BYELAW 13  |  PRIVACY POLICY 

1. WHO WE ARE 

YesCymru Cyf is a non-party political grassroots organisation campaigning for Welsh independence, majority funded by Member subscriptions and donations. The only other income comes from the sale of YesCymru Cyf merchandise in the YesCymru online shop (see Section 5). YesCymru is committed to maintaining the trust and confidence of all supporters, whether a visitor to the website, a Member or someone who has shown an interest by asking to receive the newsletter. 

YesCymru Cyf values everyone’s support in the campaign to achieve independence for Wales. We will only collect the minimum personal data needed in order to keep subscribers up to date with campaigns and to enable them to get more involved if they want to. 

2. VISITORS TO OUR WEBSITE 

When someone visits yes.cymru it uses a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. YesCymru Cyf does this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 

3. MEMBERS 

As part of the joining process for YesCymru Cyf, we collect the minimum personal information that is needed to process payments – name, postal address, email address, as well as payment details (see below). This is used to keep people up to date with our news and campaigns (so that Members know what membership payments are helping us to achieve) and ways that Members can get more involved. The main way that we keep Members informed is via our mailing list. We will automatically add Members to this when they join YesCymru Cyf. Anyone can unsubscribe at any time (see Section 7). 

Members on an annual subscription will be contacted by email when their membership is due for renewal. Members making monthly payments will be 

contacted if there are any interruptions in payments (which usually happens because a bank card has been renewed or cancelled). 

Members of YesCymru Cyf, will be automatically added to our "Say Yes" pledge (see Section 4). 

When Members voluntarily share personal or special category information with YesCymru Cyf, it is taken that shared information may be used to assist Members or otherwise to achieve our aims and objectives. 

We may process personal data in order to investigate and handle internal complaints. 

3.1 Joining via our website 

When joining via the website, payment will need to be set up using a debit or credit card. This is handled by the NationBuilder payment processor. YesCymru Cyf does not collect or store any card details. In addition to the personal information collected as described at the beginning of Section 3, YesCymru Cyf needs phone numbers because this is a requirement of the payment processor to initiate the payment. 

3.2 Joining via a paper form 

In order to set up a standing order, details of a Member’s bank account will be collected. We transfer other details from the form onto our membership database, then send the paper form directly to the Member’s bank. We will not store any Member’s bank details. 

4. OUR “SAY YES” PLEDGE 

The data collected in order to process Members’ signatures is their name, email address, and postal address. We require postal addresses to enable us to find and remove duplicate entries, to ensure the integrity of the petition. 

4.1 Signing via our website 

Signing the petition on our website is a commitment to voting "Yes" in a referendum on Welsh independence. On that basis, our reasonable belief is that it is within the signatory’s legitimate interests and our legitimate interests, that we add those people to our mailing list so that they can hear more about the work of YesCymru Cyf. 

4.2 Signing via YesCymru Cyf membership 

Members of YesCymru Cyf do not need to fill in their details again for the petition, as this will happen automatically when they join. 

4.3 Signing via a Facebook Ad 

Apart from our website, the petition can be signed by submitting a Lead Ad form that is published via our Facebook page. Facebook will pre-populate details, but these can be modified before sending. These details will then be sent to the NationBuilder system and added to YesCymru’s mailing list. Use of Lead Ads is in accordance with Facebook’s Data Policy. 

5. CUSTOMERS IN OUR ONLINE SHOP 

We collect information about customers when they use the online shop, in order to process the order. We only collect the information we need, which will be the customers’ name and postal address (so that we can send the goods to the customer) and an email and telephone number (so that we can contact them easily if there is a problem with the order). This information will be held on the Ecwid database (view the Ecwid privacy policy), so that customers don’t have to re-register with us each time for future purchases. We will not use contact details to contact customers about anything other than their purchase, unless they opt in to receive more information from us during Checkout, in which case we will add them to our mailing list (see Section 7). 

6. OTHER WAYS OF CONTACTING US 

If customers get in touch with us via post or email about any other matter (or send us contact details via social media, or for example, by direct message on Twitter), and are not already a Member or a subscriber to our newsletter, we will not contact them about any matter other than the topic they have originally contacted us about. 

If we meet (for example at an event) and contact details are given to us in order to keep in touch, we will only collect name and email address, and will seek permission to add the contact to our mailing list. Contacts regarding a specific issue will not be added to our mailing list. 

7. OUR MAILING LIST 

We use a third party provider, NationBuilder, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletter. For more information, please see NationBuilder's privacy notice. 

