Privacy Notice for Freedom of Information requests and Subject Access Requests
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purposes for which we are processing your personal data are:
To record and respond to freedom of information requests and data subject access requests received by the Registrar and their Office.
The data
We will process the following personal data: your name, address, email address, and your request. We may also process other personal data if you volunteer it.
In responding to subject access requests we may process any data on you held by the Registrar and their Office.
Legal basis of processing
To respond to freedom of information and data subject requests, the legal basis for processing your personal data is that it is necessary to comply with a legal obligation placed on us as the data controller.
Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Although we do not collect any sensitive personal data, we may process this in responding to a subject access request. We may also process data about criminal convictions in responding to a subject access request.
The legal basis for processing your sensitive personal data, or data about criminal convictions, is that processing is necessary for reasons of substantial public interest for the exercise of our functions. The function is meeting our legal obligations to answer subject access requests.
Recipients
As your 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.
Retention
Your personal data will be kept by us for up to three years since your last contact with us.
Copies of identity verification documents will be destroyed after we have verified your identity.
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 where it is processed for direct marketing purposes.
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 dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring of the use of personal information by the Registrar and their Office.
Privacy Notice for Correspondence received by the Office of the Registrar of Consultant Lobbyists (ORCL)
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.
Privacy Notice for the statutory duties of the Registrar of Consultant Lobbyists
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purposes for which we are processing your personal data are:
● To publish information required by law to be in the public domain about consultant lobbyists and their clients, and to be able to contact consultant lobbyists to maintain that information effectively.
● To enable the Registrar to fulfil their statutory responsibility to investigate possible consultant lobbying activity by unregistered organisations.
The data
In relation to maintaining the statutory published Register of Consultant Lobbyists, we will process the following personal data: name and business address of the Director(s) of the consultant lobbyist organisation (published); name of the client(s) of that consultant lobbyist (published); company number and VAT number (published); name, business and email address, and telephone number of the nominated ‘point of contact(s)’ provided to us by the consultant lobbyist. We may also process other personal data if you volunteer it.
In relation to investigating possible unregistered consultant lobbying activity, we will process names and business contact information (address, email address, and telephone number) necessary to conduct enquiries. We may also process other personal data if you volunteer it.
Legal basis of processing
The legal basis for processing your personal data is that processing is necessary for the Registrar to comply with the duties placed on them by Part 1 of the Transparency of Lobbying [etc] Act 2014, i.e. to maintain a published Register of Consultant Lobbyists, and to investigate potential unregistered consultant lobbying (including the taking of appropriate action if such activity has taken place).
Recipients
As your 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. As indicated above, certain data collected for the maintenance of the published Register will be published on that Register.
In serious cases where an organisation has breached the requirements of the Transparency of Lobbying [etc] Act 2014, the Registrar is empowered to transfer the case to the Director of Public Prosecutions for potential criminal proceedings, which will involve the transfer to the DPP of the names and contact information of person(s) concerned.
Retention
Company data required to be included in the statutory published Register of Consultant Lobbyists will be kept by us indefinitely and published on our website. Archived copies of the Register are also transferred to The National Archive (generally after five years).
Personal data we hold will be retained for three years from the last date the related organisation was on the Register (in the case of point of contact information for registered organisations), or three years from the last contact as part of a Registrar’s investigation (in the case of an unregistered organisation).
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 where it is processed for direct marketing purposes.
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 the use of personal information by the Registrar and their Office.
Privacy Notice for external contact information
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purpose for which we are processing your personal data is to communicate with you.
The personal information is processed for the purpose of making contact with individuals for the following business purposes:
- making contact with suppliers about services actually or prospectively provided by them (for example, personal information about contact persons at suppliers we use, or about suppliers we may choose to use for occasional tasks)
- making contact with individuals to inform them, or seek their views, about our policies or proposals, outside of a formal consultation process (for example, contact details for people in charities or representative bodies)
- making contact with customers or clients about services provided to them by the Registrar
- making contact with potential consultant lobbyists to ensure they are aware of the statutory requirements
- making contact with officials in other departments or public bodies (including other governments) to discuss policy proposals or development, communications activity, or operational matters
The data
We will process the following personal data:
- your name
- address
- email address
- job title
- phone number
- signature
- employer
Where we have consulted you for your views, the information may include your opinions.
