Canterbury Constituency Conservative Association


GDPR Legitimate Interests Assessment

Canterbury Constituency Conservative Association has two lawful reasons for processing individuals’ data:

  1. Public task: it is necessary for us to process individuals’ data to promote voter participation in local, county, national and other elections and referenda.
  2. Legitimate interest: it is necessary to process individuals’ data garnered from public records (e.g. the electoral roll) to encourage voter participation in all relevant elections.

Conservative Party Members have also given their express permission to be contacted by groups within the Conservative Party.

Statement of Canterbury Constituency Conservative Association’s Data Protection measures and Legitimate Interest Assessment:

We have:

  reviewed the purposes of our processing activities and selected the most appropriate lawful basis (or bases) for each activity.

  checked that the processing is necessary for the relevant purpose and are satisfied that there is no other reasonable way to achieve that purpose.

  documented our decision on which lawful basis applies to help us demonstrate compliance.

  included information about both the purposes of the processing and the lawful basis for the processing in our privacy notice.

We do not:

  process special category data.

  process criminal offence data.

  offer online services directly to children.

  use pre-ticked boxes or any other type of default consent.

  penalise individuals who wish to withdraw consent.

Requesting, recording and managing consent

  We have checked if consent is the most appropriate lawful basis for processing.

  We have made the request for consent prominent and separate from our terms and conditions.

  We ask people to positively opt in.

  We use clear, plain language that is easy to understand.

  We specify why we want the data and what we are going to do with it.

  We give separate distinct (‘granular’) options to consent separately to different purposes and types of processing.

  We name our organisation and any third party controllers who will be relying on the consent.

  We tell individuals they can withdraw their consent.

  We ensure that individuals can refuse to consent without detriment.

  We avoid making consent a precondition of a service.

  We keep a record of when and how we got consent from the individual.

  We keep a record of exactly what they were told at the time.

  We regularly review consents to check that the relationship, the processing and the purposes have not changed.

  We have processes in place to refresh consent at appropriate intervals, including any parental consents.

  We consider using privacy dashboards or other preference-management tools as a matter of good practice.

  We make it easy for individuals to withdraw their consent at any time, and publicise how to do so.

  We act on withdrawals of consent as soon as we can.

The management team of the Canterbury Constituency Conservative Association made the decision that processing is necessary for us to perform a task in the public interest at a special meeting on 4th May 2018.

We hold personal data (including names, postal and email addresses, telephone numbers, and bank details) relating to individual members who have given us their consent to process this data. We also have access to data on individual voters provided through the electoral roll. This data is accessed by officials and members of the Conservative Party for the purpose of political campaigning.

We have procedures in place to detect, report and investigate a personal data breach and we have carried out an information audit.

J Gilbey is designated as having responsibility for our data protection compliance and they have the right to attend all meetings of the Canterbury Constituency Conservative Association management team and executive council.


Approved by the Canterbury Constituency Conservative Association on 24May18.

Amy Baker is the Designated Data Protection Officer