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Electoral Services Privacy Notice
Ian Thomas is the registered Data Controller in respect of processing personal data for electoral purposes, whether in his personal capacity as Town Clerk, or as Electoral Registration Officer, or on behalf of the City of London Corporation (referred to in this notice as “the Town Clerk”), or as Ballot Holder for Business Improvement District (BID) Ballots. He is required under data protection legislation to notify you of the information contained in this Privacy Notice.
The Town Clerk is committed to protecting your privacy when administering electoral registration and elections. This Privacy Notice explains how the Town Clerk uses information about you and how we protect your privacy.
Personal information is anything that directly or indirectly identifies and relates to a living person, such as a name, address, telephone number, date of birth, or unique identification number such as elector number.
Some personal information is ‘special category data’ and needs more protection due to its sensitivity. For electoral administration, that includes nationality and may include political opinion. In rare circumstances it may also include documents received as part of an application for anonymous registration.
We may need to use some information about you to:
- Administer electoral registration and election services required by law, for example for the production and/or maintenance of:
a) The Ward Lists under the City of London (Various Powers) Act 1957 and the City of London (Ward Elections) Act 2002
b) The Electoral Register under the Representation of the People Act 1983
c) Absent Voter List
d) The Common Hall Register under the City of London Ballot Act 1887
e) The Register of Commoners under the Epping Forest Act 1878
f) The voter list under the Business Improvement Districts (England) Regulations 2004
- Employ election staff
- Help investigate any concerns or complaints you have about our services
There are a number of legal reasons why we will need to collect and use your personal information in different circumstances.
Generally, we collect and use your personal information where:
- you, or your legal representative, have given consent
- you have entered into a contract with us
- it is necessary to perform our statutory duties
- it is required by law
- it is necessary for employment purposes
- it is to the benefit of society as a whole
- it is necessary for archiving, research, or statistical purposes
The personal information we collect for the administration of electoral registration and election services fall within the categories below:
- Contact details such as alternative postal address, email address and telephone number
- Date of birth
- Elector number
For the Ward Lists, we process the following additional personal information where appropriate:
- Business name/address
- Job position
- Details of nominating qualifying body
For the Electoral Register, we process the following additional personal information:
- National insurance number
- Previous names
- Email address
For the Absent Voter Lists, we process the following additional personal information where appropriate:
- Details of blindness or other disability
- Occupation/employment/service/course details
- Registration as service voter, overseas voter, or anonymous elector
- Other location details
- Full name and address of proxy
- The family relationship between the elector and proxy (if any)
- Details of supporter including name, address, qualification to attest or support position and contact details
For the Common Hall Register, we process the following additional personal information:
- Livery Company membership(s)
For the Register of Commoners, we process the following additional personal information:
- Property in respect of claim to register as a commoner
For the voter list for BID Ballots:
- Business name/address
- Job position
In rare circumstances we may also collect information required as part of an application for anonymous registration including (but not limited to) court documentation, attestations from a qualifying officer and evidence in support of your application.
For employing election staff, we process the following personal information in addition to the information above:
- Bank account details, payroll number
- Emergency contact information
- Information such as salary, start date, working hours, job roles and any other benefits information.
- Right to work documentation, references, documents verifying identity and any other information included in the application form.
If you have any queries regarding the above, please email the Electoral Services Department.
If we have consent to use your personal information for any particular reason (not including collating the various versions of electoral registers) you have the right to remove your consent at any time. If you want to remove your consent, please email the Electoral Services Department.
The law gives you a number of rights in relation to what personal information is used by the Town Clerk, and how it is used.
You can ask us to:
- provide you with a copy of the personal information that we hold about you;
- correct personal information about you which you think is inaccurate;
- delete personal information about you if you think we no longer should be using it;
- stop using your personal information if you think it is wrong, until it is corrected;
- transfer your personal information to another provider in a commonly used format;
- not use automated decision-making processes to make decisions about you
The law does not allow us to change or delete personal information if it is included on a published version of the Electoral Register, Ward Lists, Common Hall Register or Register of Commoners.
In some circumstances, we use other organisations to either store personal information or use it to help deliver our services to you. Where we have these arrangements, there is always an agreement in in place to make sure that the organisation complies with data protection law.
The Ward Lists
The Ward Lists are the lists of everyone who is registered to vote in ward elections in the City of London. They record elector’s names, residential address or business name and address, an indication of eligibility to vote in City of London elections based on nationality and the elector’s number. We have a legal duty to allow public inspection of the Ward Lists and to provide copies to any person on request. However, in order to comply with data protection law, personal information in the Ward Lists may only be used for electoral purposes (including campaigning by candidates), and for strictly compatible purposes (for example, to enable elected members to carry out their ward duties). The Ward Lists must not be used for other unrelated purposes (for example, they cannot be used by a third party, including ward clubs, or for marketing purposes).
