Challenge to Hidden Data Ecosystem in Political Campaigning
The ICO opened an investigation to the company following the issues raised in PI's complaint as well as a number of other issues that were passed to the Investigations team to make enquiries. They issued Information Notices to obtain relevant evidence. Based on the information and evidence provided, the ICO provided advice to the CT Group regarding their future compliance with the GDPR. Our submission assisted the Commissioner in assessing the practices of CT as a group of companies and the compliance of the political consultancy industry as a whole with data protection laws.
Privacy International filed a complaint with the UK data protection regulator to investigate potential data protection infringements by a political consultancy.
UK Information Commissioner (ICO)
On 21 January 2021, Privacy International filed a complaint with the data protection authority in the UK, the Information Commissioner, against the CT group of companies.
PI asked the Information Commissioner’s Office (ICO) to conduct a full inquiry into the role of C|T group of companies (including CT Partners Limited, CT Group and CT Holdings Limited) in the UK 2019 General Election as part of the Commissioner’s ongoing work into the use of data analytics for political purposes.
The use of personal data during the electoral process has become of major public concern particularly due to the lack of transparency with regard to the data processing activities that the involved actors undertake – including the political consultancies hired by political parties. We are concerned about the impact that such services can have on free democratic elections and about the ability of individuals to exercise their data rights in the process.
One of these political consultancies is the C|T group of companies (part of which is CT Partners Limited). The group provides limited information about the data collection, profiling and targeting practices in their work for political parties, and in turn the services CT Partners Limited provided for the Conservative and Unionist Party’s 2019 UK Election Campaign. We know they provided “Market Research/Canvassing” to the UK Conservative and Unionist Party, but we don’t know what these services were, if and how data was used in the process. As a result, we asked the ICO to further investigate their practices.
The ICO opened an investigation to the company following the issues raised in PI’s complaint and a number of other issues that were passed to the Investigations team to make enquiries. They issued Information Notices to obtain relevant evidence to the relevant organisations. Based on the information and evidence provided in response to the Information Notices, the ICO provided advice to the CT Group regarding their future complaince with GDPR. Following the company’s actions, the ICO was satisfied that formal enforcement action was not appropriate. The case was closed on 4 October 2021.