Office of Rt Hon Anna Soubry MP

Data Protection Policy


This document outlines how the Office of Anna Soubry MP processes and manages personal data. It:

1) identifies our data controller;

2) provides our lawful basis for processing personal data;

3) outlines the scope of personal data we hold and process;

4) outlines the scope of the special category personal data we hold and process;

5) describes and justifies our data retention policy;

6) shows how we intend to respond to Subject Access Requests; and

7) contains a copy of our privacy notice.

The policies outlined within this document come into full effect on Friday 25th May 2018.


  1. Data Controller


The Data Controller is Anna Soubry MP.


  1. Lawful basis for processing


  1. Casework is processed primarily under the lawful basis of public task, with exceptional cases processed under the lawful basis of consent.
  2. Personal data contained in the non-political Anna Soubry MP Mailing List is processed under the lawful basis of consent and public task. It does not fall within the definition of direct marketing.
  • We undertake to always act within the reasonable expectations of our constituents and any other individuals about whom we hold personal data.


  1. Data we hold


As of 25th May 2018, the office holds information on all registered voters in Broxtowe. The electoral register is passed to us by Broxtowe Borough Council. In addition, this office holds personal information to carry out the duties of an MP in the following categories; casework, policy casework, mailing lists, paper surveys.


We operate a paperless office. Personal data is stored electronically and securely on our computer systems. These computers are in offices which are locked when unattended.




The Office uses a CMS (Content Management System) application, Cross Reference, to help with the management of constituent casework records. This information predominantly includes but is not limited to:

▪ Names, addresses and email addresses.

▪ Telephone numbers.

▪ National Insurance Numbers, Passport Numbers.

▪ Special category data, outlined in point 4.




Policy casework is stored on Cross Reference.


This information predominantly includes but is not limited to:


▪ Names, addresses and email addresses.

▪ Telephone numbers

▪ Special category data


Mailing lists


The Office also maintains a mailing list to Anna Soubry MP’s email newsletter. These subscribers receive Margot’s weekly email newsletter and information about constituency events. This data is held with the Mailchimp service, based in the US certified under the Privacy Shield regime. Personal data we hold in this regard includes:


▪ Names, addresses and email addresses.


This information is not political in nature and therefore it is not categorised as direct marketing.


Paper surveys


The Office conducts occasional paper surveys of constituents in order to better understand their views on local issues. Personal data we hold in this regard includes:


▪ Names, addresses and email addresses.

▪ Telephone numbers

▪ Special category data


Any survey requires explicit consent to be given for data to be retained.





  1. Special category data we hold


The office may also hold special category data for a smaller number of data subjects. This data will be processed under the lawful basis indicated in point two, as is permitted in clauses 23 and 24 of schedule 1 of the Data Protection Act. The data may include:


▪ Political opinions

▪ Religious beliefs

▪ Trade union activities

▪ Sexual orientation

▪ Race and ethnic origin

▪ Details of criminal offenses

▪ Physical and mental health


  1. Data retention policy


Our office will hold personal data for no longer than the duration of Anna Soubry’s time in Parliament as MP for Broxtowe. From Friday 25th May 2018, we will only hold data dating from Thursday 6th May 2010. Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. Therefore, it is reasonable for an elected representative to hold personal data for the duration of their time representing a constituency.


  1. Subject Access Requests


We will comply with Subject Access Requests in line with the guidance given by the Information Commissioners Office (ICO).


  1. We will respond as quickly as possible, within 30 calendar days.
  2. We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
  • Data subjects have the right to the following:
  1. To be told whether any personal data is being processed
  2. To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people.
  3. To be given a copy of the information comprising the data, and given details of the source of the data where this is available.


  1. Making people aware of the Privacy notice


Our office will undertake to ensure all constituents sharing their personal data can have the opportunity to read our privacy notice. We will:


  1. Publish our privacy notice on Anna’s website,
  2. Add a link to our privacy notice on Anna’s auto-response on Microsoft Outlook.
  • Direct constituents who contact us via letter and telephone to our privacy notice online, or supply them with a paper copy if needed.
  1. Modify our voicemail messages to include information about how constituents can read our privacy notice.


Privacy Notice


I will only use the information you have given to my office for the purposes of which you have asked. Your data will be processed under the lawful basis of “public task and legitimate interest” and/or “explicit consent” according to the Data Protection Act 2018. I will not share your information other than for these purposes. It is easy to withdraw your consent at any time by contacting my office.