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Electoral Services - Privacy Notice

Who the council is and what the council does

For the purposes of Data Protection legislation, the Electoral Registration Officer (ERO) and Returning Officer (RO) are data controllers who collect and use information about residents to enable us to carry out specific functions for which we are statutorily responsible.

This privacy notice is provided for clarification on how Cotswold District Council's Electoral Registration and Electoral Administration Service handle your information.

Any questions regarding our privacy practices should be sent to:

Data Protection Officer (DPO)
Cotswold District Council
Council Offices, Cirencester, GL7 1PX
Email: [email protected] 
Tel: 01993 861194

Why the council needs your information and how the council uses it

We collect the information about people as set out below, to enable us to carry out specific functions for which we are responsible and to provide you with a statutory service. Anyone to whom we disclose your information has a legal duty to keep it confidential: www.electoralcommission.org.uk/running-electoral-registration-england/access-and-supply-electoral-register/restrictions-use-full-register

What is the legal process for collecting and processing this data

Under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, the lawful bases we rely on for processing this information are:

  • Article 6 (1) (a) consent for cookie data
  • UK GDPR Article 6 (1) (c) Legal Obligation – processing is necessary for compliance with legal obligation to which the council is subject
  • UK GDPR Article 6 (1) (e) Public Task – processing is necessary for the performance of a task carried out in the public interest in the exercise of official authority vested in the council.

The lawful basis on which we collect and use special category data is:

  • Article 9 (2) (g): Processing is necessary for reasons of substantial public interest (statutory purposes, equality of opportunity and Safeguarding of economic well-being of certain individuals)

What type of information is collected from you

We may collect your personal information in a number of ways, for example:

  • In person
  • In writing - for example, application form, letter or email
  • Telephone calls
  • Online forms
  • Referrals from another department

Voter Authority Certificate applications

From 16 January 2023, electors can request via Government Electoral Registration Portal a Voter Authority Certificate (VAC) if they have no suitable photo identification that will be needed for in person voting. The Electoral Registration Officer will see the following personal information in order process and determine an application:

  • applicant's name (Forename, middle name, surname)
  • date of birth
  • address
  • postcode
  • National Insurance Number (“NINO”)
  • photograph (recent) - electronic (online) or hard copy
  • required technical data such as IP address,
  • phone number (optional)
  • email address (optional)
  • cookie / behavioural tracking data

The ERO is the data controller, with the Department of Levelling Up, Housing and Communities (DLUHC) / IER Digital Service (IERDS) providing the Portal access and will be a data processor. The ERO will manage the data on the Government Portal. (If applications are entered in EROP we do not see the NINO)

The ERO portal is a processing tool, and the VAC preparation, printing and dissemination a service, provided by the DLUHC/IERDS, so that the ERO can provide the VAC service required by legislation (the Elections Act 2022).

Via the portal, the elector can upload documentary evidence if they have not provided a NINO for the ERO to determine the identity of the applicant. This will be in document format and can include:

  • birth, marriage, civil partnership or adoption certificate
  • firearms certificate (granted under the Firearms Act 1968)
  • bail decision record
  • mortgage or pension statement
  • bank, building society or credit card statement, or account confirmation letter
  • utility bill
  • Council Tax statement or demand
  • current or previous employer's P45 or P60
  • benefits or entitlement statement, including:
  • Universal Credit
  • Disability Living Allowance
  • Personal Independence Payments
  • any other state benefits

For the printing and distribution of the VAC, personal information relating to applicants will be shared by the ERO to the print supplier, namely:

  • applicant's name (Forename, middle name, surname)
  • address
  • photo image

Personal data will be redacted in accordance with data retention policies. Approved applications will be kept along with supporting evidence for 30 days and then personal information data will be redacted from the Portal leaving transactional data being held for 10 years.

Online Absent Voter Applications (OAVA)

From 31 October 2023, electors can apply for an absent vote (postal or proxy) online via the Government's Electoral Registration Officer Portal / Online Absent Vote Application (OAVA) service and this will make use of the automated (Department, Work & Pensions) DWP NINO identity check process of the applicant (If applications are entered in EROP we do not see the NINO). In some instances where a NINO has not been provided, processing for the purposes of the identity check may include the applicant uploading documentary evidence from the following list, as prescribed by law:

  • birth certificate
  • marriage or civil partnership certificate
  • adoption certificate
  • firearm certificate
  • UK-issued Driving licence
  • police bail sheet
  • financial statement
  • mortgage statement
  • bank or building society statement or letter confirming account
  • credit card statement
  • pensions statement
  • Council Tax demand letter or statement
  • utility bill
  • P45 or P60 issued by employer/former employer
  • statement of benefits or entitlement to benefits

