Privacy Policy

Last updated: May 2025

Plymouth Knows Better (“we”, “our”, “us”) is committed to protecting your privacy. This Privacy Notice explains how we collect, use, and store your personal information when we run our campaign and when you engage with our campaign and website.

Who We Are

We are Plymouth Knows Better, a grassroots campaign based in Plymouth, United Kingdom which is being conducted by the Plymouth Labour Party. The campaign is supported by members of multiple political parties and community figures although your personal data is never shared with them. Plymouth Labour Party is the ‘Data Controller’ for all data collected and used within the Plymouth Knows Better campaign. You can contact us about any data or privacy queries at: [email protected].

Personal Data We Collect

Title, first name, last name, preferred name(s), email address, post code, home address (and old home addresses), telephone number(s), date of birth, gender;
Polling number, polling district, ballot box number, polling place name, road group, polling place address, polling place post code, local authority;
Political opinion, voting intention and, if gathered, scales from 1-10 of voting intention for or against having a Mayor where 10 is most likely to vote in that direction;
Notes about you collected during our campaign based interactions with you;
Any communications we have with you which may be over email, telephone or face to face;
Any personal data you volunteer in any free text fields in any paper-based or digital polls, surveys, questionnaire or webforms that are captured by us where you have provided enough information to be able to identify you;
Depending on how you may have interacted with any physical or digital locations managed by us, we may collect publicly available information on websites inc. Companies House, Land Registry, news and broadcast media or historical publications etc. (also used for volunteer due diligence checks);
Depending on how you may have interacted with any digital campaign locations managed by us, we may collect and use, or have used on our behalf, any personal data, language /or and behaviour within the public domain such as social media posts (X, Meta platforms, YouTube etc.);
Pseudonymous and anonymous data we have created from your personal data but we and others are unable to use this data to directly identify you;
Recordings, photographs, images and videos recorded within any interviews you have with us or you are conducting that we are (and you may be) recording;
Reason(s) for attendance to any campaign events we hold and dietary requirements and any accessibility requirements you may have to enable you to attend;
Videos of you where you are in the background when you attend an in-person event we are running and recording;
Videos of you or Podcasts recordings of you where you are acting as a speaker for our work or being interviewed on or off camera either as an invited guest or as an attendee of a campaign event we are holding;
Volunteer information (e.g. if applicable to the work you may have volunteered for; application form, cover letter, CV, right to work documentation, references, assessment information) inc. next of kin and other contact information for people contactable in an emergency;
Information about the device used to access our website, your visits and use of the website including your IP address, internet log information, location, browser type and version, referrer and activity, and details of visitor behaviour patterns;
We record your activity and preferences when visiting our website through the use of cookies (see “Cookies”, below); and
IP address, operating system and browser information.

How We Collect your Personal Data

We collect personal data in a variety of ways and at a variety of times throughout our interactions with you.

We refer to “direct data collection” when data is collected directly from you and we refer to “indirect data collection” when the data is not collected directly from you. Here is the list of ways we will collect your personal data from you:

From the Electoral Register (indirect data collection);
- The ‘Marked Register’ data (the record of whether or not people on the electoral register voted at a given election, which is available for political parties to purchase) (indirect data collection);
- The ‘Full Electoral Register’ (which is everyone that is registered to vote unless you are registered anonymously) which also includes your home address;

NOTE: although you may have opted out of the open register it does not affect whether political parties get access to your data or not i.e. even if you have opted out, we will still have a copy of your data from the open register.

From yourself via email, telephone or face to face communications we have with you (direct data collection);
Demographic data about you from our commercial supplier (Experian), and BT Osis (indirect data collection);
Data on political opinions we have collected from you on the doorstep, phone or via other methods of capturing data directly from you (direct data collection);
Online or physical forms, surveys, questionnaires or polls you have answered or completed for us where you may or may not have had the option to tell us who you are, or you may have chosen to remain anonymous (direct data collection);
From yourself when we record you at an event either in the foreground or background depending on the circumstances of any recording taking place (direct data collection);
From you or an individual on your behalf if you register of attend an event we are running (indirect data collection); and
[For supporting the campaign] From an individual who is aware of you, who may include, but is not limited to, other people who support our cause, MPs, Labour Staff, Labour Candidates, Labour members, volunteers, Specialist Volunteers or members of a trade union (indirect data collection).

When you visit our website, we collect data about you from your device and via third-party website analytics services such as Google Analytics and cookies (see below) when you visit our website. We do not make, and do not allow our Google Analytics settings to make, any attempt to find out the identities of those visiting our website.

