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Grooming Gang Justice Respond to the Consultation

Privacy and Data Protection Policy

Grooming Gangs Inquiry — Terms of Reference Consultation

This policy explains how personal data is collected, used and protected through this website in connection with the Independent Inquiry into Grooming Gangs draft Terms of Reference consultation and, where applicable, engagement activities of the Conservative and Unionist Party ("the Conservative Party" or "CCHQ").

This website is operated by Interlace Data Ltd ("Interlace"), acting as a data processor on behalf of the Conservative Party in respect of personal data collection. Interlace does not determine the purposes or means of processing your personal data — the Conservative Party does.

Data Controller and Processor

The Data Controller for personal data collected through this website is:

The Conservative and Unionist Party
CCHQ, 4 Matthew Parker Street, London, SW1H 9HQ

The Conservative Party determines the purposes and means of processing your personal data. Details of how the Conservative Party processes personal data can be found in their Privacy Policy.

Interlace Data Ltd acts as a data processor on behalf of the Conservative Party. Interlace processes your personal data solely in accordance with the Conservative Party's instructions and does not use your data for any independent purpose. A Data Processing Agreement is in place between Interlace and the Conservative Party in accordance with Article 28 UK GDPR.

For the anonymous consultation responses submitted to the Independent Inquiry into Grooming Gangs via SmartSurvey, the Inquiry itself is the data controller. That processing is governed by the Inquiry's own privacy notice, available at: gov.uk/government/publications/independent-inquiry-into-grooming-gangs-consultation-privacy-notice

Contact Details

What This Website Does

(a) Anonymous Consultation Submission

This website allows you to submit your views on the draft Terms of Reference for the Independent Inquiry into Grooming Gangs. Your consultation response is submitted to the Inquiry's official SmartSurvey. The Inquiry has explicitly stated that respondents should not include any identifying or personal information in their consultation responses. No personal data is collected or processed by Interlace or the Conservative Party for this purpose.

(b) Optional Personal Data Collection for the Conservative Party

Separately, and only with your explicit consent, this website may collect personal data on behalf of the Conservative Party for the purposes of political communication and democratic engagement. This is entirely optional and is not required in order to submit your consultation response.

Lawful Basis for Processing

For the anonymous consultation submission: no personal data is collected by this website, and therefore no lawful basis is required from Interlace or the Conservative Party for that activity. The Inquiry processes consultation responses under Article 6(1)(e) UK GDPR (public task).

For the optional collection of personal data on behalf of the Conservative Party: processing is based on your explicit consent (Article 6(1)(a) UK GDPR). Where the data reveals political opinions, this constitutes special category data processed on the basis of explicit consent under Article 9(2)(a) UK GDPR and in accordance with Schedule 1, Part 2 of the Data Protection Act 2018.

You may withdraw your consent at any time by contacting the Conservative Party at DataProtection@Conservatives.com.

Information We Collect

For the anonymous consultation submission, this website does not collect any personal data.

Where you separately consent to sharing your data with the Conservative Party, we may collect:

  • Your name
  • Email address
  • Postcode

Special Category Data

By choosing to share your personal data through a politically-affiliated website, your political opinions may be revealed. This constitutes special category data under UK GDPR, processed on the basis of your explicit consent and in accordance with Article 9(2)(d) UK GDPR and Schedule 1, Part 2 of the Data Protection Act 2018.

Data Security

Personal data collected on behalf of the Conservative Party is temporarily stored on secure servers located in the UK (AWS eu-west-2, London region) prior to transfer to the Conservative Party. Interlace retains personal data only for the minimum period necessary to complete the transfer, after which it is securely deleted from Interlace's systems.

Sharing of Personal Data

If you provide consent, your personal data will be transferred to the Conservative Party, who as Data Controller will process it in accordance with their Privacy Policy. Anonymous consultation responses are submitted directly to the Inquiry via SmartSurvey, without any personal data attached. We do not sell personal data.

Data Retention

Interlace retains personal data only for the period necessary to transfer it to the Conservative Party. In normal circumstances, this will be no longer than 6 weeks from the date of collection, after which data is securely deleted. For information about how long the Conservative Party retains your data, please refer to their Privacy Policy.

International Data Transfers

Personal data processed by Interlace is stored on servers located in the United Kingdom (AWS eu-west-2, London). Interlace does not transfer personal data outside the United Kingdom.

Cookies and Tracking

This website does not use cookies, analytics, or tracking technologies.

Your Rights

Under UK GDPR, you have the right to:

  • Request access to the personal data held about you
  • Request correction of inaccurate or incomplete information
  • Request erasure of your data (where applicable)
  • Withdraw consent at any time
  • Object to certain types of processing
  • Lodge a complaint with the Information Commissioner's Office (ICO)

Rights requests should be directed to the Conservative Party at DataProtection@Conservatives.com.

Complaints

If you are dissatisfied with how your data has been handled, you may contact the Conservative Party at DataProtection@Conservatives.com or the Information Commissioner's Office:

  • Website: ico.org.uk/concerns
  • Telephone: 0303 123 1113
  • Address: Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Changes to This Policy

We may update this policy from time to time. Where changes materially affect your rights, we will make this clear on the website.