How your information is used

This notice covers the Liberal Democrats Independent Complaints Process. It adds detail to the Party’s own privacy notice, which still applies.

Who is responsible

The Liberal Democrats, 66 Buckingham Gate, London SW1E 6AU, are the data controller. The Standards Office runs this service for the Party.

What we collect

• Names and contact details of the person complaining, the member complained about, and anyone else named in a complaint.
• What the complaint says, the evidence sent with it, responses, statements, and the decisions made.
• Where it is part of a complaint, sensitive information: for example about health, ethnicity, religion, sex life, or an alleged crime.
• A record of who has opened each complaint and each document, and when, so that access can be checked.

Why, and on what basis

We use this information to consider complaints under the Party’s Independent Complaints Procedures, and to keep the records the procedure requires.

Our lawful basis is our legitimate interests (UK GDPR Article 6(1)(f)): making sure the law and the Party’s rules are followed, as the Party’s own privacy notice says for complaints. Where the law may have been broken, we may also have a legal obligation to use and share information.

Complaints often include more sensitive information, such as health, sex life, political opinions or an alleged offence. Where you give us that kind of information about yourself, such as when you make a complaint, give a statement or ask for anonymity, we ask for your explicit consent. You can withdraw it by telling the Standards Office. If you do, we record the withdrawal, and a Senior Adjudicator is told where it may affect whether the complaint can fairly continue.

Some people cannot be asked for consent: the member complained about is not told at first, and people named in a complaint are often unaware of it. For their sensitive information, and where consent has been withdrawn but the complaint must still be dealt with, we rely on substantial public interest under the Data Protection Act 2018 (Schedule 1, Part 2: preventing or detecting unlawful acts, protecting the public against dishonesty or malpractice, and safeguarding).

Who sees what

• The Standards Office sees each complaint to administer it. Its staff do not decide complaints.
• Senior Adjudicators and the Lead Adjudicator, who are volunteers, see complaints in order to decide how each one proceeds.
• Complaints Panel members, also volunteers, see a complaint only once they are appointed to it and have declared any conflict of interest. Investigators see what they need for their enquiry.
• The person complaining sees their complaint, the decisions on it, and the member’s response as it is shared with them.
• The member complained about sees the allegations, the evidence shared with them, and the decisions, from the point they are told.
• Other party bodies, such as a local party, are told of an outcome where the procedure requires it. They are not given the complaint file.
• The police or other authorities, only where the law requires it.

The Disciplinary Sub-Group sees figures only, never an individual live complaint. Access to each complaint is limited, time-bound and recorded.

When the member complained about is told

They are not told when a complaint is made. A Senior Adjudicator first decides how it should proceed. The member is told if the complaint goes to a Complaints Panel, or at another point a Senior Adjudicator decides under the procedure. No email is sent to them before then.

Anonymity

In exceptional circumstances you can ask for your identifying details to be withheld from the member you complain about. A Senior Adjudicator decides. If it is granted, your details are hidden from the member and from anything shared with them, and are shown only to the Adjudicators making decisions. Requests for anonymity and the reasons given are stored encrypted.

Emails

Emails from this service say only that something has changed and whether you need to act. They never contain the detail of a complaint, names of the other side, or reasons. The detail is on your complaint page, behind sign-in.

Where it is stored

Complaint records are held in a database in London. The service runs on Cloudflare, and evidence files are stored with Cloudflare in the European Union. We do not use advertising or tracking cookies, and the site loads no fonts or scripts from other companies, apart from Cloudflare’s check against automated submissions on the complaint form.

How long we keep it

• Serious complaints are kept indefinitely, as the Party’s privacy notice says.
• Other complaints that were considered are kept for six years after they end.
• Complaints that were not accepted are kept for two years after that decision.
• A record that a member was given a Warning or sanction is kept on their membership record for as long as the procedure needs it, including if they later apply to rejoin.

At the end of a period the record is reviewed, and deleted or made anonymous unless there is a good reason to keep it. Nothing is deleted automatically.

Your rights

You can ask for a copy of your information, ask for it to be corrected, and in some cases ask for it to be deleted or for its use to be restricted, or object to its use. Information about other people in a complaint, including anyone granted anonymity, is not included in a copy sent to you.

Write to data.protection@libdems.org.uk. For questions about a complaint itself, contact the Standards Office at standardsofficer@libdems.org.uk.

If you are unhappy with how your information has been handled, you can complain to the Information Commissioner’s Office at ico.org.uk.

Make a complaint · Guidance