Data Privacy and GDPR
How Assembley approaches personal data and GDPR: where it is processed, what data an assembly processes
Assembley Editorial
Running a digital assembly means processing personal data: voters' names, email addresses, identities, and how they voted. Handling that data properly isn't a side concern; it's part of running a defensible meeting. This article explains Assembley's approach at a factual level.
What data an assembly involves
A typical assembly touches:
- Voter register data: names, email addresses, and (for company groups) holdings and class.
- Identity confirmation: the verification used to tie a ballot to a person.
- Voting data: the ballots cast and the record of the meeting.
This is personal data under the GDPR, which means it has to be processed lawfully, stored securely, and handled transparently.
Where the data is processed
The database and the application run in Frankfurt, Germany (AWS eu-central-1), and transactional mail is sent from Ireland. Two of the three sub-processor agreements state that primary processing takes place in the United States. The sub-processor list shows both the agreement and where each service runs, and does not resolve them into one sentence.
Why privacy and a valid vote go together
It's easy to think of data protection and vote validity as separate, but they reinforce each other. A defensible assembly needs to know who voted (identity) and keep an accurate, secure record of how, and doing that responsibly means handling the personal data behind it carefully. The same record that makes a result verifiable is also personal data that must be protected. See How Vote Integrity Is Protected and How People Join an Assembly.
Your responsibilities
Assembley provides the platform, but your organisation remains responsible for using it lawfully: for example, having a proper basis to hold your members' data, keeping your register accurate, and removing data you no longer need. Keeping a clean, current register is good practice both operationally and for data minimisation. See Editing and Removing Voters.
A note on scope
Compliance depends on your specific circumstances, and this article is a factual overview rather than legal advice. For requirements particular to your organisation (retention periods, lawful basis, members' rights), consult your own data protection adviser.
Where to go next
See Managing Your Account for account administration and The Evidence Package Explained for how the meeting record is produced.
This page is general information, not legal advice. Rules change and your articles of association may differ, so check the current rules or ask an adviser before you rely on it.
Related articles
- How People Join an AssemblyThe two ways participants reach their ballot (registering themselves at the meeting, or being invited from your register) and the electronic-ID add-on
- How Vote Integrity Is ProtectedA plain-language explanation of how Assembley keeps an assembly's record tamper-evident: append-only vote records, frozen vote weights
- The Evidence Package ExplainedWhat the Assembley evidence package contains, the formats it comes in, and why a record that verifies itself matters when a result is challenged
