Privacy Notice for the statutory duties of the Registrar of Consultant Lobbyists
Wednesday 20th October 2021
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.