Privacy Policy
The Borough first Independents is committed to protecting your personal information, respecting your privacy and being clear about how information about you is used.
We aim to be open about the information we hold and why we need it.
Personal information should be relevant to the purpose for which it is used.
Appropriate measures are used to protect the personal information we hold.
Data protection law gives you rights over how your information is used.
Who we are
The Borough first Independents ("tBfI") is a registered political party operating within the Royal Borough of Windsor & Maidenhead.
For the purposes of data protection law, The Borough first Independents is the data controller for personal information collected and used by the organisation.
We process personal information in accordance with applicable UK data protection and privacy legislation, including the UK GDPR and the Data Protection Act 2018.
Questions about this policy or the way we use personal information can be sent to:
For questions about personal data, privacy rights or this policy.
For general enquiries about the Borough first Independents.
What information we may collect
The information we collect depends on how you interact with tBfI.
This may include:
- Your name.
- Your postal address or area of residence.
- Your email address and telephone number.
- Information you provide when contacting us.
- Information submitted through website forms or surveys.
- Membership information.
- Information relating to volunteering, campaigning or community activity.
- Information provided when you sign up for news or updates.
- Donation information where applicable.
- Feedback, opinions or responses to questions and surveys.
- Records of communications with us.
Membership
Membership information may be stored and administered using the membership management platform MemberMojo.
How we may use your information
Depending on the circumstances, we may use personal information to:
- Respond to enquiries and communications.
- Communicate about local issues, campaigns and community matters.
- Understand residents' views and local priorities.
- Carry out surveys and democratic engagement.
- Manage members and supporters.
- Manage volunteers and campaign activity.
- Organise meetings, events and community activity.
- Communicate with people who have asked to receive updates.
- Administer donations and maintain appropriate financial records.
- Comply with electoral, financial, legal and regulatory obligations.
- Protect the security and integrity of our website and systems.
Our lawful basis for processing
Data protection law requires us to have a lawful basis whenever we process personal information.
The appropriate basis depends on the particular activity and circumstances. Depending on the purpose, this may include:
For example, where consent is the appropriate basis for receiving particular electronic communications.
Where our legitimate interests provide an appropriate lawful basis and those interests are not overridden by your rights and interests.
Where applicable law provides a suitable basis for activities supporting democratic engagement.
This may include requirements relating to political donations, elections, financial records or regulatory compliance.
Where consent is relied upon, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
Political opinions and sensitive information
Some information used in political activity may reveal or suggest an individual's political opinions.
Political opinions are given additional protection under data protection law and are treated as special category personal data.
Extra protection for political data
Where tBfI processes information revealing political opinions, we will only do so where an appropriate lawful basis and special-category processing condition applies, together with any safeguards required by data protection law.
Depending on the circumstances, this may include information you have provided directly, information relating to membership or regular support, explicit consent, or processing permitted to registered political parties under applicable law.
We aim to avoid collecting or using sensitive information where it is not necessary for the purpose concerned.
Where information may come from
Most information we hold is provided directly by the person concerned.
Depending on the activity, information may also come from:
- Membership and supporter records.
- The electoral register where political parties are lawfully entitled to use it.
- Volunteer or campaign records.
- Donation and payment service providers.
- Publicly available information where its use is lawful and appropriate.
- Third parties where information has been lawfully provided to us.
Where data is obtained from another source, we will consider the applicable transparency requirements and how the information can lawfully be used.
Sharing your information
We do not sell your personal information.
We may use trusted service providers to help operate our organisation and website. Depending on the service concerned, these may include:
- Website hosting and technical providers.
- Email and communication services.
- Membership management services such as MemberMojo.
- Payment and donation providers.
- Professional advisers where necessary.
Where an organisation processes personal information on our behalf, we expect it to protect that information and only use it for the agreed purpose.
We may also disclose personal information where required by law, electoral regulation, a regulator, court or other competent authority.
Donations and PayPal
The website provides links allowing supporters to make donations through PayPal.
Payment information submitted on PayPal's website is processed by PayPal in accordance with its own privacy arrangements.
tBfI may receive information relating to a donation that is necessary to administer the payment, maintain financial records and comply with electoral law.
This may include information such as the donor's name, contact information, donation amount and transaction details.
Political donations may be subject to statutory record-keeping, permissibility checks and reporting requirements.
tBfI donation page →Website data and cookies
Our website is built using WordPress and may use strictly necessary or technical cookies and similar technologies required for website operation, security, forms or other essential functionality.
We do not intend to use advertising or behavioural tracking technologies to build profiles of website visitors without the appropriate information and controls.
If non-essential cookies or similar tracking technologies are introduced, we will provide appropriate information and obtain consent where required by law.
Website forms
If you submit information through a form on this website, we will use the information provided to respond to your enquiry or for the purpose explained when the information is collected.
Technical information
Website hosting, security or server systems may process limited technical information, such as IP addresses, browser information, timestamps and security logs, where necessary to operate and protect the website.
How long we keep information
We do not aim to keep personal information for longer than it is needed.
Retention periods vary depending on the purpose for which information is held and any legal or regulatory requirements that apply.
Factors we may consider include:
- Why the information was collected.
- Whether there is an ongoing relationship with the individual.
- Whether the information is still necessary for political, membership, administrative or community activity.
- Legal and regulatory record-keeping requirements.
- The need to establish or respond to legal claims.
Security
We take reasonable organisational and technical steps to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
Your data protection rights
Depending on the circumstances and the lawful basis being used, you may have rights including:
- The right to ask what personal information we hold about you and obtain a copy.
- The right to ask us to correct inaccurate or incomplete information.
- The right to ask for personal information to be erased in certain circumstances.
- The right to ask us to restrict the use of your information in certain circumstances.
- The right to object to certain processing.
- The right to data portability where applicable.
- The right to withdraw consent where processing is based on consent.
These rights are not all absolute and whether a particular right applies may depend on the reason we are processing the information.
Your right to object to direct marketing
You can ask us to stop using your personal information for direct marketing at any time. If an email communication contains an unsubscribe option, you can also use that to stop future messages of that type.
To exercise a data protection right, contact webmaster@theboroughfirst.org.
Councillor casework
Residents may contact individual tBfI councillors for assistance with council casework.
Where a councillor is acting in their official role as an elected member of the Royal Borough of Windsor & Maidenhead, the handling of casework information may be subject to separate council or councillor data protection arrangements rather than being processing carried out by tBfI as a political party.
Residents should use a councillor's @rbwm.gov.uk council email address for official council casework wherever possible.
Children's information
We recognise that personal information about children and young people requires particular care.
We do not intentionally collect more information about children than is necessary for the particular activity or purpose.
Where information about a child is provided in connection with resident casework or a community matter, it should only be used where necessary and handled with appropriate safeguards.
International data transfers
Some technology or service providers may process information outside the United Kingdom.
Where personal information is transferred internationally, we expect appropriate legal safeguards to be used where required by UK data protection law.
Questions and complaints
If you have a concern about how tBfI has handled your personal information, please contact us first so that we have an opportunity to investigate and respond.
Privacy and data protection enquiries should be sent to:
webmaster@theboroughfirst.org
You also have the right to raise a concern with the UK's independent data protection regulator, the Information Commissioner's Office (ICO).
Information Commissioner's Office →Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our activities, services, technology or legal obligations.
The date at the top of this page shows when the policy was most recently updated.
Have a question about your data?
If you want to exercise a data protection right or have a question about how tBfI uses your personal information, please contact us.