Background

This policy was last updated on 24/5/18

The remit of the EU’s General Data Protection Regulation (GDPR) includes Liberal Democrat Expand. The regulation requires that data subjects are informed of how their data will be used, and in particular how long their data will be kept and used for. These are known as data retention periods.

Below are details of how long Liberal Democrat Expand will retain your data.

DATA RETENTION PERIODS

General

Where required by legislation, regulation or where the data is relevant to an ongoing investigation, for example, by the Party, a regulator or the police, data will be retained for as long as required. Otherwise, data will be retained for the periods as set out below.

1. Political Opinions

Proposed Retention Period: 15 years from collection

Liberal Democrat Expand has an explicit lawful basis in the UK implementation of GDPR, the UK Data Protection Bill (UKDPB) 2018. It proposes an explicit public interest lawful basis for democratic engagement and it is believed that this retention period, whilst long, is justified under the legislation. The Bill also provides an explicit exemption for political parties to process political opinions without requiring consent from the individual.

Liberal Democrat Expand also has a right to the Electoral Register under the Representation of Peoples’ Act.

Liberal Democrat Expand will therefore retain Political Opinions for a maximum of 15 years from collection whilst an individual is on the Electoral Register. This period is based on 3 Full Term Parliamentary Cycles

Covered by this data set are all political opinions collected in person, by phone, via the internet, social media and apps. This includes voting intention, voting history, and opinions on all political topics.

Individuals can ask for records of their political opinions to be corrected or deleted and can ask for the Party not to process their data.

2. Campaign Materials and Multimedia

Proposed Retention Period:

• 5 years for multimedia of non-members that is not used in publication from collection
• 15 years for all other material in this category from collection / production

As these materials will often include some personal data, for example in the form of photographs or contact details of a candidate and agent, they require a retention period.

For ensuring best practice, training and historical interest these materials may be kept for 15 years from date of publication or, in the case of material that was unpublished, from date of completion of their production process.

However, for multimedia of individuals who were not members of the Party at the time the multimedia was created (for example, photos and video) then, if that material has not been used in a publication, this limit is reduced to 5 years, based on 1 Full Term Parliamentary Cycle, during which the relevant campaign topic may still be relevant and the media could be of use.

Use of media of non-members of Liberal Democrat Epxnad will also be subject to appropriate consent requirements that will need to be obtained prior to publication, ideally at the point of capture / collection.

3. Data with Financial Content

Proposed Retention Period: 7 years from tax year of transaction

Financial regulations require retention of data for a minimum of 6 Full Tax Years. A common best practice is to retain data for 7 years to ensure data is retained for transactions that fall across tax year ends, e.g., a service is provided, invoiced and paid in different tax periods.

There is a considerable amount of data processed by the Liberal Democrat Expand that falls into this category and therefore needs to be retained for this period.

Examples of data with financial content that is required to be kept for this period includes:

• Employee Data where salaries and expenses have been paid
• Membership Data where membership fees have been paid
• Donor Data, including PPERA returns
• Election and Referendum Expense Returns
• Volunteer Data, but only where expenses have been paid
• Conference Registration, where a fee has been paid
• Event Registration, where a fee has been paid
• Suppliers details, including transactions

In these cases, sufficient data for financial controls, auditing, ensuring compliance with electoral finance regulations and fraud prevention will be kept for the 7-year period. For example, name, contact details of the individual and details of the transaction.

Other personal data that may have been appended to financial data will be retained in line with the other relevant part of this policy depending on the data’s type.

4. Contact and Personal Data

Proposed Retention Period: 12 months from opting out or no longer being accessible
Re-consent Cycle for Emails: 15 years from collection
Re-consent Cycle for Telephone numbers for SMS: 5 years from collection

Liberal Democrat Expand is required to gather consent to contact individuals by electronic methods such as email, text, apps, etc., under the Privacy and Electronic Communications Regulations (PECR). The level of consent has changed with GDPR.

Contact and personal data for someone will be retained and may be used until:

1. (a) a request from the person for such contact to cease, or
(b) Liberal Democrat Expand becoming aware that the contact information is no longer accurate (e.g. a phone number no longer works or a hard bounce is received in response to an email).

In such cases, Liberal Democrat Expand will cease attempting to make contacts using such data and will delete their personal and contact data which does not fall under section 3 after a further 12 months, unless in the interim new consent or corrections to the data, as applicable, have occurred

In addition, if a Liberal Democrat Expand member resigns or their Liberal Democrat Expand membership lapses at the end of a quarter, then Liberal Democrat Expand will delete their personal and contact data which does not fall under section 3 after a further 12 months, unless in the interim they have re-joined Liberal Democrat Expand or otherwise given consent for their data. For non-members who are donors, employees, volunteer, activists, suppliers and attendees to conference, events or training, a similar 12-month period will begin from the date of their last transaction with Liberal Democrat Expand.

Under GDPR, we are required to regularly refresh consent, where required, in this case for electronic communication under PECR.

Consent for SMS communications will be refreshed no more than 5 years after original collection.
This is based on 1 Full Term Parliamentary Cycle.

Consent for email communications will be refreshed no more than 15 years after original collection. This 15 year period is based on 3 Full Term Parliamentary Cycles. In the interim, Liberal Democrat Expand will ensure that email addresses are kept accurate and that the individual continues to engage with the Liberal democrat Expand email communications. All communications from Liberal Democrat Expand will include instructions as to how to stop receiving them.

 

5. Contact Data for Press and Media

Proposed Retention Period: 15 years from collection
Refresh Period: 5 years from collection

We have a legitimate interest to contact press and media about the democratic engagement activities of the Party. We will keep this information for 15 years based on 3 Full Term Parliamentary Cycles. We will ensure that the data is kept up to date with 5-year cycles of refreshing contact details from the date on which the contact details were obtained.

6. Special Category Data

Proposed Retention Period: 15 years from collection

The GDPR defines Special Categories of Data, specifically, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

 

Liberal Democrat Expand y is required to obtain explicit consent to process this data. This may be, for example, for campaigning, Diversity monitoring, supporting the needs of event attendees, etc.

As best practice, Liberal Democrat Expand will request consent when collecting Special Categories of Data, irrespective of whether consent has been previously received from that individual.

Liberal Democrat Expand will ask to refresh consent on Special Categories of Data for individuals who are not members of the Liberal Democrat Expand, other than political opinions, no more than 15 years after last receiving consent. If refreshed consent is not received within 15 years of the Party last receiving consent, the Special Category Data will be deleted. This 15-year period is based on 3 Full Term Parliamentary Cycles.

For members of Liberal Democrat Expand, data will be retained in line with Contact and Personal Data above. For Political Opinions, data will be retained in line with details given above.

8. Cookies

Proposed Retention Period: 5 years
Cookies will be set to expire no longer than 5 years from being accepted on our websites.

9. Customer Services Telephone Recordings

Proposed Retention Period: 3 months
All calls to Customer Services are kept for 3 months for quality and training purposes. Recordings will be deleted after this period.

 

10. Statistical and anonymised Data

Data may be anonymised and/or aggregated statistically and retained for longer than the periods outlined above. This will be, for example, for Diversity Monitoring, Campaign Modelling, training, etc. In these situations, care will be taken to ensure that individuals cannot be identified from any of the data held on them, or through combination with other data held throughout the Liberal Democrat Expand.

Questions and queries

Any questions you have about this policy should be directed to info@libdemexpand.co.uk