31 October 2019
Re: Committing to a transparent, fair and accountable campaign

As civil society dedicated to defending rights we are deeply concerned about the
exploitation of people’s data in the political sphere and its impact on privacy and
democracy.
The abuse of data in the political context is high on the agenda in the UK, with
numerous reports and committees considering this issue. A Code of Practice on
the use of personal data in political campaigning by the Information
Commissioner is on the horizon. Parliamentarians and regulators, including the
Information Commissioner and Electoral Commission have called for urgent
legislative action. However, none of this is likely to be forthcoming in advance of
the general election due to take place on 12 December 2019. Without real action,
including meaningful legislation, the public cannot be expected to have faith in
the outcome of the election.
Large platforms, together with the vast ‘influence industry’ from data brokers, to
ad tech, to the providers of campaign tools and services have much to answer
for. We are also concerned that political campaigns are abusing the architecture
of the internet to obscure the true extent of financial and informal relationships
between campaigns, thus gaming the regulatory framework. Political parties
must shoulder some responsibility for this and take steps to demonstrate a
commitment to respecting people’s rights and the democratic process.
We urgently call on political parties to take a principled stand and publicly
commit to the following:
1. Be transparent about your data processing activities, including identifying
the mechanisms you use to engage with voters (e.g. social media,
websites, direct messaging).
2. Be transparent about how you collect people's data and the sources of
this;
3. Be transparent on your political ads and messaging. You should ensure
that the public can easily recognise political messages and

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communications and the organisation behind them. You should make
available information on any targeting criteria used in the dissemination of
such political messages;
Publish a complete, easily accessible and understandable list of any
campaign groups you have financial or informal collaborative campaigning
relationships with, including all third parties and joint campaigners.
Adopt and publish data protection policies and carry out and publish data
protection audits and impact assessments;
Ensure you have a legal basis for each use of personal data (including any
special category data such as those revealing political opinions);
Be transparent as to the companies you contract with as part of your
campaigns both to obtain data and to further process data, including
profiling and targeting, such as data brokers and political advertising
companies as well as which companies are providing campaign tools/
software and which products you are using;
Ensure that any third party you are using for your campaign activities also
complies with data protection laws;
Make publicly available timely information on your expenditure for online
activities, including paid online political advertisements and
communications. This should include information regarding companies
assisting you in your online activities, including the amount spent on each
companies’ services;
Facilitate the exercise of data rights by individuals (including providing
information about how their data is processed and providing timely access
to it)

Adopting and adhering to the above, is urgently needed in order to foster trust in
the democratic process. Transparency, fairness and accountability are core
tenants of protecting people's data and electoral integrity. Failure to act risks
political manipulation and undermines the efforts to rein in the power of big
companies in this field. A starting point would be to provide the above
information on your party’s website.
Actions speak louder than words and we look forward to hearing from you as to
whether you are prepared to make and put into practice these important
commitments.
Privacy International

FairVote

Open Rights Group

Institute for Strategic Dialogue

Demos

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