Conservative Way Forward Privacy Policy
Conservative Way Forward and CWF are the names in common use of Conservative Way Forward Limited, a company incorporated in England & Wales under company registration no. 09644449 and whose registered office is at 78 York Street, London, England, W1H 1DP. Under this policy, the data controller is Conservative Way Forward Limited.
This policy sets out the basis on which any personal data we ("Conservative Way Forward/CWF") process personal data that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
CWF is committed to ensuring the privacy and compliance with Data Protection law. It is important that you read this Privacy Policy carefully together with our Terms to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
We operate as forum whereby you choose to sign up to receive information from us, and in doing so must consent to our policy, and our terms.
By interacting with our Website or CWF in other communications you must be willing to be bound by the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then please stop accessing our website, and do not communicate with us.
This Privacy Policy explains how we collect and use your Personal Data in accordance with our obligations under applicable privacy and data protection law, including the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.
For the purposes of this Privacy Policy, the term ‘Personal Data’ means any information, which identifies you, or which allows you to be identified when combined with other information. It does not include data where your identity has been removed (‘Anonymised Data’).
INFORMATION WE COLLECT AND HOW
When you use our Website or communicate with us, including attending any event we organise, we may collect certain Personal Data that can be used to identify you. Any data that does not enable you to be identified will not be considered Personal Data.
We may collect information and Personal Data from you:
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Via your interaction with our Website;
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Through social media engagement including responses to online advertisement;
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By email;
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Over the phone; or
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In person (e.g. paper based records).
We may collect and process the following data about you:
Personal Data that we require in order to keep you informed of our work and activity will include: First name, Last name, Gender, Date of birth, Email or Physical Address, Telephone numbers and social media account information. Other information may be gathered depending on the circumstances.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Device Information
When you use our Website, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address. For more information, please refer to our Cookie Policy.
Information we obtain from third parties
We may receive information about you from our third party service providers (such as Google Analytics or social media platforms like Facebook), who collect this information through our social media or from interaction with our Websites in accordance with their own privacy policies.
Special category data
The information you may provide to us may include personal data revealing racial or ethnic origin, political opinions and other special categories of data. Such categories of data may be considered Special Categories of Personal Data for the purposes of the Applicable Data Protection Law unless they are adequately anonymised. We shall always process such personal data with suitable care and in accordance with the data protection law.
Use of Personal Data
We may use information about you for various purposes, including to: Provide, maintain and improve our website and social media content, and to communication with you which will include sending you newsletters and other information on our activity or political content that we think will be of interest to you.
Sharing of Information
We may share information about you with consultants and other service providers who need access to such information to carry out work on our behalf, to maintain our online content or output of information; in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation; if we believe your actions are inconsistent with Terms then with our legal advisors. Our online activity is supported by a contract with NationBuilder, and your data will be stored on their servers, meaning outside the UK, you can see their privacy policy here: https://nationbuilder.com/privacy
Social Sharing Features
Our online content may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Sites with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Aggregated Anonymised Data
The information we collect from you may be combined with information provided by others, but only in an anonymised format, to produce aggregated anonymised data sets for research purposes. We refer to this combined data as ‘Aggregated Data.’ Aggregated Data is not considered to be Personal Data as it does not reveal your identity.
However, in the event that we combine or connect Aggregated Data with any of your Personal Data that enables you to be directly or indirectly identified, we will treat such data as Personal Data to be used in accordance with this Privacy Policy.
USE OF COOKIES AND GOOGLE ANALYTICS
CWF’s Website may use ‘cookies’ and similar technologies to enhance the users’ experience. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
LEGAL BASIS FOR USING YOUR PERSONAL DATA
The legal bases we rely upon to use your Personal Data may include the [Terms] we have with you, your consent and our legitimate interests, or where we need to comply with a legal or regulatory obligation. Where processing special category data this will be by consent or the contract you have with us. Please contact us if you require further details concerning the specific legal ground(s) we are relying on to process your Personal Data.
We offer here non-exhaustive examples of the ways in which we use your Personal Data and the legal bases we may rely upon to do so:
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If you are a participant completing one of our surveys, our legal basis for processing is your consent in taking part.
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To administer our Website our legal basis for processing is legitimate interests for running CWF.
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We may use your Personal Data if you apply for employment with us, processed under consent and then under contract if you become employed by us.
DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to process it.
DATA RETENTION
Your Personal Data will likely be retained for as long as you remain subscribed to CWF. Any Personal Data deemed no longer relevant is deleted. Though we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
If we have taken steps to anonymise your personal data (so that it can no longer be associated with you) we may use this indefinitely for analytical, research and statistical purposes.
YOUR RIGHTS
Your right to withdraw consent and cease to be a subscriber at any time. Whenever we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact CWF using the contact details provided at the end of this privacy policy. This will not affect the lawfulness of any processing carried out before you withdraw, nor ongoing contractual or other obligations requiring us to process data for example due to a court ordered law enforcement request.
The UK GDPR provides the following rights for individuals:
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The right to be informed – is met by this policy and the information provided when you have contact with us.
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The right to rectification – You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
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The right to erasure – You have the right to ask us to erase your Personal Data in certain circumstances.
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The right to restrict processing – You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
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The right to data portability – You have the right to ask that we transfer your Personal Data to another organisation, or to you, in certain circumstances.
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The right to object – You have the right to object to the processing of your Personal Data in certain circumstances.
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Your right to access the Personal Data we hold about you
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You have the right to make a request to access your Personal Data (known as a “Data Subject Access Request” or “SAR”).
We aim to respond electronically to all SARs within 28 days. We may require you to prove your identify before we reply to ensure we do not give out personal data to the wrong person. In circumstances where it may take us longer to respond (for example if your request is particularly complex or if you have made a series of requests), we will notify you. We do not charge a fee for responding to a SAR. However, we may charge a reasonable fee if your SAR is manifestly unfounded or excessive.
CHANGES TO THIS PRIVACY POLICY
We may occasionally update this Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your information.
OPT-OUT & UNSUBSCRIBE
We respect your privacy and give you an opportunity to opt-out of receiving communications. Users may opt-out of receiving any or all communications from us by contacting us or selecting the ‘Unsubscribe’ option on their email.
CONTACT INFORMATION
If you have a question please contact our Data Controller at datacontroller@conservativewayforward.com
We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner's Office (ICO) at any time about our processing of your personal information.
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).
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
Date last updated: 11 July 2022