Fair Processing Notices

Last Update: February 2023

Under the UK GDPR, individuals have the right to be informed about the collection and use of their personal data. We do this in a number of ways including our main Privacy Policy but we also need to make sure we provide individuals with this information at the point of collection; we call these fair processing notices or just-in-time notices.

Please read the information below which we hope will help you to understand how FPNs should be used. Please email Data.Protection@libdems.org.uk if you have any queries about the FPNs.

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, provides a link to the full privacy policy and details of how they can contact us.

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?

It is a legal requirement under the UK GDPR to provide individuals with information about how you will process their personal data at the time you collect the personal data from them. We need to ensure that when individuals hand over their personal data to us, they give clear consent for us to use the data for a specific purpose, know how to exercise their legal rights to that data and understand how their data will be used.

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.


Where on the FPNs below there is a field in bold this indicates the individual entering their information needs to make a choice.

Where on the FPNs below there is a field in italics this indicates you need to include the appropriate option in the notice.


Written material where data is gathered (inc. electronic communications)

The text in the box below shall be used on all occasions when personal data is gathered by or on behalf of the party by non-verbal means, e.g. online form, printed survey, petition leaflet, provision of a service (conference registration, purchase of a ticket to a dinner etc).

Wording must be clearly displayed either near to the location where data is entered/recorded by the individual 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.

When an individual enters their email address or telephone number for electronic communications themselves, under Privacy and Electronic Communications Regulations (PECR), this is known as ‘active consent’. The following wording can be used below the text field on the form where the data has been entered.


Can we keep you updated about the Liberal Democrats’ campaigns and ways to get involved?
Yes
No
The Liberal Democrats may use the information you provide, including your political opinions, to further our objectives and share it with our elected representatives. Any data we gather will be used in accordance with our privacy policy: libdems.org.uk/privacy. You can exercise your rights and withdraw your consent to future communications by contacting us: data.protection@libdems.org.uk or: DPO, Lib Dems, 1 Vincent Square, SW1P 2PN.

PETITIONS

If you plan to submit the petition to a body outside the Liberal Democrats, for example the local council, you need to tell people that using the FPN below.


Can we keep you updated about the Liberal Democrats’ campaigns and ways to get involved?
Yes
No
We will include your name and/, address/postcode and signature [if applicable] when submitting and sharing the petition with NAME OF ORGANISATION.
The Liberal Democrats may use the information you provide, including your political opinions, to further our objectives and share it with our elected representatives. Any data we gather will be used in accordance with our privacy policy: libdems.org.uk/privacy. You can exercise your rights and withdraw your consent to future communications by contacting us: data.protection@libdems.org.uk or: DPO, Lib Dems, 1 Vincent Square, SW1P 2PN.

SURVEYS

Use the FPN below on surveys.


Can we keep you updated about the Liberal Democrats’ campaigns and ways to get involved?
Yes
No
The Liberal Democrats may use the information you provide, including your political opinions, to further our objectives and share it with our elected representatives. This forms part of our activities that promote democratic engagement with electors, under the lawful basis of public task. Any data we gather will be used in accordance with our privacy policy: libdems.org.uk/privacy. You can exercise your rights and withdraw your consent to future communications by contacting us: data.protection@libdems.org.uk or: DPO, Lib Dems, 1 Vincent Square, SW1P 2PN.

Collecting data verbally

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.

FACE TO FACE

Use this if you collect a phone number/email during the conversation.

Offer them calling card and say:


Thank you for sharing your email / phone / mobile. Can we keep you updated about the Liberal Democrats’ campaigns and ways to get involved?
Yes
No
(If yes, followed by:)
Thank you. You can withdraw your consent at any time by contacting us by email data.protection@libdems.org.uk or by post to DPO, Lib Dems, 1 Vincent Square, SW1P 2PN. Any data we gather will be used in accordance with our privacy policy: libdems.org.uk/privacy.

TELEPHONE CALLS

Use this if you collect a phone number/email during the conversation


Thank you for sharing your email / mobile. May we use that/them to contact you about our campaigns and ways to get involved in future?
Yes
No
(If yes, followed by:)
Thank you. You can withdraw your consent at any time by contacting us by email data.protection@libdems.org.uk or by post to DPO, Lib Dems, 1 Vincent Square, SW1P 2PN. Any data we gather will be used in accordance with our privacy policy: libdems.org.uk/privacy.

Calling Cards/Canvass Leaflets

If you are collecting any data in person eg: voter intention, please use the following wording on the card/leaflet you hand over.


As a registered national political party, The Liberal Democrats are entitled to a copy of the full Electoral Register under the Representation of the People Regulations 2001, for the purpose of democratic engagement. For information about how we process personal data, please see our privacy notice libdems.org.uk/privacy and to exercise your rights and to stop receiving mail from us, email: data.protection@libdems.org.uk or write to us: DPO, Lib Dems, 1 Vincent Square, SW1P 2PN.

Direct Mail/Addressed Leaflets (when no data is being gathered)

Where no data is being gathered please use the following wording as best practice to inform individuals about why they have received communication from us and how they can exercise their rights. We strongly recommend using this during the General Election period and when high volume mass communications are being sent.


The Liberal Democrats obtained your name and address from our copy of the full Electoral Register, which we are entitled to under the Representation of the People Regulations 2001 for the purpose of democratic engagement. For information about how we process personal data, please see our privacy notice libdems.org.uk/privacy and to exercise your rights and to stop receiving mail from us, email: data.protection@libdems.org.uk or write to us: DPO, Lib Dems, 1 Vincent Square, SW1P 2PN.