Privacy policy

This is the Privacy Policy for Plaid Cymru – The Party of Wales.

This Privacy Policy is available in other accessible formats such as large font. If you wish to obtain a copy in an accessible format, please contact our Data Protection Officer.

This Privacy Policy has been created to demonstrate Plaid Cymru’s commitment to the protection of your data and to be transparent in how we deal with it.

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

This privacy policy was published on 29 January 2019.

Contacting us about Information Rights:

If you have any questions about this policy or for more information about how we use your data or would like to exercise any of your rights, you can contact our Data Protection Officer at:

Plaid Cymru

Tŷ Gwynfor

Llys Anson

Glanfa’r Iwerydd

CAERDYDD CF10 4AL

You may e-mail [email protected]

You may call 02920 472272

What information do we collect?

The types of personal information that we may collect about you include:

• Name
• Date of birth
• Contact Details (e.g. address, email address, telephone number, mobile number, social media)
• Communication Preferences
• Direct Marketing Preferences
• Electoral Register Data
• Demographic data
• Financial transaction data
• Opinions on topical issues
• Issues that you raise with us
• Interests you have
• IP address, cookies and other technical information that you may share when you interact with our website

We may also collect special categories of information such as:

• Political opinions
• Voting intentions

How we collect data

We collect data about you in the following ways:

Provided by you (Directly):

• In person, when you speak to one of our staff or volunteers
• Through a telephone call, either where you call Plaid Cymru 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 via our website or social media platforms
• 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, purchasing a product or paying for an event
• When you consent to receiving marketing emails etc
• When you attend a conference or campaign event

Third Party Sources (Indirectly):

• Indirectly from publicly accessible sources or other public records, including the full electoral register to which the Party is legally entitled
• CCTV, if you visit Plaid Cymru Headquarters

Plaid Cymru is legally entitled to, and receives, the electoral registration records of all electors in Wales. We receive an updated version of these every time an update is published, which is usually every month.

We collect data with the intention of using it primarily for political activities.

Plaid Cymru uses the data that we collect about you to build a picture of public opinion. We do this to:

• understand the matters and issues that are likely to be of relevance and significance to you and better inform our future policies,
• decide whether we send you our campaigning materials,
• select what campaigning material we send to you and which messages we put on it,
• evaluate whether we think you are likely to vote and for whom you will likely vote for during an election or a referendum.

How we use your information 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 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
• In order to fulfil a contract with you (contract)

The law restricts the processing of what is termed “special categories of personal data”. The work of Plaid Cymru 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.

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

You can always opt out of receiving any messages from Plaid Cymru or to exercise any of your legal rights.

We are committed to respecting your rights over your data and in some circumstances, we will have a legal duty to continue to process your data even where you have exercised one of your rights. For example, if you request that we stop processing your data for purposes of direct marketing then we justify keeping a record of this request to ensure that your wishes are respected.

Data Processed with your Consent

Where we use consent as our legal basis for processing your data, or process special categories of your data based on your explicit consent, you have the right to withdraw your consent at any time. This does not affect our right to process your data before you decide to withdraw your consent.

Who we share your data with:

We will never sell your data but sometimes it is necessary to share your information with our service providers and data processors. Data is only ever shared where we have a justification and when the law allows us to do so.

We share data with:

• Business associates and professional advisers
• Suppliers
• Service providers
• Financial organisations – such as credit card payment providers
• Elected representatives
• Regulatory bodies
• Market researchers
• Law enforcement agencies

Where we use a service provider to process your data on our behalf we will ensure that this processing is governed by a legally enforceable contract which sets out their responsibilities for protecting your data and your rights.

Transferring your data outside of the European Economic Area

Some of our service providers are located outside of the European Economic Area (EEA) and therefore it may be necessary to transfer your personal data outside of the EEA. Where we do transfer your data outside of the EEA we will make sure that it is protected in the same way as if the data was inside the EEA.