Legal basis of processing
The legal basis for processing your 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. The task is the development of Registrar’s policy, or the management of the Office of the Registrar.
Recipients
Your personal data will be shared by us with officials in other public bodies. This would be to assist in the development of policy, or for operational reasons.
As your 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.
Retention
Your personal data will be kept by us for the purposes of contacting individuals in particular roles, and once they leave those roles the information will be updated and or deleted. This should take place at least once a year.
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
- request that any inaccuracies in your personal data are rectified without delay
- request that any incomplete personal data are completed, including by means of a supplementary statement
- request that your personal data are erased if there is no longer a justification for them to be processed
- in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
- object to the processing of your personal data where it is processed for direct marketing purposes
- 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 telephone: 0303 123 1113, or email: 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 dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring on the use of personal information by the Registrar and their Office.
Summary of Investigation – CMEC UK & MENA Limited
September to November 2021
Organisation or Person Investigated
CMEC UK & MENA Limited
Matter(s) Investigated
Whether CMEC UK & MENA Limited is an unregistered consultant lobbyist
Registrar’s Decision
CMEC UK & MENA Limited is not an unregistered consultant lobbyist, based on detailed information and substantive assurances provided.
Summary of Rationale for Decision
Based on the explanation of CMEC UK & MENA Limited’s business activities and substantive assurances provided, I conclude that the company has not been engaging in consultant lobbying activity.
Chronology
| Date | Action |
| 16 September | Whistleblowing email received, giving information suggesting that CMEC UK & MENA Limited may be an unregistered consultant lobbyist. |
| 17 September | Formal letter from the Registrar to CMEC UK & MENA Limited giving background on the requirement for registering and asking if their activities fall within the criteria for registration. |
| 6 October | No response having been received, statutory Information Notice from the Registrar, requiring a response to his queries within 30 days. |
| 11 October | Response from rradar, solicitors acting for CMEC UK & MENA Limited, saying that their client did not receive the Registrar’s letter of 17 September |
| 14 October | Response from rradar that their client is aware of the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), is a not for profit company and does not engage in consultant lobbying. |
| 9 November | Letter from the Registrar, requesting more detail in relation to CMEC UK & MENA Limited’s activities, and clarifying that there is no exception for non-profits under the Act, |
| 11 November | Letter from rradar giving explicit and substantive assurances on behalf of their client that CMEC has never communicated with ministers or senior civil servants in order to lobby on anyone’s behalf. |
| 15 November | Letter from the Registrar closing the investigation. |
15 November 2021
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk
Privacy Notice for the statutory duties of the Registrar of Consultant Lobbyists
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purposes for which we are processing your personal data are:
- To publish information required by law to be in the public domain about consultant lobbyists and their clients, and to be able to contact consultant lobbyists to maintain that information effectively.
- To enable the Registrar to fulfil their statutory responsibility to investigate possible consultant lobbying activity by unregistered organisations.
The data
In relation to maintaining the statutory published Register of Consultant Lobbyists, we will process the following personal data: name and business address of the Director(s) of the consultant lobbyist organisation (published); name of the client(s) of that consultant lobbyist (published); company number and VAT number (published); name, business and email address, and telephone number of the nominated ‘point of contact(s)’ provided to us by the consultant lobbyist. We may also process other personal data if you volunteer it.
In relation to investigating possible unregistered consultant lobbying activity, we will process names and business contact information (address, email address, and telephone number) necessary to conduct enquiries. We may also process other personal data if you volunteer it.
Legal basis of processing
The legal basis for processing your personal data is that processing is necessary for the Registrar to comply with the duties placed on them by Part 1 of the Transparency of Lobbying [etc] Act 2014, i.e. to maintain a published Register of Consultant Lobbyists, and to investigate potential unregistered consultant lobbying (including the taking of appropriate action if such activity has taken place).
Recipients
As your 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. As indicated above, certain data collected for the maintenance of the published Register will be published on that Register.
In serious cases where an organisation has breached the requirements of the Transparency of Lobbying [etc] Act 2014, the Registrar is empowered to transfer the case to the Director of Public Prosecutions for potential criminal proceedings, which will involve the transfer to the DPP of the names and contact information of person(s) concerned.
