Privacy policy

This is the Privacy Policy for the Scottish National Party.

This Privacy Policy is available in other accessible formats such as Braille. If you wish to obtain a copy in an accessible format, please contact our Data Protection Officer.

This Privacy Policy has been created to demonstrate the SNP’s commitment to the protection of your data and to be transparent in how we deal with it.

The SNP will process your data in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

This privacy policy was published on 25 May 2018.

Contacting us about Information Rights:

If you have any questions about this policy or for more information about how we use your data or would like to exercise any of your rights, you can contact our Data Protection Officer at:

Scottish National Party
Gordon Lamb House
3 Jackson’s Entry
Edinburgh
EH8 8PJ

You may e-mail privacy@snp.org
You may call 0131 525 8920

What information do we collect?

The types of personal information that we may collect about you include:

  • Name
  • Date of birth
  • Contact Details (e.g. address, email address, telephone number, mobile number, social media)
  • Communication Preferences
  • Direct Marketing Preferences
  • Electoral Register Data
  • Demographic data
  • Financial transaction data
  • Opinions on topical issues
  • Issues that you raise with us
  • Interests you have
  • IP address, cookies and other technical information that you may share when you interact with our website

We may also collect special categories of information such as:

  • Political opinions
  • Voting intentions

How we collect data

We collect data about you in the following ways:

Provided by you (Directly):

  • In person, when you speak to one of our staff or volunteers
  • Through a telephone call, either where you call the SNP or we call you
  • On paper, such as if you return a printed survey or a reply slip on a leaflet
  • Digitally, such as if you fill in a form on a website or interact with the Party online via our website or social media platforms
  • When you offer or ask about volunteering, or take part in party activities
  • When you enter into a transaction with the Party, such as donating, joining, purchasing a product or paying for an event
  • When you consent to receiving marketing emails etc
  • When you attend a conference or campaign event

Third Party Sources (Indirectly):

  • Indirectly from publicly accessible sources or other public records, including the full electoral register to which the Party is legally entitled
  • CCTV, if you visit SNP Headquarters

The SNP is legally entitled to, and receives, the electoral registration records of all electors in Scotland as per Representation of the People Regulations 2001 in Scotland.  We receive an updated version of these every time an update is published, which is usually every month.

We collect data with the intention of using it primarily for political activities.

The SNP uses the data that we collect about you to build a picture of public opinion. We do this to:

  • understand the matters and issues that are likely to be of relevance and significance to you and better inform our future policies,
  • decide whether we send you our campaigning materials,
  • select what campaigning material we send to you and which messages we put on it,
  • evaluate whether we think you are likely to vote and for whom you will likely vote for during an election or a referendum.

How we use your information and why we are allowed to use it

How your data is used is protected by law and we only use your data where we have an acceptable reason for doing so. The reasons we process your data are:

  • In pursuit of an activity that supports or promotes democratic engagement (Public Interest), or
  • When it is our legal duty (legal obligation), or
  • When you provide consent (consent), or
  • In order to fulfil a contract with you (contract), or
  • When we have a legitimate interest (legitimate interest).

The law restricts the processing of what is termed “special categories of personal data”. The work of the SNP is deemed to be of substantial public interest and therefore we are permitted to process special categories of personal data relating to your political opinions and voting intentions.

The table below lists examples of how we use your data and our justification and legal basis for it.

Purpose Legal Basis and justification
Canvass Political Support In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to identify SNP supporters
Send you messages about our campaigns and policies In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to inform the electorate about what the SNP is doing
Contact you about issues or queries that you have told us about In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to engage with the electorate
Process and record voting intentions and political opinions In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to understand the electorate and identify SNP supporters
Send you surveys and process your responses In pursuit of an activity that supports or promotes democratic engagement
Process your application for membership and administration of your membership Contractual necessity and our legitimate interest in engaging with our membership base
Send you information by post about fundraising activities to support the Party In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to raise funds for the SNP.
Process your donation and checking your eligibility to donate We have a legitimate interest to process your donation and a legal duty to check your eligibility to donate amounts of more than £500
Assess suitability of prospective members and donors using publicly available sources We have a legitimate interest to ensure that our members and donors will not bring the SNP into disrepute
Send you electronic messages about our campaigns When you sign up to receive emails from the SNP you are providing us with your consent to process your data for these purposes
Identifying potential supporters using commercially available modelled data In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to identify SNP supporters
Conduct anonymised market research We have a legitimate interest to get a sense of general political opinion across Scotland

 

Our legitimate interests:

Our objective is to promote our values and to elect SNP candidates at every level of government across Scotland, or when we campaign in referenda. To do this, we rely upon the support of our members, donors, volunteers and supporters. We rely on being able to communicate and engage with the those eligible to vote in Scotland.

