ABOUT THIS NOTICE
We are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
If you have any questions about this notice or how we collect and use personal information about you please contact us.
INFORMATION ABOUT US
- We are The Office of David Cameron Limited. Our registered office is at The Poplars, Bridge Street, Brigg, North Lincolnshire, United Kingdom, DN20 8NQ and our registered company number is 10421190.
- If you have any questions, you can contact us at The Office of David Cameron, PO Box 73981, London, United Kingdom, SW1P 9PN or via the Contact page.
- The rest of this notice provides more information about what information we use and how we use it. Our activities mainly relate to:
- dealing with enquiries, casework and other correspondence addressed to David Cameron;
- providing information about, and administering, David Cameron’s activities, including his public duties and appearances; event attendance; speaking engagements; charitable and business activities; and
- operating and administering our website, davidcameronoffice.org, and social media accounts.
OUR INTERACTIONS WITH YOU
- Correspondence. If we correspond or otherwise interact with you (for example by e-mail, telephone, post, SMS or via our website), it will include personal information (such as names and contact details) in that correspondence. Correspondence may include enquiries, follow-up comments or casework, as well as greetings cards (which may be sent by post or e-mail), and information about attendance at events.
- Social media. We operate a number of social media accounts (including on Facebook and Twitter). If we engage with you on social media, we may use information you share with us (including your social media handle or profile) or which is available from your account to inform our correspondence with you.
- Events. We may also receive information about you as part of your attendance at an event, which may include your name, contact details, and participation in the event.
- We will keep and use that information for our legitimate interests in dealing with enquiries or casework, to review and improve how we operate, for administrative purposes (including managing events), and to correspond with you.
- If your information is on social media, it will be retained in accordance with the relevant social media platform’s policies. Otherwise, if we directly hold your data, it will be kept for up to 7 years after our last interaction with you.
NEWSLETTERS AND INFORMATION
- Newsletters and invites. If you subscribe to receive updates from us (such as newsletters or event invites), we will use the information you provide (such as your name and contact details) in order to send you relevant information.
- We only use this information to send you newsletters, invites and similar information if you have consented to us using it for this purpose. You can withdraw your consent at any time by contacting us. We also always provide an unsubscribe option as part of our updates to allow you to opt out.
- Unsubscribing. If you “opt-out” of our newsletters, invites or other information, you will be added to our unsubscribe list to ensure we do not accidentally send you further updates. We may still need to contact you for administrative or operational purposes, or as part of our correspondence with you, but we will make sure that those communications do not include newsletters, invites or other information which you have opted out of.
- We never share your name or contact details with third parties for marketing purposes. We may use third party service providers to send out our newsletters, invites or similar information, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
- We retain your details on the relevant list based on your consent until you “opt-out” at which point we add you to our unsubscribe list. We keep that unsubscribe list indefinitely to comply with our legal obligations to ensure we do not accidentally send you any more newsletters, invites or similar information.
- We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. This may include your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. We use this as necessary for our legitimate interests in administering and improving our website and its content, to ensure it operates effectively and securely, and to develop our business and inform our decisions. We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors) which is not personal information about you.
- For detailed information on the cookies on our site and the purposes which they are used for see our Cookie Notice.
- We keep this website information about you for up to 24 months from when it is collected or the relevant cookie expires.
- Third party websites. Our website may contain links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
PHOTOS, CONTENT AND PROMOTIONAL MATERIAL
- This is information about you which you provide to us, or images or recordings of you which you allow us (or someone on our behalf) to take (including at events or as part of a campaign), for publication or display. This may include comments, profiles, photographs (including stock photos and advertising material) and videos.
- We may display and publish this content (and, if relevant, attribute it to you) on our platforms as necessary for our legitimate interests in providing content and for promotional or informational purposes (or, in some circumstances, because you have specifically consented to us doing this).
