Overview
Sovereignty is a political party registered with the UK Electoral Commission. Our contact address is Sovereignty, Schoolhouse, Hamnavoe, Burra, ZE2 9LA. Our website is https://sovereignty.scot.
The present Privacy Policy relates to all data collected and processed by Sovereignty (“the Party”). Should you have any questions relating to this Privacy Policy, please do not hesitate to contact us on connect@sovereignty.scot.
Data Collection and Processing
Sovereignty collects and processes data from the public, and from its officebearers, staff, members, volunteers, supporters and donors.
Data Collection
We may collect personal data from you in a variety of different contexts:
- When you visit and interact with the Sovereignty website;
- When you make information public on social media or in a forum run by the Party;
- When you interact with us by phone, text, post, email, via an app, or by some other means of communication;
- When you enter a financial transaction with us, such as making a donation or signing up for membership; and,
- When you participate in a party congress, meeting or event;
We may collect information about you from other public sources, including websites, social media, and Companies House, in order to verify your eligibility to join or make a donation to the Party.
Types of Data Collected
We may collect the following types of personal data:
- Your title and full name;
- Your contact details;
- Your date of birth;
- Your sex;
- Demographic data, typically only where required by law;
- Disability information;
- Your interests and lifestyle preferences;
- Information on your contacts that you provide to us;
- Communication preferences;
- Information on financial transactions with the Party;
- Recordings of phone calls;
- The text of correspondence with us;
- Your IP address;
- Your device, operating system and browser;
- Your browsing history;
- Your username, digital identities and social media handles;
- Data you freely and publicly post online;
- Pictures and portraits of yourself;
- Attendance information; and,
- Data from marked electoral registers.
We only use data from external sources if they are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources.
Use of Personal Data
Sovereignty may use your personal data to further the objectives of the Party.
Examples of how we may use your data include the following:
- Canvassing for political support;
- Learning about your views and the issues that matter to you;
- Processing survey information;
- Informing you about the positions, initiatives and activities of the Party;
- Encouraging political participation, action or engagement with the Party;
- Informing you of other political or charitable activities that we support;
- Responding to queries, suggestions and complaints;
- Contacting you about your membership;
- Communicating with you about Party business and events;
- Administering the work of the Party;
- Measuring public opinion generally;
- Improving the digital resources of the Party;
- Improving customer services;
- Maintaining accounts;
- Processing payments;
- Fundraising;
- Fulfilling donation reporting obligations;
- Handling legal requests, and fulfilling statutory obligations;
- Conducting background checks and verifying references, employment history, and qualifications;
- Verifying your identity; and,
- Verifying your eligibility to make a donation to the Party.
We will respect any registration you hold with the Telephone Preference Service (TPS) except where you have opted in to receive phone calls on that number from us.
You may opt out of non-essential communications from us at any point.
Data Sharing
Sovereignty will never sell your personal data to a third party.
We may share your personal data with the following external service providers (in a variety of combinations, and for a variety of purposes), data sharing agreements with which are concluded separately:
- Civic UK (cookie preferences)
- Give WP (names, contact details, donations, membership fees)
- Hubspot (names, contact details, membership information)
- Jitsi (names, contact details, online meetings)
- Protonmail (names, email metadata, correspondence)
- Stripe (names, contact details, membership information, transaction-related data)
- WordPress (names, log-in details)
- Xero (names, contact details, donations)
We are seeking to minimise the number of third parties with whom we work, and to prioritise those partners with the strongest privacy protections, in order to maximise data security and privacy protection.
With your consent, service providers may hold personal data about you in order to facilitate the provision of future services or financial transactions to which you have agreed, such as a payment processor retaining your payment details in order to process agreed future payments from you.
We may share your personal data with third parties when we are required to do so by law.
In particular, the Party and our candidates are required to submit records, including personal data, of donations above certain thresholds to the relevant regulatory authority. In some cases, some of these donation details are made public. If you would like further information on this, please do not hesitate to get in touch via the contact information in the footer below.
Save in the circumstances listed above, we will never pass your personal data to unrelated third parties unless you have given us your permission to do so.
Duration of Data Retention
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Legal Basis for Data Processing
As a registered national political party, Sovereignty is entitled to a copy of the full Electoral Register under the UK Representation of the People Regulations 2001. The full Electoral Register is different to the open Electoral Register as it contains details of all voters in Scotland, including those who have opted out of the open register. We are also permitted to send one Freepost mailing to every voter in Scotland during an election period.
