Privacy Policy
Last updated: 31st December 2025
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1. Contact Details
Name: Ten Boroughs Research Ltd
Address: Box 24, 792 Wilmslow Road, Manchester, M20 6UF
Email: hello@tenboroughs.co.uk
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2. The Personal Information We Collect
We collect and process the following categories of personal information:
Standard Personal Data:
Name
Email address
Postal address (including postcode)
Telephone number
Contact details
Special Category Data:
Trade union affiliation and membership details
How we receive your information:
Directly from you when you use our email campaign service
From member organisations who engage us to conduct phone calling campaigns on their behalf using their member databases
3. How We Use Your Personal Information
We use your personal information for the following purposes:
For email campaigns:
To identify your correct elected representatives based on your postcode
To send campaign emails on your behalf to your representatives
To include necessary information for representatives to verify you are their constituent
For phone calling campaigns:
To contact members by telephone on behalf of their organisation
To conduct campaign outreach, surveys, ballots, or consultations as directed by the member organisation
To record campaign responses and outcomes for reporting back to the member organisation
General purposes:
To respond to your enquiries and provide customer support
To comply with legal and regulatory obligations
4. Lawful Basis for Processing
Under the UK General Data Protection Regulation (UK GDPR), we process your personal information on the following lawful bases:
For standard personal data in email campaigns:
(a) Consent: You provide explicit consent when you submit your information through our campaign forms. You can withdraw consent at any time by contacting hello@tenboroughs.co.uk
(f) Legitimate interests: We have a legitimate interest in facilitating democratic engagement between constituents and their elected representatives
For phone calling campaigns on behalf of member organisations:
(f) Legitimate interests: The member organisation has a legitimate interest in communicating with its members about campaigns, political matters, and union activities. We process this data as a data processor on behalf of the member organisation (the data controller)
(b) Contract: Processing is necessary to fulfil our contractual obligations to the member organisation that has engaged our services
For special category data (trade union affiliation and membership):
Article 9(2)(d) UK GDPR: Processing by trade unions (and those acting on their behalf) in the course of their legitimate activities, with appropriate safeguards for members' rights
(a) Explicit consent (where applicable): When you voluntarily provide this information through our email campaign forms
For anonymised call logs:
(c) Legal obligation: We retain anonymised call logs to comply with our regulatory obligations under Ofcom regulations
5. Our Role as Data Processor
For phone calling campaigns:
When organisations provide us with member contact details for phone calling campaigns, we act as a data processor on behalf of the member organisation (the data controller). This means:
The member organisation remains responsible for the lawfulness of providing your data to us
We process your data strictly according to their instructions
We implement appropriate security measures to protect your data
We do not use your data for any purpose other than delivering the contracted campaign services
We return your data and securely delete it from our systems according to the timescales set out in Section 9 below
Important: If you have questions about how your member organisation obtained your data or the purposes for which they're using it, you should contact them directly using the contact details they've provided to you.
6. How We Share Your Personal Information
We share your personal information in the following limited circumstances:
With elected representatives (email campaigns only): We share your name, contact details, and message content with the specific elected representatives you choose to contact.
With member organisations: For phone calling campaigns, we share campaign results, responses, and data collected during the campaign back to the organisation that engaged our services. Data may be transferred periodically during the campaign and a final transfer is completed within 4 weeks of ballot/campaign closure.
With service providers: We use trusted third-party service providers to help us operate our service, including:
Email delivery services
Telephone systems and call recording services
Web hosting providers
Database storage providers
Cloud computing services
All service providers are bound by data protection agreements and are only permitted to process your data on our instructions.
Legal requirements: We may disclose your information if required by law, court order, or governmental authority.
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
7. Call Recording and Monitoring
For phone calling campaigns:
Calls may be recorded for the following purposes:
Quality assurance and training
Accuracy of campaign data collection
Dispute resolution
Compliance monitoring
If calls are recorded, you will be informed at the beginning of the call. Call recordings are retained for 8 weeks after campaign completion and then securely deleted, unless there is a specific reason to retain them longer (such as an ongoing complaint or legal requirement).
