All data subjects whose personal data is collected, in line with the requirements of the EU’s General Data Protection Regulation (GDPR). Under the GDPR, personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Privacy notice
2.1 Who are we?
This is the office of John Nicolson MP. John Nicolson MP is the current Scottish National Party (SNP) Member of Parliament for the United Kingdom Parliament constituency of Ochil and South Perthshire. The office discharges the duties and functions of an elected Member of the UK Parliament. The office provides advocacy services for residents of Ochil and South Perthshire constituency.
John Nicolson MP (referred to in this Privacy Notice as “he”, “his”, “we”, “our” or “us”) is the Data Controller under the GDPR. This privacy notice sets out how we process personal data about constituents (referred to in this Privacy Notice as “you” or “your”).
Contact details are as follows:
- Constituency office address: 38 Primrose Street, Alloa, Clackmannanshire FK10 1JG
- Parliamentary office address: House of Commons, London, SW1A 0AA
- Email: email@example.com
- Telephone number: NA
- Website: johnnicolson.scot
2.2 Why do we need your personal information?
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
As an elected representative, John Nicolson MP will only be able to look into concerns which you raise if he and his staff can use your personal information, in order to raise enquiries with relevant agencies on your behalf. All casework undertaken is strictly confidential.
John Nicolson MP also requires your personal information so that he and his staff can keep you informed about the progress of any enquiries he and his staff make on your behalf, as well as to contact you with the outcome(s) of any enquiries he and his staff make on your behalf. John Nicolson MP also regularly receives emails or other forms of correspondence from constituents who wish to lobby him about certain policy issues or upcoming events, debates and votes in the UK Parliament. In order to respond effectively to such enquiries, John Nicolson MP requires personal information so that he can provide more details about his position and views on the matters which you raised with him.
John Nicolson MP also receives information about individuals from third parties, which can include (and is not limited to) friends/relatives of constituents in situations where the constituent cannot get in touch directly, legal representatives acting on behalf of a constituent or situations where constituents raise queries or complaints about other people. This information is processed in line with the GDPR and the Data Protection Act 2018, using one of the legal bases set out in section 2.3 below.
John Nicolson MP also operates an email newsletter, which gives constituents who wish to opt-in the opportunity to receive further general updates on his campaigns and activities as a Member of Parliament. This newsletter is a marketing communication, therefore opt-in consent will always be requested before any such communication is sent to you, in line with the Privacy and Electronic Communications Regulations 2003. In order to provide you with updates on his activities as a Member of Parliament in this format, provided you have consented to receiving such updates, John Nicolson MP requires your email address to send you these updates.
2.3 What types of personal data do we collect and process?
|Personal data type:||Source (where John Nicolson MP obtained the personal data from if it has not been collected directly from you):|
|Name||Where a full name is not provided by the constituent, details of first names and surnames are obtained from the full electoral register to verify that the person from whom data is being collected is resident in Ochil and South Perthshire constituency. The full unedited electoral register is made available to Members of Parliament to carry out the functions of their office.|
|Postal address||Where a full postal address is not provided by the constituent, address details are obtained from the full electoral register to verify that the person from whom data is being collected is resident in Ochil and South Perthshire constituency. The full unedited electoral register is made available to Members of Parliament to carry out the functions of their office.|
|National Insurance Number|
|Home Office reference number|
|Date of birth|
|Any other reference numbers connected to your enquiry|
In some circumstances, it may be necessary for John Nicolson MP or his staff to collect special categories of data about you. This could include your racial or ethnic origin, religious or political beliefs, sexual orientation, health information or details of any criminal convictions or allegations of criminal activity. This information will only be collected where it is materially relevant to the enquiry you raised with us.
2.4 How will we use your personal data?
The personal data we collect will be used for the following purposes:
- Recording of the personal data on a database (caseworker.mp, which is managed by Elected Technologies Ltd) in order to efficiently manage and respond to enquiries made to John Nicolson MP or his staff.
- Carrying out constituency casework, which can include any or all of the following processes:
- Making enquiries on your behalf when you have raised a concern/issue that you would like John to pursue with a relevant agency or organisation.
- Updating constituents on the progress of any enquiries raised on their behalf.
- Highlighting cases in Parliament in order to effect changes on Government policy.
- Providing constituents with information about John Nicolson MP’s position on a particular policy issue or on upcoming events, debates and votes in the UK Parliament, when such requests have been made either directly by the data subject or from the data subject acting through an organised lobbying campaign.
- Where constituents have opted-in to receive such information, to send newsletters and other forms of electronic marketing communication via email.
2.5 Lawful basis
The GDPR sets out a number of lawful bases under which personal data can be processed. We will always ensure that we have a lawful basis for processing your personal data. This will be one of the following bases:
- Public Task – In accordance with the discharge of key functions of a Member of Parliament and their office in responding to requests for assistance from you.
- Vital Interests – Where a request is made by someone else (e.g. a legal representative or a friend/relative), data is processed in circumstances where consent cannot be given by, or expected to be obtained from, you or where obtaining such consent would prejudice actions taken by John Nicolson MP in your vital interests.
- Consent – With your explicit consent. You can withdraw your consent at any time by contacting John Nicolson MP or his staff using the contact details provided above.
We may pass your personal data on to third party service providers in the course of dealing with your enquiry, such as local authorities, government agencies, public bodies, health boards, regulators, and so on. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to provide us with information relating to the specific enquiry you have raised with John Nicolson MP.
John Nicolson MP also contracts third party providers to provide specific services for the effective discharge of the functions of his office, for example in efficiently managing responses to individual enquiries and maintaining records of individual cases. Details of the third party providers which process personal data on behalf of John Nicolson MP, and for whom a data processing agreement has been made, is available below.
|International organisation||Safeguards in place to protect your|
|Mailchimp||John Nicolson MP has a data processing agreement with MailChimp.|
Access to data collected and processed for the newsletter and other electronic marketing communications is password-protected and only available to John Nicolson MP and staff members authorised to write and send such communications on behalf of John Nicolson MP.
MailChimp is signed up to the EU-US Privacy Shield.
2.7 Retention period
The office of John Nicolson MP will store the personal data for as long as it is required to progress enquiries made on your behalf or, if you have opted in to receive them, marketing communications regarding his activities and campaigns as a Member of Parliament. At the end of the parliamentary term, which is expected to last 5 years under the Fixed-Term Parliaments Act 2011, all data held will be reviewed and data relating to constituents who have not been in contact will be securely destroyed.
Should John Nicolson MP decide not to contest a future election, or should he leave office early as a result of resignation or death, all personal data will continue to be held for two months after a new Member is elected, during which period the office of John Nicolson MP will be wound up. During that two month winding-up period, you will be contacted for instructions on what you wish to do with your data; unless we hear from you otherwise, any data held about you will be securely destroyed at the end of the two month period.
2.8 Your rights as a data subject
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.
- Right to judicial review: in the event that the office of John Nicolson MP refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in section 2.9 below.
All of the above requests will be forwarded on, should there be a third party involved
(as stated in section 2.6 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by the office of John Nicolson MP, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and with John Nicolson MP.
The details for each of these contacts are:
|Supervisory authority contact|
|Data controller contact details|
|Information Commissioner’s Office||John Nicolson MP|
|Wycliffe House||38 Primrose Street|
|Postcode:||SK9 5AF||FK10 1JG|
|Telephone:||01625 545 745||NA|
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