Privacy Policy

This is a privacy policy for the Democratic Unionist Party. The homepage of our website can be found at www.mydup.com

We have a specific privacy policy for staffing.

The policy has been created in order to demonstrate the Party’s commitment to the protection of your data and to be transparent on how we deal with it.

The Party will process your data in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

This privacy policy was amended and published on 26th July 2021.

It will be reviewed annually along with other data protection policies and procedures, or earlier if there are changes to processing systems, legislation or Data Protection Impact Assessments.

Contacting Us about Data Protection:

If you have any questions about our privacy policy, about how we use your data or would like to exercise any of your rights you can contact our Data Protection Officer

By post at:
91 Dundela Avenue
Belfast
BT4 3BU

By Email at:
[email protected]

By Phone on:
+44 (0) 2890 471155

How we may collect personal data about you:

The Party may collect personal data via means such as:

• In person, when you speak to one of our representatives or volunteers.
• Through a telephone call, either where you call us or we call you
• On paper, such as if you return a printed survey or a reply slip on a leaflet
• Digitally, such as if you fill in a form on a website or interact with the party online
• When you offer or ask about volunteering, or take part in party activities.
• When you enter into a transaction with the party, such as donating, joining as a member or supporter, or paying for an event.
• Indirectly from other public records or sources, including the full electoral register which the party is legally entitled to.
• We may also use data from other public sources such as the Land Registry or Companies House. We do so where those sources are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources. This may include, for example, checking the eligibility of a potential donor.

What type of information do we collect?

• Name
• Date of Birth
• Contact Details (e.g. address, email address, telephone number, mobile number, social media)
• Future communication preferences
• Information about your financial transactions with the Party

We may also collect special categories of information such as:

• Political opinions, including topics you are interested in.
• Voting intentions

How we may use your personal data and why we are allowed to use it.

How your data is used is protected by law and we only use your data where we have an acceptable reason for doing so.

The reasons we may process your data are:

• In pursuit of an activity that supports or promotes democratic engagement (Public Interest), or
• When it is our legal duty (legal obligation), or
• When you provide consent (consent), or
• When we have a legitimate interest (legitimate interest).

The law restricts the processing of what is termed “special categories of personal data”. The work of the Democratic Unionist Party and the wider Democratic Unionist Party is deemed to be of substantial public interest and therefore we are permitted to process special categories of personal data relating to your political opinions and voting intentions.

Below lists examples of how we use your data and our justification and legal basis for it.

• Canvass Political Support
  In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to identify supporters of the Party.

• Contact you about issues or queries that you have told us about
  In pursuit of an activity that supports or promotes democratic engagement and our legitimate interests to engage with the electorate.

• Process and record voting intentions and political opinions
  In pursuit of an activity that supports or promotes democratic engagement and our legitimate interest to understand the electorate and identify Party supporters.

• Send you surveys and process your responses
  In pursuit of an activity that supports or promotes democratic engagement.

• Process your application for membership
  Contractual necessity and our legitimate interest in engaging with our membership base.
  Details of the Mailchimp platform used for online applications are included within the section on our service providers.

• Process your donation and checking your eligibility to donate
  We have a legitimate interest to process your donation and a legal duty to check your eligibility to donate more than £500.

• Assess suitability of prospective members and donors using publicly available sources.
  We have a legitimate interest to ensure that our members and donors will not bring the Party into disrepute.

• Send you electronic messages about the work of the Party
  When you subscribe to our email newsletter you are providing us with your consent to process your data for these purposes. More details about the Mailchimp platform used for this are included below in the section on our service providers.

Any personal information collected by the Party will be processed and stored exclusively for the purposes of the Democratic Unionist Party. Depending on how and why you provide us with your personal data it may be shared within the Party and our elected representatives.

We may use named third-party service providers to process and store personal data.

You will always have the opportunity to opt out of communications from us at any time or to exercise any of your legal rights.

Some data may be stored by a service provider outside of the European Economic Area. Where we transfer your data to a service provider outside the EEA we seek to ensure that appropriate safeguards are in place to make sure your personal data is held securely and your rights as a data subject are upheld.

Members

If you join the Party we have a legitimate interest in processing your data and contacting you about all aspects of your membership, including information about your entitlements as a member and of Party events; either by post or by electronic means. Membership data will be shared between the central party and the relevant local Branch/Association. The party is run by its members and therefore we have a legitimate interest in member engagement and retention.

If you do not renew your membership we will continue to send you information about the Party for a reasonable period. We also have a legitimate interest to retain your data after membership lapses, as well as a legal duty to keep a record of the financial transition. We will endeavour to remove details of lapsed members after five years of their last active payment.

