TERMS

This privacy notice relates to the personal data processed by the Office of Kirsteen Sullivan, Member of Parliament for Bathgate and Linlithgow, in relation to casework and policy queries

Who is the Data Controller?

The Data Controller is Kirsteen Sullivan, Member of Parliament for Bathgate and Linlithgow.

What does the office do?

The office discharges the duties and functions of an elected Member of Parliament. As part of this work, we conduct constituency casework and respond to policy queries, for which we must process personal data of our constituents. We also conduct surveys and hold mailing lists for newsletters and other local updates.

How do we process data?

This office processes constituents’ data under the lawful basis of public task. In instances where this lawful basis is not sufficient and explicit consent is required, a member of the office will contact you to establish your consent.

We are committed to ensuring that the information we collect, and use is appropriate for this purpose and does not constitute an invasion of your privacy.

What sort of data do you store?

If you contact me regarding an inquiry, a local concern, or a complaint, I will normally need to store your contact details to deal with your inquiry, concern, or complaint, and to keep you updated about this. This is considered to be “normal category data” under the GDPR.

Other personal data you may provide to me may include details about your personal and family life, social circumstances and business activities, your employment and education details, financial information or information about your housing situation etc. Depending on what views, issues or experiences you wish to discuss with me, you may be sharing “special category” data with me. For example, this could include details about race or ethnic origin, political or religious views, or physical or mental health.

If you are a supplier, I will normally need to store your name, contact and payment details for the purposes of the contract between us.

Will we share your data with anyone else?

If you have contacted me about a personal or policy issue, we may pass your personal data on to a third-party in the course of dealing with you, for example, local authorities, government agencies, and other public bodies. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the basis upon which they were originally intended.

We will not share the personal information of members of any mailing list or those in receipt of my newsletters.

In any case, we will not use your data in a way that goes beyond your reasonable expectations in contacting us.

For how long will you keep my personal data?

Casework and policy queries are often revisited to provide the best service and representation for constituents, from whom we may continue to receive correspondence. Unless specifically requested by you, my office will hold your personal data for the duration of my time a Member of Parliament. Following an election, if unsuccessful, or if I stand down from Parliament, all records will be destroyed. If there is still ongoing work in relation to your case, we will ask your permission to pass this to the next MP.

What rights do I have to my personal data?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing, such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: if our office refuses your request under rights of access, we will provide you with a reason why. You have the right to complain.

How can I contact somebody about my privacy?

You can get in touch with our office by letter, email or telephone using the details at the foot of this page.

Please note that we will ask for identification (passport, driving license, utility bill from the last 3 months) should you choose to exercise any of the above rights in relation to personal data we hold.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by this office, or how your complaint has been handled, you have the right to lodge a complaint directly with the Information Commissioner’s Office. You can find details of how to make a complaint here: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints

Terms of service

Kirsteen Sullivan MP, Bathgate and Linlithgow

Office Standards Policy

I am proud and privileged to represent over 70,000 people from the Bathgate and Linlithgow constituency. My casework service is supported by two members of staff. We’re a small team of dedicated staff who work hard to support as many people as possible, as quickly as possible.

I understand there are occasions when people may act out of character in times of trouble or distress. There may have been upsetting or distressing circumstances leading up to a constituent approaching my office.

However, unacceptable behaviour or actions that result in unacceptable or excessive demands on my staff will not be tolerated as these demands prevent them from carrying out their duties effectively.

It is these behaviours and actions that I aim to manage under this Policy.

Aggressive or abusive behaviour

I understand that many constituents are often upset and angry about the issues they have raised with me. If that anger escalates into aggression towards my team, I consider that unacceptable. Any violence or abuse towards my team will not be tolerated.

Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language (whether verbal or written) that may cause staff to feel offended, afraid, threatened or abused.

Each situation will be judged individually and I appreciate individuals who come to my office may be upset. While I accept that those who contact me may feel angry, it is not acceptable to shout or swear at anyone in my office.

Unacceptable language is that which:

· is offensive, derogatory or patronising,

· is discriminatory in any way, including racist, sexist, homophobic or transphobic comments; or

· makes serious allegations that individuals have committed criminal, corrupt or perverse conduct without any evidence.

I also may decide that comments aimed not at my team but at third parties are unacceptable because of the effect that listening to the comments or reading them may have on my team.

Examples include rudeness, offensive comments, derogatory remarks, making inflammatory statements, or raising unsubstantiated allegations made towards these third parties.