Personal data collected from electors will include:

  • applicant's name (Forename, middle name, surname, previous name where provided)
  • date of birth
  • registered address
  • delivery address (optional)
  • National Insurance number (NINO)
  • Signature
  • proxy name
  • proxy address
  • proxy contact details (optional)
  • required technical data such as IP address
  • phone number (optional)
  • email address (optional)
  • cookie / behavioural tracking data
  • Overseas Elector applications

As from January 2024, eligible British Citizens who reside abroad can apply to register to vote via the Government EROP.  The overseas elector registration application will use the automated DWP NINO identity check process.

In some instances where an applicant has been unable to evidence previous electoral registration at the address specified, processing may include checks of DWP records for previous residency at the specified address.

If overseas applicants were never registered in the UK before they left the country, they will be applying in respect of their previous residence. In this instance, they will be able to upload documents to demonstrate their connection to their previous address.

If overseas applicants were under 18 when they left the UK, they may provide evidence of their connection to a parent or guardian at the point of application, such as a birth or adoption certificate.

Types of personal data collected will be as listed above for a Voter Authority Certificate or Absent Vote application but with the addition of "previous address".  No photograph or signature will be collected from overseas applicants seeking to register.

Where a NINO cannot be provided, the applicant will be offered the ability to upload documentary evidence in order to support their identity, as set out above.

When applying to vote as an overseas applicant, the applicant may upload other evidence to support where they were last registered or resident and this includes:

  • letter from His Majesty's Revenue and Customs
  • council tax demand letter or statement
  • rent book issued local authority
  • statement of benefits or entitlement to benefits
  • letter from DWP confirming entitlement to state pension
  • letter from a school, college, university or other educational institution confirming attendance or offer of a place
  • letter from Student Loans Company
  • official copy of land register entry or other proof of title solicitor's letter confirming purchase of, or confirmation of, land registry registration
  • bank or building society passbook or statement, or letter from bank or building society confirming opening of account
  • credit card statement
  • utility or mobile telephone bill
  • letter from insurance provider

If an overseas applicant was too young to be registered when they left the UK, they will provide the name of a parent or guardian at the point of application, which may then undergo register checks. The applicant will be required to supply evidence of their connection to that individual, which may include providing a birth certificate or an adoption certificate.

Register data to third parties

The Electoral Registration Officer is legally required to:

  • to share specific information with Registered Credit Agencies upon request - statutory charge applied
  • to share specific information internally with other council service areas for the purposes of security, law enforcement and crime prevention
  • to supply specific information on subject with other Government Departments, local authorities and other agencies i.e. Police for the purposes set out above.

Candidates and potential candidates at elections and their agents

We collect the following information so that we may prepare elections notices, ballot papers and records, and communicate with you as part of the administration of elections:

  • name
  • address and postcode
  • candidates Date of Birth
  • telephone details
  • email address
  • membership of political party
  • other details such as letters, emails and notes in relation to your involvement and role in an election
  • reports of declarations of results
  • declarations of Registerable interests and acceptance of office forms of elected representatives
  • Staff employed at elections or for the canvass.

We collect the following information so that we may appoint, train, communicate with and pay you as part of the administration of elections or the annual canvass to update the electoral register:

  • Name
  • address and postcode
  • Date of Birth
  • NINO
  • telephone details
  • email address
  • other details such as letters, emails and notes in relation to your involvement and role in an election or the canvass
  • tax code
  • eligibility to work in the UK
  • bank details for payment

Suppliers of any service for which payment is required

We collect the following information so that we may make arrangements for supply of goods and/or services in relation to the administration of elections, such as the owner or caretaker of a building used as a polling station or count venue; the Head Teacher or administrator of a school used as a polling station or count venue, the suppliers of mobile polling stations; other suppliers:

  • name
  • address and postcode
  • telephone details
  • email address
  • other details such as letters, emails and notes in relation to your involvement and role in an election
  • bank details for payment

Who your information may be shared with (internally and externally)

Occasions when electors' information needs to be shared, and who it is shared with, include the following:

  • Annual data match: From June 2020, on an annual basis, the electoral register will be matched with Department for Work and Pensions (DWP) records to return information to the ERO to indicate if there is a change or no change to household composition each year. The data that will be shared:
  • elector full name
  • elector date of birth
  • address and postcode
  • unique property reference number

The ERO will use the match rate data to determine the appropriate annual canvass communication route for each property.

