Data Protection Policy
Office of Craig Mackinlay MP
This page outlines how the Office of Craig Mackinlay MP processes and manages personal data in relation to casework and policy queries.
1. Data Controller
The Data Controller is Craig Mackinlay MP.
2. Lawful basis for processing
i. Casework is processed primarily under the lawful basis of public task, with exceptional cases processed under the lawful basis of consent.
ii. Personal data contained in the non-political Craig Mackinlay MP Mailing List is processed under the lawful basis of public task. it does not fall within the definition of direct marketing.
iii. We undertake to always act within the reasonable expectations of our constituents and any other individuals about whom we hold personal data.
3. Data we hold
We operate a paperless office. Personal data is stored electronically and securely on our computer systems. Our systems are in offices which are locked when unattended.
Casework
The Office uses a CMS (Content Management System) application, Cross Reference, to help with the management of constituent casework records. This information predominantly includes but is not limited to:
- Names, addresses and email addresses
- Telephone numbers
- National Insurance Numbers, Passport Numbers
- Special category data, outline in Point 4.
Policy
Policy casework is stored in a folder system on Microsoft Outlook.
This information predominantly includes but is not limited to:
- Names, addresses and email addresses
- Telephone numbers
- Special category data on political beliefs.
Mailing lists
The Office also maintains a mailing list of around 4,000 subscribers to the Craig Mackinlay MP’s Mailing List. These subscribers receive Craig Mackinlay MP’s monthly newsletter and information about upcoming advice surgeries. Personal data we hold in this regard includes:
- Names, addresses and email addresses.
This information is not political in nature and therefore it is not categorised as direct marketing.
4. Special category data we hold
The office may also hold special category data for a smaller number of data subjects. This data will be processed under the lawful basis indicated in point two, as is permitted in clauses 23 and 24 of schedule 1 of the Data Protection Act. The data may include:
- Political opinions
- Religious beliefs
- Trade Union activities
- Sexual orientation
- Race and ethnic origin
- Details of criminal offences
- Physical and mental health
5. Data retention policy
Our office will hold personal data for no longer than the term of office of Craig Mackinlay MP. From 25th May 2018, we will only hold data dating from Monday 11th May 2015 inclusive. Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. Therefore, we feel it is reasonable for an elected representative to hold personal data for the duration of office, which may be across various parliamentary terms.
6. Subject Access Requests
We will comply to Subject Access Requests in line with the guidance given by the Information Commissioners Office (ICO).
i. We will respond as quickly as possible, within 30 calendar days.
ii. We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
iii. Data subjects have the right to the following:
a. To be told whether any personal data is being processed
b. To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people.
c. To be given a copy of the information comprising the data, and given details of the source of the data where this is available.
7. Privacy notice
Our office will undertake to ensure all constituents sharing their personal data can have the opportunity to read our privacy notice, which is below.
Privacy Notice
This privacy notice relates to the personal data processed by the Office of Craig Mackinlay MP, Member of Parliament for South Thanet, in relation to casework and policy queries.
Who is the Data Controller?
The Data Controller is Craig Mackinlay MP, Member of Parliament for South Thanet.
What does the Office do?
The office discharges the duties and functions of an elected Member of Parliament. As part of this work, we conduct constituency casework and respond to policy queries, for which we must process personal data of our constituents. We also manage a small, non-political mailing list for the purpose of sending Craig Mackinlay MP’s E-Newsletter and information about upcoming advice surgeries.
How do we process data?
This office processes constituents’ data under the lawful basis of public task. In instances where this lawful basis is not sufficient and explicit consent is required, a member of the office will contact you to establish your consent.
We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Will we share your data with anyone else?
If you have contacted Craig Mackinlay MP about a personal or policy issue, we may pass your personal data on to a third-party in the course of dealing with you, such as local authorities, government agencies, public bodies, health trusts, regulators, and so on. Any third parties that we may share your data with are obliged to keep your details similarly securely, and to use them only for the basis upon which they were originally intended.
We will not share the personal information of members of the Craig Mackinlay MP Mailing List or those in receipt of our E-Newsletter.
In any case, we will not use your personal data in a way that goes beyond your reasonable expectations in contacting us.
For how long will you keep my personal data?
Unless specifically requested by you, our office will hold your personal data for the period that Craig Mackinlay MP is your Member of Parliament, which may cover multiple Parliamentary terms.
Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. Therefore, we feel it is reasonable for an elected representative to hold personal data for the duration of their period of office.
What rights do I have to my personal data?
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing, such as direct marketing, e.g. the receipt of an e-newsletter.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: if our office refuses your request under rights of access, we will provide you with a reason why. You have the right to complain.
How can I contact somebody about my privacy?
You can get in touch with our office by letter, email or telephone using the details at the foot of this page.
Please note that we will ask for identification should you choose to exercise any of the above rights in relation to personal data we hold.
Freedom of Information
The Freedom of Information Act 2000 requires the public bodies to supply information to requesters. It does not extend to individual Members of Parliament or to the information held by their staff or within their offices. MPs’ correspondence with public bodies may be subject under FoI to disclosure upon request to that public body. Guidance has been issued recommending that public bodies consult with MPs under such circumstances before relating such correspondence and it might, therefore, be exempt. A case-by-case basis is likely to apply.