Note before reading:
⚠️Qomon in no way replaces the advice within your movement/association of a "Data Controller" or "Data Protection Officer".
⚠️ These resources are articles compiled or derived from interviews with CNIL and GDPR experts. They are here for information only and can in no way replace expert advice.
⚠️ Qomon does not own the personal data you collect, so you are responsible for its collection.
GDPR and electoral law
Who can carry out political communications?
Political communication can be carried out by:
a political structure (party, association, training group, etc.) bringing together several categories of individuals: members, sympathizers, activists, correspondents, supporters, "regular contacts", "prospects", etc.
an elected representative or candidate with his or her own files compiled as part of his or her political activity: people received in his or her office, people present at public meetings, "prospects", etc.
What you should keep in mind in terms of GDPR
It's important to distinguish between:
Regular contact: someone who has signed up to receive a newsletter, who has authorized you to contact them and receive information - either because you've met them, or because they've registered on your site.
Occasional contact: someone who once sent an email to ask a question, or a contact obtained through the sponsorship of one of your activists.
What's the difference?
A regular contact can be the subject of regular political communication, while an occasional contact can only be contacted once.
Send an initial message in which you suggest that they receive regular information, if they respond positively, they become regular contacts.
Can I use party files for my local campaign?
Yes.
Best Practices
1. Be transparent and clear about your purpose
Whether in person, online, or via email, you and your team should clearly communicate:
Who you are.
What your purpose is (e.g., a municipal campaign or preparing a new project for future elections).
Examples:
For regular contact:
"You are receiving this message from Movement X because we met you and you gave your consent to be contacted. Your details will be used to keep you informed throughout the campaign. If you no longer wish to receive my messages, you can unsubscribe."For occasional or one-time contact:
"You live in City Y, and we are preparing a program for the next municipal elections. If you would like to stay informed or get involved, sign up here! Our next meeting will be held..."
2. Give citizens the ability to exercise their rights
Citizens must be able to easily unsubscribe from your outreach messages. The method to opt out depends on the communication channel used (phone, email, SMS) and must be accessible, simple, and effective.
Examples of opt-out methods:
An unsubscribe link at the bottom of an email.
A phone number.
A "STOP" message for SMS.
💡 Tips:
Clearly collect consent from the people you meet.
Include on your data collection forms (paper or online) an email address dedicated to handling these requests promptly.
Assign a person responsible for managing and tracking these requests to ensure they are processed as quickly as possible, especially if multiple candidates in the same party use the data.
Practice "voter empathy": don’t send messages you wouldn’t want to receive yourself.
For emails, always include an unsubscribe link in each message. The link should be operational, visible, and accessible.
3. Secure your processes to ensure confidentiality
The main vulnerabilities are often related to passwords! To ensure security:
Regularly change the passwords for your applications.
Revoke access for inactive members.
Use the "BCC" feature in emails to protect the confidentiality of your contact list.
4. Prioritize humans over automation
Feedback shows that poorly targeted and unsolicited political outreach, even if legal, can irritate voters to the point of being counterproductive (e.g., complaints on social media, frustration with automated calls, annoyance among undecided voters).
To convince voters, human interaction and argument exchange remain the most effective methods.
Sources: