Local government candidate diversity survey 2022: data protection impact assessment

This data protection impact assessment (DPIA) reports on and assesses against any potential data protection or privacy impacts as a result of the running of the 2022 local government candidate diversity survey, and the data processing undertaken as part of the project.

This document is part of a collection

5. Questions to identify privacy issues

5.1 Involvement of multiple organisations

The survey process involves 2 contractors, currently The APS Group and Questback, to support the processing of data. We have received and reviewed assurances from the contractors that their work follows the UKGDPR frameworks.

5.2 Anonymity and pseudonymity

As explained in the information leaflet that is given to candidates alongside the questionnaire, initial processing of the questionnaires requires that data not be anonymous. We ask for the name candidates are standing under, only for the purpose of being able to record which candidates have been elected following the election. This means we can understand the diversity both of all candidates at the elections, and of those who are ultimately elected.

Once the Scottish Government receives the data from APS and Questback, the 2022 LGCDS data will be pseudonymised. A unique identifier will be assigned to each candidate. The names will then be removed from the survey data before the data is analysed. While this unique identifier can be (and needs to be) linked back to the survey data, the linking information will be held separately and only used where necessary.

To help manage the anonymity of the data, names will be held separately from the survey data. The number of people who will be able to make the link between the survey data and the names of candidates will be tightly controlled and there will only be a small number of analysts within the CIMA Team who have access to both records. The Scottish Government will not hold on to the data for any longer than is necessary. Names of the candidates will be deleted within 30 days of the Scottish Government receiving the full dataset.

Email addresses will also be removed from the survey data and a separate dataset of recontact information will be held for those who have consented to providing this. Email addresses, where supplied with consent to be sent a copy of the survey report, will be deleted once the survey report has been sent. Email addresses (recontact data), where supplied with consent to be contacted about potential future research, will be deleted after 6 years.

The data provided from each candidate will be combined with the information from all other candidate responses, to create statistics about the diversity of candidate and elected members in the 2022 local government election. These statistics are subject to disclosure control guidance issued by the Office for National Statistics.

5.3 Technology

Questback, the Scottish Government's in-house survey tool will be used to collect the personal data from the online questionnaire. Questback is UKGDPR compliant and approved for use within the SG.

Within Scottish Government, personal data will be held electronically on restricted areas of the Scottish Government's secure server as previously described.

5.4 Identification methods

Once initial processing has been completed, candidates will be identified by their unique identifiers.

A unique identifier will be assigned to each candidate within the 2022 LGCDS data once received by the Scottish Government. Whilst personal information such as names and email addresses will be stored separately from the main survey response data, the unique identifier will be common to all datasets to enable this data to be matched if/when required.

5.5 Sensitive/Special Category personal data

Information about ethnicity, religion, physical and mental health, sexual orientation and political opinion will all be collected in the 2022 LGCDS. However, this information will not be stored alongside personal details in the data such as names and email addresses.

The survey will ask questions relating to sex and gender, including asking the candidate about their transgender status. This is in line with the SG guidance: Sex, gender identity, trans status - data collection and publication: guidance - gov.scot

Disclosure checks will be carried out on the data before it is published.

5.6 Changes to data handling procedures


5.7 Statutory exemptions/protection


5.8 Justification


5.9 Other risks



Email: diverserepresentationdata@gov.scot

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