We may use third party survey software, 123FormBuilder, to send surveys, where we collect the same personal information described in Section 3. The data is securely stored by 123FormBuilder. For more information, please see 123FormBuilder's privacy notice. 

The different ways to subscribe to our mailing list are explained above. Subscribers will receive occasional newsletters to keep them up to date with news, campaigns, events and ways they can get involved. These emails may be sent from YesCymru Cyf centrally, or from the local YesCymru Cyf group (see Section 8). 

We may also use contact information to check that our records are accurate and to check every now and then that contacts are happy and satisfied. 

From time to time, we may provide information about specific appeals we are running, for example if we are crowdfunding to raise money for a campaign, but we will keep these communications to a minimum. 

We may also partner with various local independence-supporting businesses around Wales that have committed to offering discounts on their goods and services exclusively to Members of YesCymru Cyf. We may email about these offers from time to time. YesCymru Cyf does not share any Member/contact details with these companies. 

Apart from the subscription methods described above, the website may be used to subscribe to our mailing list via the Sign up for news and updates section of our website. As part of the registration process for our mailing list, we collect minimum personal information - name and email address. 

7.1 Unsubscribing from our mailing list 

People on our mailing list may unsubscribe at any time by clicking the To change your email preferences, click here link at the bottom of any of our emails. There will be an option of whether to unsubscribe from specific types of email, or from all emails. The specific types of emails that can be unsubscribed are:- news and updates from YesCymru Cyf centrally, news and updates from YesCymru Cyf groups, and emails from YesCymru Cyf centrally containing exclusive offers from our partners. 

People may also unsubscribe by emailing us at [email protected]. If contacts unsubscribe via this method, we assume that they want to unsubscribe from all types of email, unless they state otherwise. 

8. SHARING INFORMATION WITH GEOGRAPHIC GROUPS 

YesCymru Cyf has a number of Geographic Groups operating in different communities across Wales. Members will be added to their local Geographic Group’s mailing lists automatically. A Group is deemed to be local if the Member lives in a county council ward deemed to be within the group’s catchment area - usually within a 10 mile radius of a Group. The ward is approximated by geocoding, which requires all parts of the postal address, and is based on the most recent address we hold for that person. 

The Geographic Group is bound by the privacy policies set out in this document. Provided that the Geographic Group also satisfies the criteria set out in Byelaw 7.5, the Group may nominate a person or persons to act as Data Processors. The Data Processor(s) for Geographic Groups may contact Members via email on behalf of their Group. They will only use Members data to keep them up to date with news about what the group is doing, and to issue invitations to local events and meetings. The Data Processor(s) for the Group will not be permitted to export data from our database, or share it with any third parties. 

Individual’s data will not be visible to the Data Processor(s) of any other YesCymru Cyf Group. 

All Data Processors for YesCymru Cyf are bound by the YesCymru Cyf Data Protection Declaration (Byelaw 12). 

Members can unsubscribe from the mailing list of their Geographic Group at any time by selecting the relevant option within the To change your email preferences, click here link at the bottom of any email from YesCymru Cyf or a Geographic Group (see Section 7.1). 

9. GENERAL 

We are a not-for-profit organisation that qualifies for an ICO registration fee exemption, and we are not legally required to appoint a data protection officer. 

We do not rent or trade email lists with any other organisations or businesses. We process personal data under the legal basis of Legitimate Interest. 

We will retain the personal information that we collect from Members until one year following the expiry of their membership. 

We do not use automated decision-making or profiling as part of our data processing activities. 

Individuals have the following rights in relation to their personal data: 

• To be informed about the data we hold, and how and why we process it; 
• To request a copy of the personal information that we hold about them; 
• To require us to rectify any inaccuracies within the personal data we hold about them; 
• To restrict processing of their data, if data is inaccurate or being processed unlawfully; 
• To object to their data being processed if they suspect that what we are doing is not legitimate; 
• To request that their data is deleted; 
• To request that we send a copy of their data electronically to them, or to a third party; 
• To withdraw consent by unsubscribing to our newsletter or cancelling a membership; 
• To lodge a complaint with the Information Commissioner's Office (ICO), who is our supervisory authority for data protection (https://ico.org.uk/concerns). 

10. FURTHER INFORMATION 

Any questions about this privacy statement or about how we use or store data? Contact us at [email protected]. 

Our registered address is:- YesCymru Cyf, Office 23609, PO Box 92, Cardiff, CF11 1NB. 

