This document outlines how the Office of Rt. Hon. Sir Desmond Swayne TD MP processes and manages personal data. It:
1) identifies our data controller;
2) provides our lawful basis for processing personal data;
3) outlines the scope of personal data we hold and process;
4) outlines the scope of the special category personal data we hold and process;
5) describes and justifies our data retention policy;
6) shows how we intend to respond to Subject Access Requests; and
7) Our privacy notice.
The policies outlined within this document come into full effect on Friday 25th May 2018.
1. Data Controller
The Data Controller is Rt. Hon. Sir Desmond Swayne TD MP.
2. 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.
ii. Personal data contained in the non-political Sir Desmond Swayne’s MP Mailing List is processed under the lawful basis of public task. It does not fall within the definition of direct marketing.
iii. We undertake to always act within the reasonable expectations of our constituents and any other individuals about whom we hold personal data.
3. Data we hold
We operate a paperless office. Personal data is stored electronically and securely on our computer systems. Our systems are in offices which are locked when unattended.
Casework
The Office uses Cross Reference 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.
• copies
Data Protection Policy v.1.4 – 30th April 2018
• National Insurance Numbers, Passport Numbers.
• Special category data, outlined in point 4.
Policy
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 issues.
Mailing lists
– We do not have mailing lists. We use the open electoral register to identify 18 year olds: This information is not political in nature and therefore it is not categorised as direct marketing.
4. 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. 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
5. Data retention policy
Our office will hold personal data for no longer than is necessary to close constituency casework that constituents have brought to my attention.
Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. Therefore, I feel it is reasonable for an elected representative to hold personal data for the duration of the period that I remain their parliamentary representative.
6. 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 be told whether any personal data is being processed
b) 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.
c) To be given a copy of the information comprising the data, and given details of the source of the data where this is available.
7. 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 Sir Desmond’s website, www.desmondswaynemp.com
ii. Add a link to our privacy notice to staff email signatures, and to Sir Desmond’s email signature.
iii. Add a link to our privacy notice on Sir Desmond’s auto-response on Microsoft Outlook.
iv. Direct constituents who contact us via letter and telephone to our privacy notice online
v. Modify our voicemail messages to include information about how constituents can read our privacy notice.