Data Protection Policy and Privacy Notice
This document outlines how the Office of Cat Smith processes and manages personal data. It:
- identifies our data controller;
- provides our lawful basis for processing personal data;
- outlines the scope of personal data we hold and process;
- outlines the scope of the special category personal data we hold and process;
- describes and justifies our data retention policy;
- shows how we intend to respond to Subject Access Requests; and
- contains a copy of our privacy notice
- Data Controller
The Data Controller is Cat Smith.
- Lawful basis for processing
i. Casework is processed primarily under the lawful basis of public task, with exceptional cases processed under the lawful basis of consent and contractual arrangements with third party service providers.
ii. We undertake to always act within the reasonable expectations of our constituents and any other individuals about whom we hold personal data.
- Data we hold
We operate a paperless office. All of our personal data is therefore stored electronically and securely on our computer system.
The Office uses a CMS (Content Management System) application, Caseworker.MP, to help with the management of constituent casework records. This information predominantly includes but is not limited to:
- Names, addresses and email addresses
- Telephone numbers
- National Insurance Numbers, Passport Numbers
- Special category data as outlined in point 4
Policy casework is stored in a folder system on Microsoft Outlook.
This information predominantly includes but is not limited to:
- Names, addresses and email addresses
- Telephone numbers
- Special category data on political beliefs
The Office may maintain mailing lists for purposes of contacting individuals.
Mailing lists for the purpose of updating constituents and other non-political activities relating to the proper functioning of an MP office. The information contained in these newsletters is non-political and is therefore processed under the lawful basis of public task.
We may operate other mailing lists for other purposes, including party political messaging. The personal data in these mailing lists are therefore processed under the lawful basis of consent
Personal data we hold in this regard may include:
- Names, addresses, occupation and email addresses.
Subscribers are able to opt out from these newsletters at any time.
- Special category data we hold
The office may also hold special category data for a smaller number of data subjects. This data will be processed under the lawful basis indicated in point two, as is permitted in clauses 23 and 24 of schedule 1 of the Data Protection Act 2018. The data may include:
- Political opinions
- Religious beliefs
- Trade union activities
- Sexual orientation
- Race and ethnic origin
- Details of criminal offenses
- Physical and mental health
- Data retention policy
We will keep personal data for as long as we deem necessary for the proper execution of duties as an MP office in accordance with our Data Protection Policy and Privacy Notice.
Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. We therefore feel it is reasonable for an elected representative to hold personal data for as necessary in order to carry out the proper execution of MP office duties.
- Subject Access Requests
We will comply with Subject Access Requests in line with the guidance given by the Information Commissioners Office (ICO).
i. We will respond as quickly as possible, within 30 calendar days.
ii. We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
iii. Data subjects have the right to the following:
a. To lodge with this office a Subject Access Request free of charge
b. To be told whether any personal data is being processed
c. To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people.
d. To be given a copy of the information comprising the data, and given details of the source of the data where this is available.
- Privacy notice
Our office will undertake to ensure all constituents sharing their personal data can have the opportunity to read our privacy notice. We will:
i. Publish our privacy notice on Cat’s website, www.catsmith.co.uk
ii. Add a link to our privacy notice to staff email signatures, and to Cat’s email signature.
iii. Add a link to our privacy notice on Cat’s auto-response on Microsoft Outlook.
iv. Direct constituents who contact us via letter and telephone to our privacy notice online, of supply them with a paper copy if needed.
This privacy notice relates to the personal data processed by the Office of Cat Smith, PPC for Lancaster and Fleetwood, in relation to casework and policy queries.
Who is the Data Controller?
The Data Controller is Cat Smith, PPC for Lancaster and Fleetwood.
What does the Office do?
The office discharges the duties and functions of an elected Member of Parliament. As part of this work, we conduct constituency casework and respond to policy queries, for which we must process personal data of our constituents. We also manage two, small mailing lists for the purpose of sending regular newsletters.
How do we process data?
This office processes constituents’ data under the lawful basis of public task. In instances where this lawful basis is not sufficient and explicit consent is required, a member of the office will contact you to establish your consent.
For newsletters, the data processed in mailing lists for purposes of updating constituents and other non-political activities relating to the proper execution of MP office duties is processed under the lawful basis of public task.
The data processed in other mailing lists for purposes other than for non-political activities relating to the proper execution of MP office duties, such as party political messaging, is processed under the lawful basis of consent.
We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Will we share your data with anyone else?
If you have contacted Cat about a personal or policy issue, we may pass your personal data on to a third-party in the course of dealing with you, such as local authorities, government agencies, public bodies, health trusts, regulators, and so on. 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. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures.
We will not share the personal information of subscribers of the newsletter mailing lists.
In any case, we will not use your personal data in a way that goes beyond your reasonable expectations in contacting us.
For how long will you keep my personal data?
Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. We therefore believe it is reasonable for an elected representative to hold personal data for as long as deemed necessary for the proper execution of duties an MP office.
What rights do I have to my personal data?
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- 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 – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing, such as direct marketing.
- Right to make a complaint – you have the right to submit a formal complaint to the Information Commissioner’s Office by writing to:Information Commissioner’s Office
Water Lane, Wilmslow
Cheshire, SK9 5AF
Or follow the link to their website: https://ico.org.uk/
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: if our office refuses your request under rights of access, we will provide you with a reason why. You have the right to complain.
How can I contact somebody about my privacy?
You can get in touch with our office by letter, email or telephone using the details at the end of this document.
Please note that we will ask for identification should you choose to exercise any of the above rights in relation to personal data we hold.
Office of Cat Smith
Parliamentary Candidate for Lancaster and Fleetwood
House of Commons
Tel: 0207 219 6001