We will use one of the following safeguards to ensure this:

• Where the European Commission has issued an adequacy decision determining that a non-EEA country or organisation ensures an adequate level of data protection.
• A contract is put in place with the recipient of the data obliging them to protect the data to the same standards as the EEA.
• The transfer is to an organisation that complies with the EU-US Privacy Shield.

How long we retain your data for:

We constantly review the data that we hold and regularly review its relevance and our need to hold onto it. Whilst we do not set finite periods for data retention we use several factors to determine whether we need to hold onto the data. Factors we take into consideration are:

• Retention periods as required by law – for example Plaid Cymru is under a statutory duty to retain financial information for a period of 6 years,
• The purpose for which the data was provided or obtained,
• Our legitimate interests in holding onto your data,
• Whether holding onto your data will infringe your rights over your data,
• Legal and regulatory obligations that may require reference to your data,

Cookies

A cookie is a tiny text file that is stored on your computer. We may use technology to track the patterns of behaviour of visitors to our site. This can include using this “cookie” file which would be stored on your computer. You can usually modify your browser to prevent this happening. We may store the internet address you connect to our computer with, the time and date you connected, browser information and the pages you visited. This information is used only to provide us with a broad statistical breakdown of our site usage and to monitor site security.

Log Files and Statistics

We use IP addresses, URL’s of requested resources, timestamps and HTTP user-agents to analyse trends, administer the system and gather broad demographic information for aggregate use. In addition to this we use Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies, to help analyse how visitors use our site. The information generated by the cookie about the use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our website, compiling reports on website activity for Plaid Cymru and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your Web browser, however please note that if you do this you may not be able to make full use of our website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How we protect your data:

The security of your data is paramount to the Party and as such we ensure that appropriate technical and organisational measures are in place to protect it. We constantly review our measures to ensure that your data is protected from any threats that may emerge.

Your rights over your data 

Right of access to your data: You have the right to request a copy of your personal information that we hold. This is commonly known as a Subject Access Request. We follow the ICO’s “Subject Access Code of Practice” when dealing with requests for access to personal data. You can read this code by visiting https://ico.org.uk/media/for-organisations/documents/2014223/subject-access-code-of-practice.pdf

Right of rectification of your data: You have the right to request that inaccurate or incomplete information that we hold about you is corrected.

If you need to correct the information you can do so by emailing [email protected].

Right to be forgotten: In certain circumstances you can ask for the data we hold about you to be erased from our records. When we do so, we keep the bare minimum of your information to continue to respect your wishes when your personal data is next provided to us by a local authority, which is at least annually.

Right to restriction of processing: You have the right to request that we restrict the processing of your data where you are contesting the accuracy of the data or when the data has been unlawfully processed.

Right to object: You have a right to opt out of your data being used for direct marketing. If we process your data based on “a task carried out in the public interest” then you have the right to object to 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 legal grounds for the processing.

Opt Out: We provide you the opportunity to opt-out of receiving communications from us easily and promptly. Please email [email protected] if you would like to unsubscribe from receiving updates or if you would like us to permanently delete any personal information the party holds about you.

Automated individual decision-making, including profiling: We may use computer software to make decisions about you or to create a profile about you. You have the right not to be subject to such a decision or to that profiling where it creates legal effects concerning you or where it significantly affects you. None of our processing falls within that category.

INFORMATION ON CHILDREN

Plaid Cymru does not process any personal details from individuals under the age of 14 without parent/guardian consent. Details of children under 16 are processed for membership purposes only.

LINKS TO OTHER SITES

Our site contains links to other sites and servers. Plaid Cymru is not responsible for the privacy practices or the content of such websites.

Our Data Protection Officer:

Our Data Protection Officer is Gareth Clubb. If you'd like to speak with him about anything contained within our privacy policy, or in regards to your own data, please phone 02920 472272 and ask for Gareth Clubb.

Making a complaint: If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom. The contact details for the Information Commissioner’s Office are:

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

Telephone: 0303 123 1113
Website: https://ico.org.uk/concerns/