How We Use Your Personal Data

Purpose for using personal data	Lawful basis for using
To manage and run the Plymouth Knows Better campaign. This is within the definition of our legitimate democratic engagement activities. [From the Data Protection Act 2018: “The term “democratic engagement” is intended to cover a wide range of political activities inside and outside election periods, including but not limited to: democratic representation; communicating with electors and interested parties; surveying and opinion gathering, campaigning activities; activities to increase voter turnout; supporting the work of elected representatives, prospective candidates and official candidates; and fundraising to support any of these activities“]	The lawful basis we shall be relying on is for the performance of a task carried out in the public interest by a data controller in accordance with UK GDPR Article 6.1(e), also known as “Public Task”. And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To allow us to carry out our campaigning with the general electorate data we hold which includes engaging with you (voters) as part of the democratic process, including face-to-face canvassing. I.e. This may mean we have printed your information so that people who are knocking doors are able to know who you are and capture your opinion about our campaign goals; it may also mean your personal data is securely accessible on our canvasser’s digital devices for short periods whilst walking the streets and knocking on doors.
For us to identify and distribute the most effective referendum campaign messaging to a demographic or geographic area you belong to or where you may be located [NOTE: this is generally aggregated data we have purchased and usually is not able to directly identify you]	Our legal basis for profiling is a mixture of both Legitimate Interests (GDPR Article 6 (f)) and Public Task (GDPR Article 6(1)(e)) in order to engage with voters and send them messages which they are likely to be interested in. And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To inform our campaign targeting and demographic modelling activities through profiling of your data from any location we may legally correct your personal data.
To respond to you when you have engaged with us or any campaign material whether via social media, generic digital campaign locations on websites which may be polls, surveys and/or questionnaires, or email or SMS (text) distribution lists you are legitimately on that either we already hold or a partner on our behalf holds already where they have a lawful basis to do so.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). [Depending on how you interact with us the lawful basis may be in accordance with UK GDPR Article 6.1(e), also known as “Public Task”.] And, Special categories of personal data used for the purpose of Substantial Public Interest under UK GDPR Article 9.2(g) in line with Schedule 1, Part 2, Paragraph 22 Political Parties of the Data Protection Act 2018.
To invite you to join the Labour Party as a member or become involved in the Plymouth Labour Party.
		To send you referendum campaign material in the post that is addressed directly to you, via FREEPOST, whether or not you have opted out of the electoral register. You must contact us directly to be put onto a ‘do not contact’ list to ensure you do not receive this post from us.	The lawful basis we shall be relying on is for the performance of a task carried out in the public interest by a data controller in accordance with UK GDPR Article 6.1(e), also known as “Public Task”. The Political Parties and Referendums Act 2000 allows for this activity.
To send you marketing material either in the post, via email or text (SMS).	The consent you have provided us for this use of your personal data in accordance with UK GDPR Article 6.1(a). And, The consent you have provided us for this use of your special categories of personal data in accordance with UK GDPR Article 9.2(a).
To manage any events we hold and your attendance at the event as well as any issues that may occur.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f).
To allow for accessibility and dietary needs/requirements at any event(s) we run.
To use any photograph(s) / video(s) taken at our event(s) without the expressed written permission of those included within the photograph(s) / video(s), for use in marketing collateral and documentation which may include brochures or broadcasts. If you do not wish to be in any photograph(s) / video(s) being taken, please make sure you position yourself out of the line of sight of any cameras.
To review your eligibility to be a Volunteer for our campaign including performing due diligence checks for ethical, safeguarding and security issues that may be of relevance.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). And, The lawful basis we shall be relying on where processing is necessary in order to protect the vital interests of yourself or of another natural person is in accordance with UK GDPR Article 6.1(d).
So we are able to align you to a volunteering activity.
To identify personal data and take relevant action upon submission of a data subject rights request.	Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the UK General Data Protection Regulation to uphold your data protection rights. Special categories of personal data used for the purpose of Substantial Public Interest (Preventing or detecting unlawful acts; Protecting the public; Regulatory requirements) under UK GDPR Article 9.2(g).
To be able to assess any impact on individuals of a data breach involving personal data held on Labour Party systems or on third party systems.
To help protect an individual from neglect or physical, mental or emotional harm, or protect the physical, mental or emotional well-being of an individual.	Use of the personal data is necessary to protect the vital interests of an individual or individuals in accordance with UK GDPR Article 6.1(d). Special categories of personal data used for the purpose of Substantial Public Interest (Preventing or detecting unlawful acts; Protecting the public; Regulatory requirements) under UK GDPR Article 9.2(g).
To deal with legal claims and ongoing litigation cases.	Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the UK General Data Protection Regulation to uphold your data protection rights. Special categories of personal data used for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity under UK GDPR Article 9.2(f).

