This notice outlines how Kemi Badenoch processes and manages personal data (as defined in the UK GDPR) in her campaign to become leader of the Conservative and Unionist Party and:
- Identifies the data controller.
- Explains the lawful basis for processing personal data.
- Describes the personal data held and processed.
- Provides information about special category personal data.
- Provides information about your rights as a data subject and how to exercise them.
The data privacy policy Kemi Badenoch maintains in her role as a Member of Parliament can be found here.
- Data Controller
The Data Controller is Kemi Badenoch. Only her campaign team, under her direction, and service providers will process this personal data.
- Contact
If you have any questions about this policy, for more information about how we use your data or if you wish to exercise any of your rights, please get in contact via the contact information provided on this website.
- Lawful basis for processing
All processing is carried out on the basis of our legitimate interests, in performance of a task in the public interest, or as necessary for compliance with a legal obligation, or where relevant, with your consent. The primary purpose of the processing of personal data is to build engagement as part of the process to be elected as leader of the Conservative and Unionist Party, to communicate with members of the Conservative and Unionist Party and the wider public, then if elected leader to promote democratic engagement with the public as leader.
We may also process personal data under the lawful basis of a task carried out in the public interest, in particular to support or promote democratic engagement. This includes fundraising activity in order to support democratic engagement.
- Data sources
We hold the personal data that you provide when you contact us. We may also hold data that you provide when we contact you – for instance, if we ask you to participate in a survey. If you do not wish for us to contact you by telephone please do not provide your telephone number. Personal data obtained in this way may be combined with information from the Conservative and Unionist Party, or related entities that support Conservative aims or the Conservative and Unionist Party. Where legally permitted, it may be used for electoral purposes in conjunction with the Register of Electors that councils provide to authorised persons under the Representation of the People Act.
When you sign up for communications, use our website or communicate with us in any way, including attending any event we organise, we may collect certain personal data that can be used to identify you. Any data that does not enable you to be identified is not considered personal data.
When you use our website, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address. For more information, please refer to our Cookie Declaration.
We may receive information about you from third party service providers (such as Google Analytics or social media platforms like X or Facebook), who collect this information through our social media or from interaction with our websites in accordance with their own privacy policies.
- Purposes of Processing
We will use your personal data for the broad purpose of Kemi Badenoch’s leadership campaign.This will include communicating with you, and using the information that you provide to improve and refine our campaign, including how we use advertising.
- Data Security
Personal data is stored electronically and securely. We ensure that our service providers comply with the same high standard that we do.
- Special category data
Special category data (which in this case means data about your political opinions) will be processed with your consent.
- Transferring your data outside of the UK
Some service providers are located outside of the UK and therefore it may be necessary to transfer your personal data outside of the UK. Where the transfer of your data outside of the UK takes place we will make sure that it is protected in the same way as if the data was inside the UK, and it occurs only in accordance with the law.
We will only transfer your data to countries where the U.K. has adequacy regulations in place, or by other lawful transfer mechanisms/
- Data retention policy
We will not hold personal data for longer than necessary (some types of data may be held for longer than others). This data will be reviewed following the conclusion of the leadership election process, and will either be put beyond use or, with your consent, transferred to the Conservative and Unionist Party’s contact database so you can remain informed of Party Policy and democratic engagement.
- Will we share your data with anyone else?
We may need to share your data with a third party, such as the police and regulators such as the Information Commissioner, if required to do so by law.
We will share your personal data with a small number of service providers and suppliers for example printing and delivery suppliers, technology providers, organisations providing services for events, and social media platforms.
With your consent, data may also be shared with entities of Political Party associations, federations, branches, groups and affiliates in order to assist you or maintain contact with you in support of democratic engagement.
Your personal data is only used as outlined here and within your reasonable expectations based on the nature of the communication, and recognising the need of politically related engagement in wider support of democratic engagement.
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the basis upon which they were originally intended.
- Data Subject Rights
You have the following rights:
- Right of access – you have the right to request a copy of the information held about you.
- Right of rectification – you have a right to have data held about you corrected if it is inaccurate or incomplete.
- Right to erasure – you can ask for the data held about you to be erased from our records.
- Right to object – you have the right to object to certain types of processing, such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
- Right to withdraw consent – you have the right to withdraw your consent at any time if you have given specific consent to any processing of your personal data. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
We will request verification of the identity of any individual making a request, ask for further clarification and details if needed and respond within one calendar month once we have confirmed it is a legitimate request. In accordance with ICO guidelines, we keep a log of Subject Access Requests that contains details of the request, including that which can identify you personally, indefinitely.
- Making a complaint
If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom. The contact details for the ICO are:
- Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
- Telephone: 0303 123 1113
- Website: https://ico.org.uk/concerns/
If you have any questions about the data held please contact Kemi Badenoch via the contact information on this website.
Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.
We retain the right to update this policy at any time. If there are changes that significantly impact your rights, we will contact you in advance.
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