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 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, prospective candidates and official candidates; and fundraising to support any of these activities.
Political parties require to compile personal data on people’s political opinions and this is permitted in the public interest as long as appropriate safeguards are in place. This privacy notice provides information about those safeguards.
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 own 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 will be 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 Electorate in Scotland
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 you an internal identification number. If we contact you for the purpose of canvassing 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 as follows:
Donations over £500: The SNP must check that you are registered to vote and appear on a UK electoral register (this applies to overseas residents as well as UK residents). We must store your name and address
Donations over £7,500: The SNP must report the name and the amount of the donation to the Electoral Commission for inclusion in their public register of donations to the SNP.
For donations of less than £500, we will create a record of your donation on our database.
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 and in accordance with 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 information to provide you with information or carry out our functions as a political party. Data will only be shared where appropriate legal contract and security safeguards are in place.
Business associates and professional advisers
Email software providers such as MailChimp, EventBrite, SendGrid etc
Cloud service providers such as Microsoft, Salesforce etc
Elected representatives/local candidates and activists
Regulatory bodies and law enforcement agencies when required for investigations.
How long we retain your data for
We constantly review the data that we hold and regularly review its relevance and our need to hold onto it. We will only process your personal data for as long as is necessary and we have a retention policy that sets out our view on that time period.
A cookie is a tiny text file that is 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 which would be stored on your computer. You can usually modify your browser to prevent this 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 broad statistical breakdown of our site usage and to monitor site security.
Log Files and Statistics
We ensure that appropriate technical and organisational measures are in place to protect your data. We constantly review our measures to ensure that your data is 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 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.
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