  • To verify your identity, the data you provide will be processed by the Individual Electoral Registration Digital Service managed by the Cabinet Office. As part of this process your data will be shared with the Department of Work and Pensions and the Cabinet Office suppliers that are data processors for the Individual Electoral Registration Digital Service.  You can find more information about this service on the Register to vote site privacy notice.
  • To inform the previous local authority of people who have moved area.
  • With law enforcement agencies, for the prevention or detection of a crime.
  • With the Jury Central Summoning Bureau, to indicate those persons who are aged 76 or over and who are no longer eligible for jury service.
  • When obtaining IT support from the council's ICT Service or from the contracted electoral database supplier.
  • When printing your poll cards, postal vote packs and other electoral material, in which case your information is shared with the council's print and mail service staff, contracted printers and the Electoral Registration Officer or Returning Officer's staff.
  • When instructing appointed canvassing staff to follow up non-responding households to the canvass form, or to follow up non-responding individuals to invitations to register.
  • In making available for public inspection the electoral register: the electoral register is a public document which can be viewed only by attendance in person, under strict control.
  • With candidates standing for election
  • With local and national political parties
  • With local parish and town councils

A Memorandum of Understanding/Data Sharing Agreement on Data Protection (Controller to Processor) has been entered into by the ERO with the Department of Levelling Up, Housing and Communities (DLUHC) for the Government department to process personal data using the Electoral Registration Officer Portal (EROP) covering 3 services: application of Voter Authority Certificate, Online Absent Vote Applicants and applications to register as an Overseas Elector. Such changes have been introduced by the Elections Act 2022.

The council will not share your information with third parties for marketing purposes. 

Automated decision making

If you are a postal voter, we use your information to make decisions through automated means when we check personal identifiers that you provide against those contained in your original postal vote application. In any case where the automated process reports that the personal identifiers you have provided do not match those on your original postal vote application, there will be an intervention by a human being (The Returning Officer) who will make any final decision (ie there will always be the involvement of a human decision-maker where the result of the automated process indicates the possibility of a decision to your detriment).

How long the council keeps your information (retention period)

Your details will be kept and updated in accordance with the Electoral Registration Officer (ERO) and Returning Officer's (RO) legal obligations in line with statutory retention periods.

See the retention schedule:

PDF Icon Electoral Documents Retention Periods - pdf - 212 Kb

Once your data is no longer needed it will be securely and confidentially destroyed or disposed of the data in line with retention schedules.

How the council protects your information

Your data is stored securely on our systems and accessed only by authorised officers using their own username and password created in line with pre-defined user credentials. Personal data is also held in electronic files on the council’s network drives. These are only accessible through personal logon credentials and access privileges to specific drives. Access to our council sites require a personal electronic pass to access staff only areas. The council has strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording and sharing information which staff receive training on.

The council will not transfer your personal data outside the EU without your consent.

The council have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse or unauthorised alteration or destruction.  

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.  

The council will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

Your rights

You have the following rights under the Data Protection Legislations:

  • To access your personal data
  • To be provided with information about how your personal data is processed
  • To have your personal data corrected
  • To have your personal data erased in certain circumstances
  • To object to or restrict how your personal data is processed
  • To have your personal data transferred to yourself or to another business in certain circumstances
  • To be told if the council have made a mistake whilst processing your data and the council will self-report breaches to the Commissioner.

How you can access, update or correct your information

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request'.

If you wish to see a copy of your records you should contact the Data Protection Officer. You are entitled to receive a copy of your records free of charge, within a month.

In certain circumstances access to your records may be limited, for example, if the records you have asked for contain information relating to another person.

The accuracy of your information is important to us to be able to provide relevant services more quickly. The council is working to make our record keeping more efficient. In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information the council holds is inaccurate or out of date, please email us or write to us at:

Electoral Service
Cotswold District Council
Council Offices, Cirencester GL7 1PX
Email: [email protected]

Further information

If you would like to know more about how the council uses your information, or if for any reason you do not wish to have your information used in any of the ways described in this privacy notice, please contact the Data Protection Officer at [email protected]

For more information about data protection please visit: www.cotswold.gov.uk/about-the-council/council-data-and-information/data-protection/

If you are concerned about the way the council is handling your personal information you can contact the Information Commissioner (ICO): https://ico.org.uk/make-a-complaint/

The council reserve the right to update this privacy notice from time to time by publishing a new version on our website.

Related Pages

© Cotswold District Council 2024