All threats against either myself or my team will be taken extremely seriously and if my team feel scared or threatened at any point during a conversation with a constituent, the interaction may be ended at any time and the Police may be contacted.

Unreasonable demands

A demand becomes unacceptable when it starts to (or when complying with the demand would) impact substantially on the work my staff carry out on my behalf.

Examples of this behaviour include:

· repeatedly demanding response within an unreasonable timescale,

· insisting on seeing or speaking to a particular member of staff, when that is not possible,

· repeatedly changing the substance of a complaint or raising unrelated concerns.

An example of such impact would be that the demand takes up an excessive amount of time and in doing so disadvantages other constituents and prevents their own complaint from being dealt with quickly.

Unreasonable levels of contact

Sometimes the volume, frequency and duration of contact made to my office by an individual causes problems. This can occur over a short period, for example, a number of calls in one day or hour, or frequent and persistent emails on a vast range of issues which take up a disproportionate amount of staff time.

It may occur over the life-span of a complaint when a constituent repeatedly makes long telephone calls to us or inundates us with copies of information that has been sent already or that is irrelevant to the complaint.

I consider that the level of contact has become unacceptable when the amount of time spent talking to a constituent on the telephone, or responding to, reviewing and filing emails or written correspondence impacts on my office's ability to deal with that complaint, or with other constituents’ complaints.

Harassment

My team has the right to carry out their duties free from harassment or threats of harassment. I ask everyone to respect that my team are delivering a service on my behalf and therefore this may not reflect their own views or preferences.

Examples of behaviours I consider to be harassment against my office include:

· recording telephone discussions and publishing the information online such as through YouTube, Vimeo or Twitter;

· contacting staff using their personal details or social media presence such as Facebook, Twitter or LinkedIn;

· publishing personal, sensitive or private information about staff online or other public domains such as noticeboards or newsletters.

Unacceptable or excessive demands

A demand becomes unacceptable when it starts to (or when complying with the demand would) impact substantially on the work of my office.

Examples of this behaviour include:

· repeatedly demanding a response within an unreasonable timescale,

· insisting on, or refusing to, speak to a particular member of staff, when that is not possible,

· repeatedly changing the substance of a complaint or raising unrelated concerns, including “spamming” my office with emails on a vast range of issues.

· Making repeated and unnecessary contact during the course of us dealing with a complaint or carrying out an investigation,

· Refusing to accept a decision where explanations for the decision have been provided.

An example of such impact would be that the demand takes up an excessive amount of staff time and in doing so disadvantages other constituents and prevents their own complaint from being dealt with quickly.

Refusal to co-operate.

When looking at a complaint, my office will need to ask the individual who has contacted us to work with us. This can include agreeing with us:

· the complaint we will look at,

· to provide us with further information, evidence or comments on request, or

· help us by summarising their concerns.

Sometimes, an individual repeatedly refuses to co-operate or fails to respond to our requests and this makes it difficult for us to proceed. My office will always seek to assist someone if they have a specific, genuine difficulty complying with a request.

However, it is unacceptable to bring a complaint to my office and then not respond to clear and appropriate requests by my team.

Reasonable adjustments

I understand that some constituents may find it difficult to express themselves or communicate clearly, especially when they are anxious or upset. In order to assist, we ask that they explain what adjustments they’re looking for and how this will ensure they can access the service my office offers.

My office will always consider making reasonable adjustments for a constituent asked to do so. Examples of adjustments we can consider are:

· we could consider using different methods of communication;

· providing written communication in large print, coloured text, or in translation;

· giving clear warnings if conversations become unproductive and allowing constituents to opportunity to modify their behaviour before ending a call.

I do not expect my staff to accept being subjected to aggressive, offensive, threatening or abusive actions, language or behaviour.

I may still use the policy if there are actions or behaviours which are having a negative effect on our staff or our work even where a reasonable adjustment has been made.

Actions I may take:

When my office experiences behaviour or demands which are unacceptable, I may consider taking more formal action. The actions I will consider may include the following:

· Warning the constituent about their behaviour and requesting that the constituent modifies their behaviour in future contact with us.

· Reporting an individual to the Police.

· Appointing a specific point of contact for the constituent

· Communicating only in writing or via a representative

· Deciding not to investigate a complaint on the basis that it has been pursued in a way that is unacceptable.

· Stop all communication with a constituent

· Restricting or limiting contact

· Your telephone number and email may be automatically blocked from our systems.

Terms of service

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