Third Parties

NOTE: We never sell your personal data.

Any data shared with the below categories of recipients is the minimum necessary for the task they have been instructed to carry out on our behalf or in conjunction with us.

Where the sharing of personal data is within the context of a product or service being supplied under contract to us, a Data Processing Agreement, in accordance with UK GDPR Article 28 is put in place. This makes sure the supplier cannot use your personal data outside of the list of uses above.

Within the purposes of using your personal data, as listed above, we will share your personal data with the following:

An electoral roll database management service provider;
Digital communications and storage service providers;
If applicable and you have interacted with them, online polling, survey, questionnaire or web-form platform providers;
Labour’s digital campaign team of designers and physical printing facilities and external print organisations;
Any department or unit within the Labour Party with an authorised level of secure access to electoral register data;
If initiated by you and where relevant and agreed by you, media organisations which may include news media and journalists who represent specific and relevant views;
If initiated by you and where relevant and agreed by you, charities, charitable causes or individual families which have the possibility of being positively impacted from your contact and engagement with them (if agreed, any further uses of your personal data will be in line with their privacy information and Labour takes no liability for any use of your personal data in how they use your personal data); and
If applicable, with Police, Law Enforcement Agencies, Healthcare Services including the NHS, Adult Services, Children Services, Local Authority Designated Officers (LADO), charities, charitable organisations or agencies or any other safeguarding related institutions or organisation(s), solicitors, legal counsel and/or claimants.

There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime, or prove we have adhered to their request. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.

In all circumstances, the unlawful and unauthorised sharing of copies of personal data in which the Labour Party is the data controller is expressly prohibited. Any unauthorised sharing of Labour Party data is classified as a data breach which we will record and report to the ICO as required.

For the avoidance of doubt, we do not sell, rent, or share your personal information with any other third parties, political parties, or elected officials.

Data Storage and Security

We implement appropriate technical, organisational and contractual security measures to protect the personal data we hold about you. This is to protect it from unauthorised disclosure, use, alteration or destruction. We keep these under review to make sure that the measures we have implemented remain appropriate.

Individuals working with personal data within the Plymouth Knows Better campaign are required to attend or undertake data protection training and at least once every two years for active members of the Plymouth Labour Party.

Your data, as it is stored for the Plymouth Knows Better campaign, is securely stored securely in the United Kingdom and EU, and all website data transmissions are protected via SSL (Secure Socket Layer) encryption. Any personal data is not subject to any automated decision-making.

Your Rights

You have the following rights in respect of your personal data:

You have the right of access to your personal data and can request copies of it and information about our processing of it.
If the personal data we hold about you is incorrect or incomplete, you can ask us to rectify or add to it.
Where we are using your personal data with your consent, you can withdraw your consent at any time.
Where we are using your personal information because it is in our legitimate interests to do so, you can object to us using it this way.
Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you can object to us doing so.
You can ask us to restrict the use of your personal data if:
- It is not accurate,
- It has been used unlawfully but you do not want us to delete it,
- We do not need it any-more, but you want us to keep it for use in legal claims, or
- if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

You can unsubscribe from our mailing list at any time by clicking the unsubscribe link at the bottom of any campaign email or by contacting: [email protected].

Cookies

As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies to enhance your experience of our website.

Our website uses cookies for collecting user information which may include IP address, operating system, and browser information. We use persistent cookies to track returning visitors. They expire after 12 months and enable us to compare website traffic from month to month.

Cookies are text files, which identify a user’s computer to our servers. Cookies in themselves do not identify the individual user, just the computer used.

You can manage and delete cookies through your web browser. Each browser manages cookies differently, but you can learn more about cookie settings in the most common browsers using the links below:

You can also prevent your data from being used by Google Analytics by using the Google Opt-out Browser Add-on, available at this link.

How to Complain

We ask for the opportunity to address any of your data protection concerns or complaints before you raise your complaint with the regulator.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO). They can be contacted using the following information:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://ico.org.uk/concerns/.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.

Contact Us
If you have any questions or concerns about how we handle your data, please contact:
✉️[email protected]

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