- This information is kept and published or displayed by us for as long as we consider it relevant for those purposes. You can ask us to remove or delete your content at any time (subject to any agreements about our right to use it) by contacting us. If we are displaying or publishing the information based on your consent, you have the right to withdraw that consent at any time.
- If you work for one of our suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
- We keep this information for up to 7 years after the end of our relationship with your organisation.
JOB AND INTERNSHIP APPLICATIONS, REFEREES AND EMERGENCY CONTACTS
- We will collect and hold information on job or internship applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide. We may also collect information about your professional history which you make available on LinkedIn, or which is on your employer’s website, or where relevant from a background check provider.
- We use this as necessary to enter into an employment or internship contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights. Where you voluntarily provide us with special categories of data, such as information about your race, health or sexuality, we will store this as part of your application on the basis that you have decided to make it public to us for this purpose, and to ensure that our record of your application is accurate so we can comply with (and demonstrate our compliance with) our obligations under employment law.
- If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice. If you currently work for us, or used to work for us, you can request a copy of this from us. If you are not successful in your application, your information will be held:
- for up to 2 years to contact you about potential future opportunities, unless you let us know that you do not want to be contacted, or you ask us to keep it for longer to contact you; and
- in any event, for up to 6 months after the relevant round of recruitment has finished, so we can deal with any queries about the recruitment process.
- You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
- If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.
- If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that member of staff. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that member of staff. Your information will be kept until it is updated by that member of staff, or we no longer need to contact them after they have stopped working for us.
Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
INFORMATION WE RECEIVE FROM THIRD PARTIES
- We may also receive information about you from the following sources:
- Our service providers and partners. We work closely with third parties (including, for example, event organisers, business partners, charities, NGOs, think tanks, and sub-contractors in technical services) who may provide us with information about you, to be used as set out in this privacy notice.
- Our personnel. Given the nature of our work, you may deal with representatives of our organisation as individuals (rather than as “The Office of David Cameron Ltd”). In those circumstances, where it is appropriate, they may share relevant information with us in relation to our professional activities. For instance, you may only have had contact with David Cameron in his personal capacity, but you may be contacted by us in relation to potentially working together.
- Publicly available sources. If relevant, as part of our relationship with you, we may obtain information from publicly available sources such as Companies House, LinkedIn, news articles or employer websites.
SPECIAL CATEGORIES OF INFORMATION
- Other than as set out in this notice, we do not collect any “special categories” of more sensitive personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, as well as information about criminal convictions and offences).
- If you contact us and provide us with any “special categories” of information about yourself as part of your correspondence with us, we will only use these as necessary to respond to you and answer any queries you have raised. This information will be stored as part of (and dealt with on the same basis as) your communication with us and kept for the same period of time. We do not require you to provide any “special categories” of information to us, it is entirely voluntary on your part, and so we use it in relation to your correspondence with us on the basis that you have manifestly made it public to us.
WHY ELSE DO WE USE YOUR INFORMATION?
- Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:
- we need to perform a contract we have entered into with you;
- we need to comply with a legal obligation;
- it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests; or
- we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
- Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
SHARING YOUR INFORMATION
- We never sell your data to third parties.
- Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, or others or where we have another legitimate interest in doing so.
- As well as any sharing listed above, we may also share your information with third-party service providers. Our service providers are required to respect the security of your personal information and to treat it in accordance with the law. We may use third-party service providers in relation to the following types of activity: legal advice; contract administration; and IT services.
- How secure is your information with third-party service providers? All our third-party service providers are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
- What about other third parties? We may share your personal information with other third parties, for example with professional advisers. We may also need to share your personal information with a regulator or to otherwise comply with the law.
WHERE WE STORE YOUR INFORMATION
- Our office headquarters are based in London. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers.
- We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
- Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
- If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
- We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
- In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
- Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
- Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
- Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
- Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.
- No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights described above). However, we may refuse to comply with a request if it is clearly unfounded or excessive.
- What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified.
- Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.