Privacy Notice for Correspondence received by the Office of the Registrar of Consultant Lobbyists (ORCL)
Published on: Friday 19th November 2021
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
The data
We will process the following personal data:
Name, address and email address of the correspondent, as well as their opinions and details of any concerns raised in their correspondence. It is possible that correspondents will volunteer additional biographical information about themselves or third parties.
We may process special category data or data about criminal convictions if such data is volunteered by the correspondent. Special categories of personal data include data about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health, or sex life or sexual orientation.
Purpose
The purpose for which we are processing the personal data is to respond to letters, emails or other communications from Members of Parliament, Peers, Stakeholders and members of the public.
Legal basis of processing
The legal basis for processing the personal data is that processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. In this case, that is being accountable and transparent about the functions and policies for which ORCL is responsible.
Where special category data or data about criminal convictions is volunteered by a correspondent, our legal bases relied upon for processing it are:
(1) The processing is necessary for reasons of substantial public interest for the exercise of a function of the Crown, a Minister of the Crown, or a government department. The substantial public interest is being accountable and transparent about the functions and policies for which ORCL is responsible; and
(2) The processing consists of the disclosure of personal data to an elected representative or a person acting with the authority of such a representative; and it is in response to a communication to the controller from that representative or person which was made in response to a request from an individual; and the personal data is relevant to the subject matter of that communication; and the disclosure is necessary for the purpose of responding to that communication.
Recipients
Your information may be shared with other public bodies, or the devolved administrations, where it is necessary and in order to provide a full answer to you.
Your information may be shared with other public bodies, the devolved administrations, constituency offices or political parties, where it is necessary to transfer correspondence to a more appropriate body for an answer.
Your information may be shared with your MP, where they are writing on your behalf.
As personal data will be stored on our IT infrastructure, it will also be shared with our data processors, who provide email and document management and storage services.
Source of information
Where we did not receive your personal data from you, it was received by your MP, or by another person writing in on your behalf, or by a correspondent.
Retention
Personal information in correspondence will usually be deleted three calendar years after the correspondence or case is closed or concluded.
Public correspondence may however be kept if it is sufficiently significant that it should be retained for the historical record.
YOUR RIGHTS
You have the right to request information about how your personal data are processed, and to request a copy of that personal data.
You have the right to request that any inaccuracies in your personal data are rectified without delay.
You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.
You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.
You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.
You have the right to object to the processing of your personal data.
INTERNATIONAL TRANSFERS
As your personal data is stored on our IT infrastructure, and shared with our data processors, it may be transferred and stored securely outside the UK. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses.
COMPLAINTS
If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or 0303 123 1113, or casework@ico.org.uk.
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
CONTACT DETAILS
The data controller for your personal data is the Office of the Registrar of Consultant Lobbyists, 1 Horse Guards Road (Room 3.26), London, SW1A 2HQ, or 020 7271 8827, or office@orcl.gov.uk .
The contact details for the data controller’s Data Protection Officer are: Stephen Jones, Data Protection Officer, Cabinet Office, or dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring of use of personal information by the Registrar and their Office.