Guidance

Privacy notice: ERO Contact Register for use by the Department for Levelling Up, Housing and Communities

Updated 27 September 2022

© Crown copyright 2022

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This publication is available at https://www.gov.uk/government/publications/privacy-notice-email-distribution-list-for-modern-registration-division/privacy-notice-email-distribution-list-for-modern-registration-division

1. Your data

1.1 Purpose

The purpose for which we are processing your personal data is to communicate important information about the Individual Electoral Registration (IER) Digital Service (and Canvass Data Match) and the Department for Levelling Up, Housing and Communities (DLUHC) to key stakeholders. These communications include newsletters and one-off notifications.

We may also use your data to invite you to participate in research (including surveys or focus groups). The purpose of collecting your data through research is to better inform policy making around electoral processes, or operational decision making concerning the IER Digital Service and Canvass Data Match.

1.2 The data

The data will be collected by the IERDS/CDM team who will be regularly refreshing this data on a 3 to 6 month cycle.

We will process the following personal data for our contact register:

  • first name
  • last name
  • role within local authority
  • email addresses
  • contact telephone number

In addition, if you agree to participate in research that you are invited to take part in, we may also process the following:

  • ethnicity and other special category/sensitive etc (if we do research related to these characteristics)
  • where you participate in research, your opinions or any other data that you volunteer

In the event of your participation in qualitative research, we will ask for your separate consent if these are voice or video recorded.

You will not be personally named in any analysis, but we may use anonymised quotes in reports, and information may be attributed to, for example, types of local authorities eg ‘urban’, South East.

The legal basis for processing your personal data is that processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. In this case that is to communicate important information about the IER Digital Service and Canvass Data Match to key stakeholders, such as electoral administrators, about service downtime etc. It is also used to communicate general updates about project work that is ongoing within the Constitution Group and to ask for input from electoral administrators in research.

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, health, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Our legal basis for processing any sensitive personal data that you volunteer through a survey is that processing is necessary for reasons of substantial public interest for the exercise of a function of a government department (paragraph 6, schedule 1, DPA 2018).

The legal basis for processing voice/video recordings is that you will have freely and explicitly given your consent.

1.4 Recipients

Your personal data will be shared by members of the Constitution Group with GOV.UK Notify, who we use to send emails, IT suppliers who help us to provide that service, and any contracted third-parties assisting with our research. In the event of any further data sharing with other government departments, this will be covered by separate and explicit data sharing agreements confirming the use of this data for a specific purpose.

As your personal data will be stored on our IT infrastructure it will also be shared with our data processors who provide email, and document management and storage services.

2. Retention

Your personal data will be kept by us for as long as you wish to receive communication from Constitution Group. For operational reasons, contact details for key Electoral Registration staff are required for as long as they are in post.

If you respond to a survey then we will keep your data in identifiable form for no more than 2 years, and then in an anonymised format for up to 7 years. Voice recordings and consent forms will be kept up to 3 months after analysis is complete, after which they will be permanently deleted. Recordings may be transcribed to enable analysis, and these will be kept for up to 7 years in anonymised form.

3. Your rights

You have the right:

  • to request information about how your personal data are processed, and to request a copy of that personal data
  • to request that any inaccuracies in your personal data are rectified without delay
  • to request that any incomplete personal data are completed, including by means of a supplementary statement
  • to request that your personal data are erased if there is no longer a justification for them to be processed
  • in certain circumstances (for example, where accuracy is contested), to request that the processing of your personal data is restricted
  • to object to the processing of your personal data where it is processed for direct marketing purposes
  • to object to the processing of your personal data

Where data is processed with your consent, you have the right to:

  • you have the right to withdraw consent to the recording of your personal data at any time

4. International transfers

As your personal data is stored on our IT infrastructure, and shared with our data processors, it may be transferred and stored securely outside the UK. Where that is the case it will be subject to equivalent legal protection through an adequacy decision or the use of Model Contract Clauses.

5. Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

6. Contact details

The Department for Levelling Up, Housing and Communities (DLUHC) is the data controller. The Data Protection Officer can be contacted at:

Data Protection Officer
Department for Levelling Up, Housing and Communities
Fry Building
2 Marsham Street
London
SW1P 4DF
dataprotection@levellingup.gov.uk

The Data Protection Officer provides independent advice and monitoring of DLUHC’s use of personal information.

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