Submission to the ICO on Code of Practice for the use of personal data in political campaigning

submission cover

In October 2019, PI responded to the UK Information Commissioner’s (ICO) consultation on a draft Code of Practice for the use of personal data in political campaigning.

This follows on from PI's submission in December 2018, to the ICO’s Call for Views.

PI welcomes the draft Code of Practice as a first step. However, much remains to be done to close the implementation and enforcement gap and strengthen existing regulatory frameworks.  

In response to the ICO’s questions, PI’s submission calls for the following.

  • Inclusion of guidance on:
    • Rights of data subjects
    • Sanctions/ Remedies
    • Campaigning outside of an election
    • Digital and experimental campaign techniques
  • More detail/ clarity on:
    • Transparency
    • Profiling
    • DPIAs and assessments re lawful basis
    • Purpose Limitation
    • Fairness
    • Processors
    • Special category personal data
    • Data from third party sources
    • Electoral register - opt-out
    • Digital/ online campaigning techniques and tools such as Apps and targeted digital advertising on TV
    • Actors other than political parties/ candidates