On the 1st of February the names were announced of the members elected to the new NGB, and the 15 board members have now started at their posts. The elected members represent 6 regions (5 from Wales and 1 region representing members from outside Wales).

North of Wales Region - Elfed Williams, Elgan Owen and Vaughan Williams Mid and West Wales - Ifor ap Dafydd, Gaynor Jones and Geraint Thomas
South Wales West - Christine Moore and Nerys Jenkins
South Wales Central - George Gethin Hudson, Andrew Murphy and Richard Huw Morgan South Wales East - Mihangel Ap-Williams and Phyl Griffiths
Outside of Wales - Barry Parkin and Louise Aikman

The process of incorporating YesCymru as a Company Limited by Guarantee is complete. The NGB held their first meeting with Azets on 2nd February, further meetings are scheduled over the coming weeks to ensure the hand over of administration from the interim management to the NGB is carried out smoothly and efficiently.

This is the beginning of a new and exciting period for YesCymru, and in the coming weeks, YesCymru will look to build further on the success of the past few years, leading the way in our campaign for independence for Wales.

INTRODUCTION

It’s now two months since the new National Governing Body was elected, and it’s been a busy time for the new directors.  Getting the foundations of the new YesCymru Cyf Company Limited by Guarantee (CLG) in place has been the first priority, starting with a host of handover meetings with the stakeholders that have been involved in the running of the organisations in recent months.  These meetings covered a range of areas including financial, legal, communications, social media and more. From these meetings and handover documents the NGB identified 153 action points that needed to be addressed to get the organisations back on track.

It was decided that the board would split up to 3 workstreams to execute these actions, made up of 5 directors each, working on Legal, Financial and Communications.  Weekly NGB plenary meetings are held, and workstream meetings are held frequently in between.  Monthly in-person meetings have been held, the first in February in Wrexham, and the March meeting in Merthyr Tudful.

WORKSTREAMS PROGRESS SO FAR

| The Financial Team’s Outline of work

Finance isn’t always the first thing that comes to mind when people think about independence but as a member driven organisation it’s vitally important that we ensure every single penny of members’ money can be accounted for and is wisely spent. From this year YesCymru’s accounts will be managed by experienced professional accountants ensuring independent support and scrutiny.

Membership money for this year has been allocated to finance two marche, the publication of a second YesCymru newspaper, designing and implementing a new website, and designing and printing new leaflets supporting campaigns addressing current issues. 

In addition funds are available for local groups to support bespoke activity across Wales including attendance at high profile public events. And this year, for the very first time, a portion of membership money will be set aside to fund our campaign during a future referendum on Welsh independence.

| The Legal Team’s Outline of work

At the last General Meeting of YesCymru, the Membership voted to change the legal status of our organisation from being an unincorporated association to that of a company limited by guarantee. YesCymru Cyf. was then formally incorporated and a board of directors (the National Governing Body, or NGB) was elected by the Membership. You can see publicly available information about YesCymru Cyf., including its directors, on the Companies House website.

The Membership also voted to adopt the Articles of Association (effectively the constitution) proposed by the Gweithgor but it is a requiremen that the NGB produces its own bylaws. These are the rules, policies and procedures by which YesCymru Cyf. is run. The Gweithgor did an exceptional job in a short period of time to provide a proposed draft set of bylaws, but the NGB is required to review these and amend or update them where necessary. 

There are 18 Bylaws in all, and 14 of the Bylaws have so far been processed and presented to the NGB, and have either been adopted by the NGB or are very shortly to be adopted following minor agreed amendments, leaving four Bylaws still in process.  

There have also been some less intensive tasks, such as ensuring that our insurance policies are transferred across to YesCymru Cyf., making recommendations regarding our registered company address and how we cover the Company Secretarial aspects.

The next significant task will be to review the Bylaws and identify the appointments, systems and procedures that will be needed to ensure that we are working in strict accordance with the Bylaws, and to ensure that the Bylaws are kept up to date.

| The Communication Team’s Outline of work

The Communication Team’s early priority was to reconnect the NGB with the wider membership and grass roots campaigning.  It was decided that a newsletter would be a good communication tool to connect with the membership.  The focus of the newsletter is grassroots campaigning and a focus on groups. Two slightly different versions of the newsletter are produced every week - one for the 10,000 members on the database and one for the 20,000 supporters on the mailing list.  

The email account [email protected] was set up to encourage members to share the photos of grassroots campaigning with a wide audience through YesCymru’s social media channels. If you have any campoaigning pictures to share please send them to us.