Applications and membership data are collected and stored using sheepCRM from Authentic Digital (www.authenticdigital.co.uk). More details are available in the section on our service providers.

Members can access and amend their data via the Members section of the Party website. There is an option to upload a photograph to your membership profile. This may aid with party events etc.

Donors

If you donate money to the Party then we have a legitimate interest in processing and retaining your information and to contact you about our fundraising activities either by post or electronic means. We justify this because our activities are funded by donations. For donations over certain thresholds we also have a legal obligation to report it to our regulator, the Electoral Commission, who will publish certain details on their website.

Online donations can be made via PayPal or Stripe. More details are available in the section on our service providers.

Service Providers

Mailchimp (The Rocket Science Group)
We use Mailchimp to manage our email newsletter subscriber lists and to collect data necessary to process online applications for Party membership.

Alongside the details submitted in the capture form on the website, Mailchimp will collect data including:

• Location - based on your IP address when you interact with emails and signup forms
• Preferred email client
• Details of email opening and links clicked.
  
  Read their privacy policy
  https://mailchimp.com/legal/privacy/

Google
We use Google Analytics on our website to measure the performance of the Party website. The users I.P address will be logged and details of visitor behaviour patterns monitored. This information is only processed in a way which does not identify anyone.

Information collected include:

• Time of visit, pages visited and time spent on each page.
• Referring site details.
• Type of web browser
• Type of operating system (OS)
• Flash version, JavaScript support, screen resolution and screen colour processing ability.
• Network location and IP address.

Read more about how Google uses data here:
https://policies.google.com/technologies/partner-sites?hl=en-GB&gl=uk

PayPal & Stripe
We use PayPal and Stripe as a facility to make online donations. Information stored will include name, email address and the amount donated. For donations over £500 you must be a permissible donor. We may use the data provided to either contact you, or to check publicly available records to check permissibility of the donation. All donations made via the Party website will be to the central Party, and donations over £7,500 will be reported to the Electoral Commission and will be published by them.

Read their privacy policy
https://www.paypal.com/en/webapps/mpp/ua/privacy-full
https://stripe.com/en-gb/privacy

ActionPoint
They provide our email service and host this website.

Vertical Structure
They host this website.

Cookies

Please visit our cookies page for information on cookies used by this site.
http://www.mydup.com/cookies

Other websites

Our website links to other sites, but it will be clearly identifiable where this is the case. Please note we are not responsible for the privacy practices of other sites. Make sure you read their privacy statements if you are concerned about the information they are collecting about you. This statement only applies to our website.

Opting Out / Unsubscribing

Email Updates - You can opt-out of receiving email updates at any time using the “unsubscribe” link in each email we send or using the contact details at the top of this privacy notice.

Membership - You can cancel your Party membership at any time using the contact details at the top of this privacy notice.

Access to your data

You have the right to request a copy of any personal information that we hold about you. This is commonly known as a Subject Access Request.

More information on submitting such a request can be found here:
https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/preparing-and-submitting-your-subject-access-request/

This may entitle you to a copy of the personal data that we hold about you. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

Right to Portability

In certain cases where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Right to Object

You have a right to opt out of our data being used for direct marketing.

If we process your data on the basis of “legitimate interests” or “a task carried out in the public interest” then you have the right to object us using your data in that way. This right is not absolute and we may continue to process your data if we can demonstrate compelling legitimate grounds for the processing.

Correcting / Updating Information

If you need to change your email address on our mailing list you can unsubscribe and sign-up again using new information. Other information can also be amended online or by contacting the party via the contact details listed above.

Deletion of Data

We will retain your data for as long as it is required to meet the purposes set out in this notice, unless a longer retention period is required by law.

Data from those who have unsubscribed from our email newsletter mailing list will remain on the database afterwards. All data for those who have unsubscribed will be periodically deleted. This process will take place at least once every calendar year.

Details of those who have applied for membership online remain on the database, whether the application has been successfully completed or not. Data will remain on the database for at least twelve months following the date of application but will be deleted at some point during the following twelve months.

Anyone who wishes their data to be deleted earlier than this can contact the party using the details above and make a request for this to happen. There may be good legal reason for us to continue to hold all or some of the data that you have asked us to erase. If this is the case we will tell you what that reason is at the time we respond to the request.

Lodging a Complaint

If you have a complaint about any issue related to your data you can submit a complaint to the party, addressed to the Chief Executive, to the party’s contact details listed above.

The supervisory authority for the United Kingdom is the Information Commissioner’s office. They can be contacted at:
https://ico.org.uk/