8. International Data Transfers
Your personal information is primarily stored within the UK/EEA. If we transfer data outside the UK/EEA, we ensure appropriate safeguards are in place, such as:
Standard Contractual Clauses approved by the UK Information Commissioner's Office
Transfers to countries with adequacy decisions
Binding corporate rules (where applicable)
9. How We Store and Protect Your Information
We take the security of your personal information seriously and implement appropriate technical and organisational measures, including:
Encryption of data in transit and at rest
Regular security assessments and audits
Access controls limiting staff access to personal data on a need-to-know basis
Secure backup procedures
Staff training on data protection
Secure telephone systems with restricted access
Regular deletion protocols
Data Retention:
For email campaigns:
Active campaign data: Retained for the duration of your use of our service
Completed campaign data: Retained for 2 years after your last interaction with our service
Consent records: Retained for 3 years after consent withdrawal to demonstrate compliance
For phone calling campaigns:
Member contact details and campaign data:
Data collected during the campaign is returned to the member organisation within 4 weeks of ballot/campaign closure (with periodic transfers during the campaign as required)
All personal data is securely deleted from our systems within 8 weeks of campaign closure
Data may be transferred periodically to the member organisation during active campaigns
Call recordings: Retained for 8 weeks after campaign completion, then securely deleted
Anonymised call logs: To comply with Ofcom regulations, we maintain anonymised logs containing only telephone numbers (with no other personal data) for 6 years. This is standard practice in our sector and enables us to respond to regulatory enquiries or complaints.
Contract and instruction records: Retained for 7 years to demonstrate compliance with our data processing obligations
After these periods, we securely delete or anonymise your personal information.
10. Your Data Protection Rights
Under UK data protection law, you have the following rights:
Right of access: You can request copies of your personal information.
Right to rectification: You can ask us to correct inaccurate or incomplete personal information.
Right to erasure: You can ask us to delete your personal information in certain circumstances, such as when it's no longer necessary for the purposes we collected it. Please note that we cannot delete anonymised call logs, which contain telephone numbers, as we are legally required under Ofcom regulations to retain this data for compliance purposes.
Right to restrict processing: You can ask us to limit how we use your personal information in certain circumstances.
Right to object: You can object to our processing of your personal information where we rely on legitimate interests, including for direct marketing purposes.
Right to data portability: You can request a copy of your personal information in a portable format to transfer to another service provider.
Right to withdraw consent: Where we process your data based on consent, you can withdraw that consent at any time.
Rights regarding automated decision-making: We do not use automated decision-making or profiling that produces legal or similarly significant effects.
Special note for trade union members:
If your data was provided to us by your trade union for phone calling campaigns:
We process your data on behalf of the trade union
You should direct rights requests to your trade union in the first instance, as they are the data controller
We will cooperate with your trade union to facilitate your rights
You can also contact us directly at hello@tenboroughs.co.uk and we will coordinate with the trade union
Your personal data will be deleted from our systems within 8 weeks of campaign closure as standard practice
To exercise any of these rights:
Email us at hello@tenboroughs.co.uk
Write to us at the address above
Contact your trade union directly (for phone campaign data)
We will respond to your request within one month. There is no charge for exercising your rights unless your request is manifestly unfounded or excessive.
11. Opting Out of Communications
For email campaigns: You can withdraw your consent at any time by contacting hello@tenboroughs.co.uk
For phone calling campaigns:
You can ask to be removed from the campaign calling list by informing the caller during a call
You can contact your member organisation directly to opt out of such communications
You can contact us at hello@tenboroughs.co.uk to request removal
We maintain a suppression list to ensure you're not contacted again for similar campaigns
Your request will be honoured immediately and your data will be deleted in accordance with our standard deletion timescales
12. Regulatory Compliance
We are regulated by Ofcom for our telephone calling activities. As part of our regulatory obligations, we:
Maintain anonymised call logs (telephone numbers only, with no other personal data) for 6 years
Comply with applicable telephone communications regulations
Respond to regulatory enquiries and complaints as required
Follow industry best practices for telephone campaigning
The retention of anonymised call logs is a legal requirement and standard practice in our sector. These logs contain only telephone numbers and no other identifying information.
13. Cookies and Tracking Technologies
Our website uses cookies and similar technologies. Please see our separate Cookie Policy for detailed information about:
What cookies we use
Why we use them
How to control or delete cookies
14. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by:
Updating the "Last updated" date at the top of this policy
Posting a notice on our website
Emailing you (for significant changes affecting email campaign users)
For phone campaign participants, material changes will be communicated via your member organisation.
We encourage you to review this policy periodically.
15. How to Complain
If you have concerns about how we handle your personal information:
First, contact us:
Email: hello@tenboroughs.co.uk
Post: Ten Boroughs Research Ltd, Box 24, 792 Wilmslow Road, Manchester, M20 6UF
For phone campaign data, you can also contact your member organisation directly.
We will investigate your complaint and respond within a reasonable timeframe.
You can also complain to the supervisory authority:
Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk
You have the right to lodge a complaint with the ICO at any time, though we would appreciate the opportunity to address your concerns first.
For regulatory complaints about telephone communications:
Office of Communications (Ofcom)
Riverside House
2a Southwark Bridge Road
London
SE1 9HA
Website: www.ofcom.org.uk