Although a creative agency was helping with running our social media accounts, the contract expired at the end of January, it was agreed to continue working with them until the end of March as part of a handover process, and a procurement process has been executed to identify new suppliers to provide the service.

A short term strategy was agreed upon, and a re-focus on campaigning, members and the grass-roots base of YesCymru was deemed to be priority, and a focus away from internal issues that had been such a prominent part of the communications focus of the past few months (i.e. the Gweithgor, the EGM, and elections). Combining this strategy with the ability of the membership to re-start campaigning on the streets gave the Communication Team a good base to get to grips with the task in hand.

| The Groups Team brief outline of work

The Groups Team started work late than the first three workstream teams, but has made headway in setting up a lot of the structures required in the Articles of Association and Byelaws. The 5 Regional Councils have been set up, and all have had their first meetings. This should pave the way for the inaugural Council of Deputies meeting later this year.  Work has started on an audit of the groups to find out which groups are still active, and which have joined forces with others. Some groups have been identified as active campaigners, some are only active in the social media domain.  As part of the questionnaire, there were open questions regarding what resources groups would like to support their campaigning. Work is already underway to set up training sessions to enable group leads to maximise their use of NationBuilder database software.

Work has started to engage with groups who are registered as ‘accredited’ in the new constitution, as well as to form mechanisms to enable ‘associate’ groups to develop into fully accredited groups. A survey is under way to investigate the diversity make-up of our groups.  Diversity monitoring information will enable us to monitor the effectiveness of our Equal Opportunities Policy and meet our legal obligations under the Equality Act 2010.

Moving forward, there will be a bi-monthly newsletter to update group leaders. 

| Defined Roles

In a recent plenary meeting the following roles were outlined to the following directors.

MEDIUM TERM PROJECTS IN THE PIPELINE

The NGB and partners have been working on the following projects so far and they will form the basis of our medium term campaigning for the next few months.

| Skills Audit

We will be emailing a survey to all of our members to audit the skills we have within the organisation.  It was agreed that our campaigning needs to be a multi pronged approach.  This requires a multitude of disciplines, some practical, others technical, organisational and many more.  We have a wealth of experience and talent within our members, and tapping into only a fraction of this pool should enable YesCymru to ramp up its campaign in many different ways.  

The skills audit result will form part of the members’ database, and will enable the NGB to build strong ties with grassroot members, and bring our members to the forefront of the strategic planning in the long term.

| Newspaper

Due to the success of last year’s YesCymru newspaper, the second edition is already in the pipeline.  

Getting the independence message out to a wide audience is the primary aim, an audience who may not normally engage in other campaigns, or on-line streams.  Furthermore the newspaper gave groups and individuals a focus to their campaigning for a period of time, uniting groups after a previous period of Covid induced inertia.  We hope to build on the success of the first edition with this second edition due out in late spring.

| New Website

A new YesCymru website is under construction, and will provide an upgrade on the existing provision. The new website will provide a more streamlined journey through the website and a more coherent organisation of information and features. It will provide a greater scope for news and features, integrate fully with YesCymru’s database software, and also improve the journey for the indy-curious who visit the website to interact with YesCymru and become part of our campaign for Independence.

| Leaflet

As part of our mission to update our campaign literature, YesCymru intends to improve the output of leaflets available.  The first new leaflet has already left the press - a leaflet on energy and electricity production and fuel poverty.  The leaflet design was provided by YesMerthyrTudfil, and was fast tracked by the NGB to a large-scale print run to be used nationwide.

| Eisteddfod

After a two year hiatus, the National Eisteddfod will be back in 2022, this time in Tregaron. YesCymru will once again have a stall on the Maes, and a talk in the debating arena - Pabell y Cymdeithasau. Once again we hope that the YesCymru stall will be the hub of all things indy on the Maes, and a place that everyone can come to buy their YesCymru merchandise for the year.

| Research Team

In instigating the YesCymru research team  we hope to build up a bank of written material that will form a foundation of our campaigning.  The output will vary from high-level academic type papers to long essays, articles, features and short focus articles.  This bank of information will be used throughout our campaigning, from updating our ‘Independence in Your Pocket’ booklet to creating topic-specific leaflets down to social media bite-sized outputs.

| Wrexham March

YesCymru will be playing a pivotal role in organising the independence march in Wrexham on July 2nd, and are working closely with the local organising committee and AUOB to make this the best independence march yet.  This time round the event will be much more than just a march, with a weekend-long indy festival in the pipeline.  The festival will involve live music and events over Friday evening, Saturday and Sunday, and will be an event to involve the whole community in the town centre.  More information will be announced as the details are put in place.

