Last Update: 7 February 2020
As you will see if you have been campaigning with the Lib Dems for a while, the Fair Processing Notices are changing. Please read the information below which we hope will help you to understand how FPNs should be used and why they need to change. Please email [email protected] if you have any queries about the FPNs. Details of data protection training webinars for volunteers are advertised in the monthly LPO Newsletter.
What is a Fair Processing Notice? (FPN)
A Fair Processing Notice (FPN) is a notice given to individuals when you gather their personal data. The notice explains how their data will be used, how they can exercise their legal rights over their data and provides a link to the full privacy policy.
When should FPNs be used?
You must provide an FPN every time you gather personal data from an individual.
Why do we need to use FPNs?
The GDPR has made it a legal requirement to provide individuals with information about how you will process their personal data at the time you collect the personal data from them.
How should an FPN be provided?
An FPN can be provided either verbally or in writing. The FPN must be offered before you gather any personal data from the individual.
Why are the FPNs changing?
In September 2019 Lib Dem HQ was audited by the ICO (Information Commissioners Office) and was given a number of recommendations to implement in order to reach the standard of data protection compliance that the ICO expects from us. One of these recommendations was to change the Fair Processing Notices to ensure that when individuals hand over their personal data, they give clear and explicit consent for us to use the data for a specific purpose and that the individual is clear about how their data will be used.
This is the formal list of FPNs. For details about how to use these in context, please see our guidance on Data Gathering and Consent.
Where on the FPNs below there is a field in bold/italics this indicates;
- A link should be added
- For petitions; the name of who it is being submitted to
- an And/Or choice needs to be made.
Fair Processing Notice for all non-verbal material
The following text shall be used on all occasions when data is gathered by or on behalf of the party by non-verbal means, e.g. online form, printed survey, petition leaflet, etc. The wording must be displayed legibly either near to the location where data is entered/recorded by the member of the public or near to the return mechanism (e.g. where a postal return address is given or a submit button for an online form). Please note that additional tick boxes can be added for other contact categories if relevant.
Can we keep you updated about our activities including campaigns, events, fundraising and details about how to get involved?
Yes please ⬜ No thanks ⬜
The Liberal Democrats will use your contact details to send you information on the topics you have requested. Any data we gather will be used in accordance with our privacy policy at libdems.org.uk/privacy. To exercise your legal data rights, email: [email protected].
Surveys/Petitions
Can we update you about the progress of this petition/survey?
Yes please ⬜ No thanks ⬜
Can we keep you updated about our activities including campaigns, events, fundraising and details about how to get involved?
Yes please ⬜ No thanks ⬜
For petitions: We will include your name and/, address and signature [if applicable] when submitting and sharing the petition with NAME.
The Liberal Democrats will use your contact details to send you information on the topics you have requested. Any data we gather will be used in accordance with our privacy policy at libdems.org.uk/privacy. To exercise your legal data rights, email: [email protected]
Fair Processing Notice for telephone calls
Thank you for sharing your email/mobile. May we use that/them to contact you about our campaigns and activities in future?
If yes, followed by:
Thank you. You can unsubscribe at any time. Full details of your rights and how we may use your personal data are in our privacy policy at libdems.org.uk/privacy
If Contact is related to a service
If data is gathered by non-verbal means or by telephone calls, and the communication involves the provision of a service – defined here as a transaction involving money that is not a donation, e.g. conference registration, purchase of ticket to a dinner
May we also use your email/phone number to contact you about our campaigns and activities in future?
if yes, followed by:
Thank you. You can unsubscribe at any time. Full details of your rights and how we may use your personal data are in our privacy policy at libdems.org.uk/privacy.
Face to Face
Offer them calling card and say:
Thank you for the details you have provided. If a landline phone number, mobile phone number or email address is secured, in addition say:
Thank you sharing your email / phone / mobile. May we use that/them to send contact you about our campaigns in future?
You can unsubscribe at any time. Full details of your rights and how we may use your personal data are in our privacy policy at libdems.org.uk/privacy.
The script /data capture form being used for such conversations must include a question for recording that a ‘yes’ was given, and this data must always be recorded when received.
Consent Wording for online email and telephone number collection
Where entering an email address or telephone number (for SMS) for electronic communications under PECR is being taken as active consent, then the following wording can be used above the text field on the form where the data is being collected. This must be in addition to using the appropriate Fair Processing Notice from above.
We’d like you keep you up to date on our work. Can we use the email / phone you’ve provided to contact you in future?
Yes, keep me updated | No thanks
Calling Cards or other unaddressed leaflets/letters where no data is being gathered
The Liberal Democrats will use any personal data we collect in accordance with our privacy policy at: libdems.org.uk/privacy. To exercise your legal data rights, email: [email protected].
On an addressed letter/leaflet where no data is being gathered please use the following:
Why am I receiving this leaflet/letter?
As a registered national political party in the UK, The Liberal Democrats are entitled to a copy of the full Electoral Register under the Representation of the People Regulations 2001. The full Electoral Register is different to the open Electoral Register as it contains details of all voters in the UK, including those who have opted out of the open register. Any data we gather will be used in accordance with our privacy policy at libdems.org.uk/privacy. To opt out of receiving mail from us or to exercise your other legal data rights, email: [email protected].