The GDPR and Data Protection Act 2018 provides a list of reasons that an organisation may use to permit them to process personal data.
| Category | Reason | Method | Legal Basis |
| Personal information, including contact details | To facilitate communication with officebearers, staff, members, volunteers, supporters and donors. | Voluntarily provided information, third parties, the Electoral Register. | GDPR Article 6(e) Public Interest (Legal Basis) GDPR Article 9(2)(g) * processing is necessary for reasons of substantial public interest (Condition for processing). |
| Political opinions | To learn about your views and the issues that matter to you. | Canvassers, online surveys, voluntarily provided information. | GDPR Article 6(e) Public Interest GDPR Article 9(2)(g) Processing is necessary for reasons of substantial public interest (Condition for processing)* |
| Demographic information | To comply with relevant legislation. | Forms. | GDPR Article 6(a) Consent (Legal Basis). GDPR Article 9(2)(a) Consent (Condition for Processing). * |
| Financial transactions | To retain financial information required by law. | Online forms, over the phone. | GDPR Article 6(b) For the purpose of entering into a contract. GDPR Article 6(a) Consent. |
| Photographs | To provide material for our website, publications. | Voluntarily provided images, pictures taken during events etc. | GDPR Article 6(a) Consent |
| Event attendance information | To facilitate the management of events. | Registration forms, check-in details. | GDPR Article 6(b) For the purpose of entering into a contract |
| IP address | To improve our website. | By accessing the restorescotland.org website. | GDPR Article 6(a) Consent |
| Usernames, social media handles | To facilitate participation in online fora, social media. | By accessing the relevant web services. | GDPR Article 6(a) Consent |
| Telephone recordings | To improve customer services. | By calling the Party. | GDPR Article 6(f) Legitimate Interests |
| Details of enquiries, suggestions or complaints. | To improve service standards. | By contacting the Party. | GDPR Article 6(f) Legitimate Interests |
| Your profile in our promoted materials | To showcase the work of the Sovereignty team. | By attending our events, voluntarily provided information, by giving specific consent. | GDPR Article 6(a) Consent |
| Employment-related data | To fulfil the HR function of the Party. | By interacting with the Sovereignty NEC, administrative team or HR department. | GDPR Article 6(b) For the purpose of entering into a contract |
| Publicly available data. | To verify member and donor eligibility. | By submitting a registration form, renewal form, or making a donation. | GDPR Article 6(b) For the purpose of entering into a contract. |
*Data defined as Special Category Data in the GDPR requires a condition for processing found in Article 9(2).
Similarly, you may from time to time give us your consent to send you communications by e-mail (or similar mediums) which promote our work. Where you do that we will use your details to send you those kinds of communications until you tell us otherwise. Should you ever ask us to stop sending those kinds of communications we will hold your details on file to ensure that we respect that request – we justify that retention on the basis that we have a legitimate interest in holding your data in that way.
We will only hold data about you if we have a legal basis for doing so. If we find that we no longer need your data for the purpose it was acquired or we can no longer establish a legal basis for holding your data we will delete it as soon as possible.
Cookies
A cookie is a small text file placed on your device when you visit a website. You can accept or decline cookies through your browser settings or other software. For more information about cookies, see information from the Scottish Information Commissioner on cookies and how to disable them.
When you visit the Sovereignty website, we may use cookies for one of the following reasons:
- Improving or customising your experience of the website;
- Gathering information you have submitted;
- Processing requests for information;
- Processing sessions;
- Gathering statistical information on site usage;
- Improving the functionality of the site;
- Remembering previously submitted information; and,
- Remembering your preferences on cookies.
By using our website, you are consenting to our use of cookies in accordance with this Privacy Policy. If you do not agree to our use of cookies, then you should set your browser or other software settings accordingly.
We may provide links to third-party organisations. In such cases, additional cookies may be placed to facilitate this arrangement and the third parties may also gather personal data about you in line with their own privacy policies.
We also provide options to share content on social media which may result in your being directed to the social media network’s own systems. If you proceed with this, those networks may gather personal data about you in line with their own privacy policies. On our website or in other digital communications we may also use technologies variously described as web beacons, pixel tags, clear gifs or tracking pixels to provide us with information about how people have navigated through the site or responded to the communication.
Data Security
The Party takes the protection of your information very seriously. We use encryption to protect your personal data when appropriate, and the information you provide to the Party is stored securely once we receive it.
Data Retention
We only keep your personal data for as long as required to meet the purposes set out in this Privacy Policy, unless a longer retention period is required by law. For example, this may include holding your data after you have ceased to engage with the party (such as by resigning or ceasing to be a member) where we have a legitimate interest in doing so, such as to enable us to respond effectively to grievances that may arise after you cease to engage with us. Where we collect and hold your details as part of our public interest work, this may also include retaining those details for as long as you remain a registered voter in Scotland.
Where permitted by law, we may also save personal data for archiving purposes in the public interest, including historical research.
Your Data Rights
We are committed to respecting your legal rights over your personal data that we hold, in accordance with the law. Your data rights include the right of access to your data, the right of rectification of your data, the right to restriction of processing, the right to data portability, and the right to object to your data being used for direct marketing, with certain limitations to these rights being permitted or necessitated by law. You can exercise these rights by contacting the Sovereignty Data Protection Officer.
Contact
Sovereignty has appointed a Data Protection Officer in line with guidance from the Information Commissioner’s Office. If you have any queries relating to the present Privacy Policy, then please do not hesitate to contact us on
Sovereignty, Schoolhouse, Hamnavoe, Burra, ZE2 9LA