As a member: If you join the SNP we have a legitimate interest in processing your data and contacting you about all aspects of your membership including information about your entitlements as a member and about Party events; either by post or by electronic means. The party is run by its members and therefore we have a legitimate interest in member engagement and retention. If you do not renew your membership with the Party we will continue to send you information about the SNP, including information on how to re-join, for a reasonable period after your membership lapses. We also have a legitimate interest to retain your data after your membership lapses, as well as a legal duty to keep a record of the financial transaction.

As a donor: If you donate money to the SNP then we have a legitimate interest in processing and retaining your information and to send you marketing about our fundraising activities; either by post or by electronic means. We justify this because our activities are funded by donations.  For donations over certain thresholds we also have a legal obligation to report it to our regulator, the Electoral Commission, who will publish certain details on their website.

As a volunteer: If you volunteer for the SNP or enquire about volunteering for the Party, and are not a member, we have a legitimate interest in processing and retaining your information and contacting you about volunteering opportunities. We justify this because of the vital function that volunteers perform both during and outside of elections.

If you attend an event: If you attend one of our events such as SNP  conference or one of our social events, and are not a member of the Party, we have a legitimate interest in retaining your information and to send you marketing about future similar events which we think might be of interest to you; either by post or by electronic means. We have a legitimate interest in inviting people to our events to raise vital funds for the Party and have determined that attendees would expect to receive such communications from us.

You can always opt out of receiving any messages from the SNP or to exercise any of your legal rights.

We are committed to respecting your rights over your data and in some circumstances, we will have a legitimate interest to continue to process your data even where you have exercised one of your rights. For example, if you request that we stop processing your data for purposes of direct marketing then we justify keeping a record of this request to ensure that your wishes are respected.

Data Processed with your Consent

Where we use consent as our legal basis for processing your data, or process special categories of your data based on your explicit consent, you have the right to withdraw your consent at any time. This does not affect our right to process your data before you decide to withdraw your consent.

Who we share your data with:

We will never sell your data but sometimes it is necessary to share your information 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.

We share data with:

  • Business associates and professional advisers
  • Suppliers
  • Service providers
  • Financial organisations – such as credit card payment providers
  • Elected representatives
  • Regulatory bodies
  • Market researchers
  • Law enforcement agencies

Where we use a service provider to process your data on our behalf we will ensure that this processing is governed by a legally enforceable contract which sets out their responsibilities for protecting your data and your rights.

Transferring your data outside of the European Economic Area

Some of our service providers are located outside of the European Economic Area (EEA) and therefore it may be necessary to transfer your personal data outside of the EEA. Where we do transfer your data outside of the EEA we will make sure that it is protected in the same way as if the data was inside the EEA.

We will use one of the following safeguards to ensure this:

  • Where the European Commission has issued an adequacy decision determining that a non-EEA country or organisation ensures an adequate level of data protection.
  • A contract is put in place with the recipient of the data obliging them to protect the data to the same standards as the EEA.
  • The transfer is to an organisation that complies with the EU-US Privacy Shield.

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. Whilst we do not set finite periods for data retention we use several factors to determine whether we need to hold onto the data. Factors we take into consideration are:

  • Retention periods as required by law – for example the SNP is under a statutory duty to retain financial information for a period of 6 years,
  • The purpose for which the data was provided or obtained,
  • Our legitimate interests in holding onto your data,
  • Whether holding onto your data will infringe your rights over your data,
  • Legal and regulatory obligations that may require reference to your data,

Cookies

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 use IP addresses, URL’s of requested resources, timestamps and HTTP user-agents to analyse trends, administer the system and gather broad demographic information for aggregate use. In addition to this we use Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies, to help analyse how visitors use our site. The information generated by the cookie about the use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our website, compiling reports on website activity for the SNP and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your Web browser, however please note that if you do this you may not be able to make full use of our website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How we protect your data:

The security of your data is paramount to the Party and as such we ensure that appropriate technical and organisational measures are in place to protect it. We constantly review our measures to ensure that your data is protected from any threats that may emerge.

Your rights over your data 

Right of access to your data: You have the right to request a copy of your personal information that we hold. This is commonly known as a Subject Access Request. We follow the ICO’s “Subject Access Code of Practice” when dealing with requests for access to personal data. You can read this code by visiting https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdf

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. When we do so, we keep the bare minimum of your information to continue to respect your wishes when your personal data is next provided to us by a local authority, which is at least annually.

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.

Right to object: You have a right to opt out of your data being used for direct marketing. If we process your data based on “legitimate interests” or “a task carried out in the public interest” then you have the right to object to us using your data in that way. This right is not absolute, and we may continue to process your data if we can demonstrate compelling legitimate grounds for the processing.

Automated individual decision-making, including profiling: We may use computer software to make decisions about you or to create a profile about you. You have the right not to be subject to such a decision or to that profiling where it creates legal effects concerning you or where it significantly affects you. None of our processing falls within that category.

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 Information Commissioner’s Office are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Telephone: 0303 123 1113
Website: https://ico.org.uk/concerns/