The Electoral Register
The Electoral Register lists everyone who is registered to vote in elections for the UK Parliament, the European Parliament and the Greater London Authority and other national polls, for example, referendums. It records voters’ names, address, an indication of eligibility to vote in elections based on nationality, the date of attainment of voting age if applicable and the electors’ number. The register is used for electoral purposes, such as making sure only eligible people can vote. It is also used for other limited purposes specified in law, such as:
- detecting crime (e.g. fraud)
- calling people for jury service
- checking credit applications
We have a legal duty to provide the electoral register to credit reference agencies, political parties, candidates, courts, the police, the City of London Corporation and other permitted recipients. Any other person may look at a copy of the Electoral Register under supervision, but may not search for names by electronic means or copy or transmit any part of it. It is a criminal offence for anyone to use or pass information from the Electoral Register onto others if they do not have a lawful reason for doing so.
We are also required by law to produce an Open Register (also known as the Edited Register). The Open Register is an extract of the Electoral Register, but is not used for elections. It can be bought by any person, company or organisation. For example, it is used by businesses and charities to confirm name and address details. If your name and address are included on the Electoral Register, they will also be included in the Open Register unless you ask for them to be removed. Removing your details from the Open Register does not affect your right to vote.
If you are concerned that having your name or address on the register may affect your safety, there could be other options available to you. In certain circumstances, you can register without your name and address showing on the register. To find out more, please email the Electoral Services Department. You can find out more information about both registers and how they may be used at The Electoral Register.
To verify your identity when registering to vote on the Electoral Register, the data you provide will be processed by the Individual Electoral Registration Digital Service managed by the Cabinet Office. As part of this process your data will be shared with the Department for Work and Pensions and the Cabinet Office suppliers that are data processors for the Individual Electoral Registration Digital Service. You can find more information on how to register to vote. In addition, on occasion we use the Cabinet Office GOV.UK Notify system to inform voters electronically of electoral registration or electoral issues.
Absent Voter Lists
The Absent Voter Lists contain information on postal, proxy and postal proxy votes, and there are separate lists relating to the Electoral Register and the Ward Lists. They record absent voters’ names, postal address, elector number and whether the absent vote is permanent or temporary. Absent Voter Lists and the information contained on the absent voting record which would be used to generate the lists in case of an election are available for public inspection and copies may be supplied, free of charge, to:
- elected representatives (in as much as they relate to their area)
- local constituency parties
- political parties (in as much as they relate to their area)
- candidates (in as much as they relate to the area in which they are standing or intending to stand)
The personal identifiers record is a record of absent voters’ signatures and dates of birth. This is not open to public inspection and is not available for supply.
The Common Hall Register
The Common Hall Register is a list of those liverymen who are eligible to vote in Common Hall in the nomination of candidates for Lord Mayor, and in the election of Sheriffs, Ale Conners, Bridgemasters and Auditors. It records voters’ name, address, Livery Company membership and Common Hall Register number.
We have a legal duty to allow public inspection of the Common Hall Register and to provide copies to any person on request. However, in order to comply with data protection law, personal information in the Common Hall Register may only be used for electoral purposes (including campaigning by candidates), and for strictly compatible purposes (for example, the identification of liverymen for related administrative purposes). The Common Hall Register is also archived in perpetuity for historical research purposes. The Common Hall Register must not be used for other unrelated purposes (for example by a third party, or for marketing purposes).
The Register of Commoners
The Register of Commoners is a list of individuals who are entitled to a right of common in or over Epping Forest and therefore entitled to vote in the election of verderers of Epping Forest. It records electors’ name, address of the property which gives rise to the claim to register as a commoner and elector number. We have a legal duty to allow public inspection of the draft Register of Commoners at the Guildhall and in the Forest prior to the septennial election of verderers. However, in order to comply with data protection law, personal information in the Register of Commoners may only be used for electoral purposes (including campaigning by candidates), and for strictly compatible purposes (for example, contacting commoners about matters relating to their rights of common). The Register of Commoners must not be used for unrelated purposes (for example by a third party, or for marketing purposes).
The voter list for BID Ballots
The voter list is a list of individuals who are entitled to vote at a BID Ballot. It records the name, business address and contact address of the voters. The information contained in the voter list will be shared with the BID proposer.
We have a legal duty to make sure we hold your personal information (on paper and electronically) in a secure way, and to only make it available to those who have a right to see them. Examples of our security include:
- Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password).
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- Training for our staff allows us to make them aware of how to handle personal information, and how and when to report when something goes wrong
- Regular testing of our technology and ways of working, including keeping up to date on the latest security updates (commonly called patches)
You can find more details of our Information Security expectations in the City of London IT Security Policy.
The majority of personal information is stored on systems in the UK or EU. However, there are some occasions where certain personal information may leave the UK/EU either in order to get to another organisation, or where it is stored in a system outside of the EU.
We may send out information concerning elections or electoral registration via MailChimp which will result in your email address being transferred to the United States. We have additional protections on your personal information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We will only hold your personal information for as long as it is necessary to fulfil our legal duties or business purposes. There’s often a legal reason for keeping your personal information for a set period of time.
If you have any concerns or questions about how we look after your personal information, please contact the Town Clerk’s Data Protection Officer, Michael Cogher. You can email the Electoral Services Department or write to PO Box 270, Guildhall, London, EC2P 2EJ.
For details about how the City of London Corporation uses your information and protects your privacy, go to the Privacy Notice page.
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:
Water Lane , Wilmslow
Cheshire SK9 5AF