Legal

Data Protection Policy

How the Forum handles personal data internally — the obligations our volunteers work to.

Placeholder — legal review required

The text on this page was drafted for a prototype to show the shape and tone of the policy. It is GDPR-aware but has not been reviewed by a qualified adviser and must not be relied upon or published as-is.

Scope

This policy applies to every trustee, coordinator, policy group member and volunteer of British Overseas Voters Forum who handles personal data on the Forum’s behalf, wherever in the world they are.

Principles

We handle personal data:

lawfully, fairly and transparently;
only for the purposes we told people about;
keeping only what we actually need;
keeping it accurate and up to date;
keeping it no longer than necessary;
securely.

Particular sensitivities for this organisation

A list of British citizens abroad, organised by country and by the political issues that concern them, deserves more care than its apparent sensitivity suggests. Accordingly:

We never share supporter data with political parties, in any form, including aggregate lists.
We do not record voting intention and volunteers must not record it in free-text fields.
Branch coordinators see only their own branch’s data, and only what they need to do their role.
Case studies are anonymised and published only with explicit, recorded permission.

Responsibilities

Trustees are accountable for compliance and review this policy annually.
A named trustee is the point of contact for data protection matters and subject access requests.
Volunteers must use Forum systems rather than personal spreadsheets, and must not export data without authorisation.

Retention

Supporter records are kept until the individual unsubscribes; member records for the membership term plus the period required for financial records; consent records for as long as we rely on the consent plus a reasonable evidential period. Records are reviewed annually and deleted or anonymised when no longer needed.

Subject access, export and deletion

Requests are answered within one calendar month. The admin dashboard provides data export and deletion functions so that requests can be actioned without engineering involvement. In this prototype those functions are demonstrated as stubs which show what would be exported or removed.

Security

Passwords are stored hashed and salted, never in plain text.
Access to the admin dashboard is restricted to named trustees.
Data is held in a hosted database within the UK or EEA.
Volunteers use unique accounts; shared logins are not permitted.

Breaches

Any suspected breach must be reported to the responsible trustee immediately and never handled informally. Breaches posing a risk to individuals are reported to the Information Commissioner’s Office within 72 hours, and affected individuals are told without undue delay where the risk is high.