Retention
Company data required to be included in the statutory published Register of Consultant Lobbyists will be kept by us indefinitely and published on our website. Archived copies of the Register are also transferred to The National Archive (generally after five years).
Personal data we hold will be retained for three years from the last date the related organisation was on the Register (in the case of point of contact information for registered organisations), or three years from the last contact as part of a Registrar’s investigation (in the case of an unregistered organisation).
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 where it is processed for direct marketing purposes.
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 the use of personal information by the Registrar and their Office.
Privacy Notice for Correspondence received by the Office of the Registrar of Consultant Lobbyists (ORCL)
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.
Privacy Notice for Freedom of Information requests and Subject Access Requests
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purposes for which we are processing your personal data are:
To record and respond to freedom of information requests and data subject access requests received by the Registrar and their Office.
The data
We will process the following personal data: your name, address, email address, and your request. We may also process other personal data if you volunteer it.
In responding to subject access requests we may process any data on you held by the Registrar and their Office.
Legal basis of processing
To respond to freedom of information and data subject requests, the legal basis for processing your personal data is that it is necessary to comply with a legal obligation placed on us as the data controller.
Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Although we do not collect any sensitive personal data, we may process this in responding to a subject access request. We may also process data about criminal convictions in responding to a subject access request.
The legal basis for processing your sensitive personal data, or data about criminal convictions, is that processing is necessary for reasons of substantial public interest for the exercise of our functions. The function is meeting our legal obligations to answer subject access requests.
Recipients
As your 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.
Retention
Your personal data will be kept by us for up to three years since your last contact with us.
Copies of identity verification documents will be destroyed after we have verified your identity.
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 where it is processed for direct marketing purposes.
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 dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring of the use of personal information by the Registrar and their Office.
Privacy Notice for external contact information
This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
YOUR DATA
Purpose
The purpose for which we are processing your personal data is to communicate with you.
The personal information is processed for the purpose of making contact with individuals for the following business purposes:
- making contact with suppliers about services actually or prospectively provided by them (for example, personal information about contact persons at suppliers we use, or about suppliers we may choose to use for occasional tasks)
- making contact with individuals to inform them, or seek their views, about our policies or proposals, outside of a formal consultation process (for example, contact details for people in charities or representative bodies)
- making contact with customers or clients about services provided to them by the Registrar
- making contact with potential consultant lobbyists to ensure they are aware of the statutory requirements
- making contact with officials in other departments or public bodies (including other governments) to discuss policy proposals or development, communications activity, or operational matters
The data
We will process the following personal data:
- your name
- address
- email address
- job title
- phone number
- signature
- employer
Where we have consulted you for your views, the information may include your opinions.
Legal basis of processing
The legal basis for processing your 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. The task is the development of Registrar’s policy, or the management of the Office of the Registrar.
Recipients
Your personal data will be shared by us with officials in other public bodies. This would be to assist in the development of policy, or for operational reasons.
As your 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.
Retention
Your personal data will be kept by us for the purposes of contacting individuals in particular roles, and once they leave those roles the information will be updated and or deleted. This should take place at least once a year.
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
- request that any inaccuracies in your personal data are rectified without delay
- request that any incomplete personal data are completed, including by means of a supplementary statement
- request that your personal data are erased if there is no longer a justification for them to be processed
- in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
- object to the processing of your personal data where it is processed for direct marketing purposes
- 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 telephone: 0303 123 1113, or email: 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 dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring on the use of personal information by the Registrar and their Office.
Privacy Notice for Office of the Registrar of Consultant Lobbyists (ORCL) Media list
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 personal data from queries in the same way as all correspondence.
In addition, journalists can opt into ORCL’s media list.
Purpose
The media list’s purpose is to inform journalists, who have opted in, when the Registrar of Consultant Lobbyists publishes an update such as an investigation case summary.
Legal basis of processing
The legal basis of processing is consent through opting into the ORCL media list. You can opt out of the list.
Recipients
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 another person writing in on your behalf, for example your colleague.
Retention
Your contact details will be kept on the ORCL media list until you opt out.
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 opt out of further updates.
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 where it is processed for direct marketing purposes.
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.