Last Updated: 1st March 2024
When collecting data for the Liberal Democrats, the single most important thing to remember is that there should always be a Fair Processing Notice (FPN) on all literature, publications and websites that collect data. This should become as much of a default for the party as the Imprint / Impression on our literature.
We should always take the latest version of Fair Processing Notices from this page.
There are different Fair Processing Notices that cover the following scenarios:
In addition, there is wording for when consent is required to gather data.
As outlined above, the main thing to do when collecting data is to provide a Fair Processing Notice. This informs the individual about how we will handle their data, points them back to our main Privacy Notice and gives them our contact details.
As outlined above, the correct Fair Processing Notice needs to be used when collecting data
Fair Processing Notice | Notes | Examples |
Printed on online publications | The Fair Processing Notice always has to be provided on the page where data is being collected. Consent wording for email, telephone numbers and special category data | Online or paper surveys, petitions, grumble sheets, casework, street stall sign in sheets, event sign in sheets, donation forms
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Telephone Calls | There is no need to read out a Fair Processing, but consent needs to be explicit if email addresses, mobile numbers or special category data is collected (see below) | Telephone canvassing,
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Face to face / Doorstep data collection | A leaflet with the Fair Processing Notice should ALWAYS be handed over if data is collected. If the leaflet is refused, we cannot record the data. Where consent is refused by a request or assertion to not knock again, this should be recorded as Do Not Doorstep in Connect / MiniVAN. Consent wording when collecting email, telephone numbers and special category data. | Canvassing, Knock Up,
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Alternatives to the above, when offering a service where there is an exchange of money, other than donations. | The Fair Processing Notice always has to be provided on the page where data is being collected. Consent wording when collecting email, telephone numbers and special category data. | Conference registration Social Event, e.g., dinner registration Not donation forms, use standard non verbal FPN.
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As outlined above, when collecting data on the door step or face to face, for example, for canvassing, knock up, street stall or casework, a Fair Processing Notice must be provided.
We recommend a calling card or leaflet, that includes your local campaigning messages and also includes the appropriate Fair Processing Notice.
This leaflet should always be handed over as part of the doorstep or face to face conversation. If the leaflet is not provided, then the data cannot be recorded and used.
Whilst many assume that UK GDPR is primarily about consent, the reality is that there are many legal reasons we can collect data. The Party has identified lawful bases for handling the vast majority of data we collect without consent. See below for further details.
There are only a few scenarios where we need to get explicit consent for collecting and using data. These are:
Under the Privacy and Electronic Communication Regulation (PECR), we need to have consent for marketing via email. We can campaign and communicate by physical mail without consent. And we can also campaign and communicate by telephone calls, but only if we honour Telephone Preference Services (TPS) registration. We can gather telephone consent that overrides TPS registration.
The definition of marketing covers all forms of campaigning and promotion activity the Party carries out, and consent should always be obtained when collecting this information. Email addresses and phone numbers gathered during the processing of casework, cannot then be used for further campaign direct marketing unless explicit consent has been given.
Consent under UK GDPR must be:
If you receive an opt-in for a Local Party, then you can add that email to a Ward or Branch specific email list. However you cannot do the opposite. An email addresses added to a Branch or Ward list should not be added to a Local Party list. In general opt-ins can flow down through the party structure, but not up.
The appropriate Fair Processing Notice must be included whenever collecting data, whether it requires consent or not. Learn more here.
Collecting Consent for Special Category Data
Special category data is more sensitive, and so needs more protection. For example, information about an individual’s:
We recommend you contacting the Data Protection Officer data.protection@libdems.org.uk if you feel it necessary to collect special category data before creating your survey/letter/email. The DPO can review your wording and advise on any changes to ensure you are collecting the information lawfully.
This type of data could create more significant risks to a person’s fundamental rights and freedoms. For example, by putting them at risk of unlawful discrimination.
For special category data, you will need to gather the consent close to where the questions are situatied on the page. It should always use granular, affirmative consent, with either unticked check boxes or Yes / No options:
Tick boxes:
Yes/No Buttons:
*delete as appropriate
When recording Consent, we need to record:
We only need to keep a track of those Fair Processing Notices where we are required to collect Consent.
Recording Consent in Connect
In Connect, it’s important to store both the consent(s) given and the relevant survey/communication that was used. For every script you use to gather consent, you need to have the appropriate opt-in questions and the relevant FPN on the script.
Withdrawing Consent
Individuals have the right to opt out of communication or processing of their data at any time. Withdrawal of consent must be as easy as providing consent. These requests MUST be acted on within one month.
The standard opt out page for withdrawing Consent can be found here.
If consent is withdrawn face to face, on paper forms, or on a telephone call, you should:
Collecting Data as an Elected Representative or on their behalf
Elected representatives are Data Controllers in their own right. When they collect data as an elected representative, they must follow the guidance provided by their parliament, council, assembly or appropriate body. A clear separation must be maintained between Liberal Democrats Data and their data.
Sharing Data from the Lib Dems to Elected Representatives
The wording of our Fair Processing Notices and Privacy Policy allows for the sharing of data with elected representatives, but not for email and telephone unsolicited direct marketing. This wording allows for activists to collect casework, and contact information for casework and pass it on to Councillors, MPs and other elected representatives to assist the public with their local issues and concerns.
The contact details collected cannot then be used by the elected representative for marketing, unless the individual provides separate consent for that purpose.
Sharing Data from Elected Representatives to the Liberal Democrats
Data cannot be shared by an Elected Representative to the Liberal Democrats. In particular contact details such as email addresses and phone numbers cannot be added to email distribution lists for the Party’s campaign.
The individual must specifically opt in to being contacted by the Party. For example, once a casework issue is resolved, you may want to email the individual and ask:
“I would like you keep you up to date on my work in the Liberal Democrats. Please click here to sign up to my Liberal Democrats mailing list.”
This should then link to an email sign up page on your Lib Dem website, which includes the relevant Fair Processing Notice and appropriate consent wording.