and email address to send you marketing and communications by email from time to time.
5. Basis for processing
Our objective is to promote our values which you can find here: https://toriesincomms.org/story. In order to do this, we rely upon the support of, and being able to communicate with, our team, patrons and sponsors.
We will only use your personal information where we have a lawful reason for doing so. In most circumstances it is necessary for us to use your personal information to provide the Services to you and perform our obligations in accordance with any contract that we may have with you. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you and to carry out the processing described above.
By voluntarily participating in one of our surveys we rely on your consent to use the personal information we collect or you supply as part of such survey. However, where special category information is collected as part of one of our surveys, we rely on legitimate interests to process the special category data to improve the diversity and inclusiveness of Conservatives in Communications and/or we rely on reasons of public interest.
6. Sharing with third parties
We may share, where relevant, your personal information (e.g. name, contact information including email address, other information relevant to the provision of our Services, or any personal information that you provide to us as part of our providing the Services) with third parties to enable us to provide the Services, carry out the processing described in paragraph 4 above and deliver on the values of Conservatives in Communications.
We may share, where relevant, your personal information (e.g. name, contact information including email address, other information relevant to the provision of our Services, or any personal information that you provide to us as part of our providing the Services) with third parties to enable us to provide the Services, carry out the processing described in paragraph 4 above and deliver on the values of Conservatives in Communications. These third parties include the wider Conservative party and other third parties such as to third-party customer survey company who assists us with administering the surveys or marketing platforms who assist us with our marketing newsletters.
We will never sell your data but sometimes it is necessary to share your information, either within the wider Conservative Party, or with our service providers and data processors. Data is only ever shared where we have a justification and when the law allows us to do so.
7. Third Party Links and Services
8. Transfers outside the EEA and UK
Where necessary in order to deliver our Services, we will transfer personal information to countries outside the EEA and UK. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
9. How long do we keep your personal information for?
We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to Conservatives in Communications and our legal and regulatory obligations.
10. How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns or by calling their helpline on 0303 123 1113.