BRENDAN SMITH T.D.
As an elected representative, candidate for office and Fianna Fáil party member, I take your privacy seriously. This statement sets out how my staff and I use, hold, share and otherwise process personal data. In particular, we are committed to processing the personal data of constituents and other individuals in a fair, lawful and transparent manner. In relation to any data that we obtain and hold, I will be responsible for ensuring that such data is used, stored and eventually destroyed in compliance with data protection law.
- What is personal data?
Personal data is any information relating to a living individual which allows either directly or indirectly the identification of that individual. Personal data can include a name, address, date of birth, contact details and any other details specific to that individual and that would allow the individual to be identified.
Data protection law also recognises that certain data of a sensitive nature requires additional protection. These so-called special categories of personal data (“SCPD”) in particular include data relating to health, race / ethnicity, sexual orientation and political opinions. Data protection law also requires that any data relating to criminal offences / convictions be given special protection.
- How we collect your personal data
In most cases, we will collect your personal data directly from you in the context of canvassing activities and when going about constituency work. For example, this will include situations where you provide your contact details to me or my staff while we are canvassing or where you send an email or make a phone call to the constituency office.
We may also obtain certain personal data from third parties, including from colleagues and other individuals in the constituency. For example, if somebody asked me or my team to contact a particular individual in relation to a particular issues, they may provide us with the contact details for that individual. From time to time, we will also obtain personal data from publicly available sources, including from media reports, websites and the Electoral Register.
- How we use your personal data
We use personal data for a range of purposes depending on the particular circumstances. Generally speaking these purposes are as follows:
- Constituency work and requests/representations: My team and I are provided with personal data, on a daily basis relating to a wide range of issues involving constituency work. The nature of this work varies as does the type of personal data that we are provided with. On one hand, this data can relate to contact details of individuals within the constituency or elsewhere which is used for the purpose of making contact with those individuals. On the other hand, we often receive representations and requests concerning sensitive issues relating to, by way of example, the health, wellbeing and finances of individuals. Such data will regularly include special categories of data such as data concerning health, trade union membership and political views etc.. My team and I will use such data only for the purpose(s) for which the data has been provided to us. This may involve us sharing that data with a limited number of individuals, such as the party spokesperson on a particular issue (e.g. Health or Education) or a government minister or official in connection with a request or representation, as permitted by data protection law.
- Canvassing and political purposes: As an elected representative, my team and I will also use personal data in connection with our electoral purposes. This involves the communication of our policy views through written leaflets, social media, email bulletins and also in the course of door-to-door canvassing. When we contact you, it may be because you signed up to receive an email bulletin at a campaign event, via one of my social media pages or when you met me or a member of my team in person. This may also entail us keeping records of the political interests and affiliations of individuals whom we come into contact with. Because this data will often relate to your political views we will take special care when using this data as permitted by data protection law. Of course, if you no longer wish to receive information from us and/or would like us to remove your name and contact details from our lists, you can do by contacting my constituency office at: [email@example.com]
- Staffing and volunteering: As part of work described above, my team and I are always on the lookout for capable and trustworthy volunteers and staff to assist us. From time to time we may obtain personal data, such as contact details, of potential new staff and volunteer recruits and candidates for office. We will use such data initially to assess the suitability of such individuals for any roles that may be available and subsequently also to make contact with them.
- Your rights under data protection law
Under data protection law you have various rights, which include:
- the right of to receive detailed information on the processing of your personal data;
- the right of access to your persona data that we hold on you;
- the right to have personal data that we hold rectified, restricted or erased (known as the “right to be forgotten”);
- the right to object to the processing of your personal data by us in certain circumstances, including in relation to automated decision making, including profiling and where processing is based on our legitimate interests.
- Disclosing personal data
In limited circumstances, we may disclose personal data to third parties, or allow third parties to access personal data that we hold. An example includes where we use a third party company to help us to circulate email bulletins. Where we are required to do so, we enter into written agreements with third parties that process any personal data on our behalf and we will ensure that the appropriate contractual protections are in place to safeguard such personal data. From time to time we may also disclose data to our professional advisors such as external lawyers or accountants.
Other examples include where we share personal data (including special categories of data such as health information) with the party spokesperson on a particular issue (e.g. Health or Education) or a government minister or official or a local councillor in connection with a request or representation from or on behalf of an individual.
- Data Retention
We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as such purposes are set out in this Statement). The duration for how we retain personal data will vary depending on the type of personal data we hold and the purpose(s) for which we have obtained it.
- Further Information
You can ask a question, make a request or seek further information in relation this Statement by contacting my constituency office at [firstname.lastname@example.org]. While you also have the right make a complaint in respect of our compliance with data protection law to the Irish Data Protection Commission, we would request that you contact us in the first instance to give us the opportunity to address any concerns that you may have.
Updated: November 2018