And of course we are looking forward to the second march in Cardiff in the autumn.

| Merthyr Rising

YesCymru will have a presence at this festival of music and radical thinking, 10-12 June 2022. Having outgrown its Penderyn Square location, this year sees the festival moving to a large marquee in Cyfarthfa Park. YesCymru involvement will consist of a stall within the main marquee for information, merchandise and recruitment of new members. In addition, we have been invited to organise an indy talk on the main stage on the Saturday morning. YesCymru members attending the festival will be able to claim a discounted rate on ticket prices.

Please click for more details - https://www.merthyrrising.uk

AMBITIONS FOR THE COMING MONTHS

| NGB - Groups relationship

The NGB hopes to enable members and groups to campaign at grass root level by being the oil in the machine of YesCymru’s grassroots campaign.  We appreciate that the frontline of our campaign is the day-to-day campaigning of our members and groups.  We aim to install all the structures and processes needed to ensure that this relationship develops as smoothly as possible.  This will involve good communication lines, encouragement for campaigning through financial support and national communications.  We will also work to encourage members who may not play active parts in group activities to join local networks, and strive to develop campaign-shy members into active confident campaigning members of YesCymru (see more about this below).

| Regional Campaigning

With the introduction of the Regional Council, another dynamic has been created.  With frequent strategic meetings at regional level comes the opportunity to coordinate events for maximum impact.  Although YesCymru NGB board members cannot take lead roles in the Regional Councils, the NGB will encourage cooperation between groups, Regional Council, Council of Deputies and NGB to coordinate campaigning for maximum impact.

| National Campaigning

The NGB strives to lead the campaign nationally by supporting marches, providing material and all the networks, structures and practical support needed to maintain the campaign nationally. By cooperating with other pro independence groups in sport, music and the arts, we hope to move the agenda forward beyond YesCymru itself. Continuous dialogue will be established with all stakeholders within the independence movement, including a formal representation at the constitutional commission, and actively encouraging our members to engage in the commission’s process.

MEDIUM TERM STRATEGY

| Professionalise the movement

Almost all of the efforts of the NGB so far has been to professionalise YesCymru.  As we have previously mentioned, this involves many legal and financial frameworks and processes.  Much of this work is a continuation of the work that the Gweithgor carried out in the lead up to the EGM in December.  These processes should serve YesCymru well for years to come, and allow for increases in both membership and campaigning capacity.

| Increasing Grassroots Participation

As the second largest politica l organisation in Wales, YesCymru strives to capitalise on the campaigning capacity of its membership.  Although a large percentage of our members will regularly participate in active campaigning, we will look to encourage and enable as many members and supporters as possible to participate in grassroots campaigning.  Like many campaigning organisations, a percentage of members and supporters will be somewhat campaign-shy.  The NGB will seek to enable members to become campaign-confident over the coming months.  This might involve increasing the number and variety of events and campaigns to suit different demographics, but also join the dots, so to say, between members and groups (both geographical and special interest).

| Driving the Independence agenda in the media once again

In the past YesCymru has been very successful in getting the idea of independence to Wales to the forefront of the political agenda in the media. By developing and coordinating our campaigns locally and nationally, as well as specific targeting of media outlets and social media, YesCymru should aim not only to lead the debate on independence, but to actively drive it forward.  This isn’t going to be easy, as the news landscape has changed somewhat in the recent past, and will take a great deal of effort and resources to do so, but it will form a cornerstone of YesCymru’s strategy in the medium to long term.

| Engaging Key Demographics

Another of the NGB’s strategic priorities is to aim to engage key demographic groups and sections of society in the independence movement by diversifying the way we campaign.  By identifying key demographics and sectors of societies and communities that will be key to gaining the majority needed in a referendum, we can start actively engaging with these groups.  This might involve indirect campaigning strategies including music, sports and the arts for example. Connecting the independence movement with certain cultures (say the music scene, or sport teams supporters networks) will help some groups who may not be naturally politically engaged to drive the independence agenda across Wales.

These are some of the early achievements, projects and thoughts of the new YesCymru NGB.  No doubt these elements will evolve over time, and will need to be reviewed frequently as the movement and political climate changes.  

Thank you for reading this update, and please feel free to feedback your thoughts.