Timeline of Correspondence with Dominic Cummings

Ii[Tli'li11~of correspondence with Dominic Cummin_g~~

- Date Correspondence ______30/08/2018 Ema ii from Dominic Cummings:

Con firmed he will sign the undertaking and can be interviewed in October. ------1 15/08/2018 j Ema ii from Danielle Whalley to Dominic Cummings asking for dates he is available to b e interviewed and a copy of a draft undertaking for him to sign. - 08/08/2018 j Ema ii from Dominic Cummings to confirm he will be interviewed. 02/08/2018 Witness letter sent to Dominic Cummings:

The contents confirm that "the ICO has reasonable grounds to believe that a pot ential breach of the Data Protection Act, may have occurred in regards to the use, transfer or sharing and processing of personal data between Vote Leave and AIQ'

"We wish to interview you as a witness to the matters we are investigating". The inte rview conducted with you will be audio recorded in order to assist us in obtaining your full account and ensure that our conversation is accurately recorded" - ---- 10/07/2018 Ema ii from Dominic Cummings to Danielle Whalley answering the questions asked in the letter 19/06/18 - ------06/07/2018 Ema ii from Dominic Cummings to Danielle Whalley including 2 attachments.

DC a dvises in his email that a further letter explaining the context would be sent shortly. - 03/07/2018 Cha ser email from Danielle Whalley to Dominic Cummings regarding the letter dated 19/06/18. ------26/06/2018 Ema ii from Dominic Cummings confirming receipt of the letter dated 19/06/18 -----< 19/06/2018 Letter from Danielle Whalley to Dominic Cummings:

Further questions regarding Vote Leave and Aggregate IQ to assist with our inve stigations. ------~------' 22/11/2017 Ema ii from Steve Wood to Dominic Cummings & Henry de Zoete:

Con firmation that an Information Notice had been sent to Vote Leave and a resp onse received from Venner Shipley, acting on behalf of them. Steve Wood advi ses that Venner Shipley have not supplied detailed answers to the ICO's ques tions. Although the above are no longer formally involved with Vote Leave, they hold key knowledge about how data analytics were used within the cam paign.

In light of the gaps Steve Wood request a meeting with both Dominic and Henry. -- 09/08/2017 EmaiI from ICO to Dominic Cummings:

Confirming receipt of his response and to advise that we may wish to contact Vote Leav e in due course with further enquiries. - 16/07/2017 Letter from Dominic Cummings to ICO:

• AIQ hired for direct marketing • AIQ were given information ----- • Allegations that AIQ shared data with other companies are false • Only relationship between Vote Leave and BeLeave.is that Vote Leave made a donation to Be Leave after the Electoral Commission stated that they could. Requested evidence of this in further enquiries. • Someone from BeLeave may have attended regular Steering Group to discuss the campaign or a similar meeting. • Some data analytics conducted in house and hired some consultants to provide specialist data science help. Requested further details in next round of enquiries • Data Science team contractually bound to uphold the highest standards in terms of data protection. Believes that no data science consultants held non-anonymised personal data on their company systems. • Very limited (if any) paid advertising on Twitter. Spent a lot of money on Facebook. Used Facebook to run surveys to add to polling data. Used information obtained via Facebook to add to polling data - requesting clarification on this. • Generated large amounts of personal data from a football competition. • Nationbuilder was used for activist management - need further information on this. • Data scraped for free from the web.

(unable to obtain letter through link-17/07/17) - 17/05/2017 The letter dated 4 May 2017 was sent to Dominic Cummings by email. Within the email Steve Wood advises that Vote Leave "are regarded as part of the wider ·invesfigatibnlhoffgnTiidividual 'cfecisioris wm ·oe· made· about the extent of the investigation on different elements". 14/05/2017 Email from Dominic Cummings to Steve Wood: Confirmation that if the questions could be sent to him directly he will answer to his best ability. - 13/05/2017 Email from Matthew Elliot from Vote Leave to Steve Wood:

Advising the best person to answer the questions would be Dominic Cummings

-- a_nd Henry de Zoete _____ ------< 04/05/2017 Letter from Steve Wood to Victoria Woodcock at Vote Leave:

To arrange a meeting with Vote Leave's senior leadership to discuss their use of the services of Aggregate IQ ("AIQ"). Within the correspondence specific points for discussion are addressed. • Upholding information rights

ICO. Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 SAF Information Commissioner's Office Tel. 0303 123 1113 Fax. 01625 524 510 www.ico.org.uk

Victoria Woodcock Vote Leave Limited Westminster Tower 3 Albert Embankment London SE1 7SP

By email only to:

4 May 2017

Dear Ms Woodcock

Reported use of personal data by AggregateIQ and the use of data analytics by Vote Leave for political purposes

The Information Commissioner's Office is the UK's independent authority established to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

As Head of International Strategy and Intelligence, my responsibilities include tracking strategic issues or risks related to privacy and data protection.

You may be aware that the Information Commissioner's Office (ICO) has been considering recent media coverage and enquiries regarding data analytics use by political parties and whether this use of data is compliant with the United Kingdom's Data Protection Act 1998. In this context we will be contacting a number of organisations, and intend to publicise our overall findings later this year.

Given your reported use of the services of technology company 'AggregateIQ', we would like to arrange a meeting with Vote Leave's senior leadership to discuss these matters in more detail. I would be grateful if you could provide us with some suitable dates for a meeting to take place within the next three weeks.

The Information Commissioner requests your cooperation in helping us to establish the facts in order that we may make an informed decision about what further action, if any, is necessary. To assist you in preparing for our meeting, we • ICO. Information Commissioner's Office

thought it would be helpful to set out some of the points we would like to discuss:

(1) the relationship between Vote Leave and AggregateIQ (and any other relevant group of companies); (2) the relationship between Vote Leave and the campaign group BeLeave; (3) what, if any, services or data provided by AggregateIQ have been used by Vote Leave; (4) any use of data analytics services by Vote Leave; (5) any use of data extracted from Facebook, Twitter or any other social media platform; (6) what types of personal data were held by Vote Leave in advance of the EU referendum and are being held currently, including electoral roll information; (7) how (and where) that data was and is being processed, and for what purpose; (8) the sources of the personal data processed by Vote Leave in advance of the EU referendum and subsequently; (9) any information that was and is being provided to individuals to assist them in understanding what data is being gathered about them and how and for what purpose it is being used; and (10) any other information you feel may assist us in understanding: a. how data has been used by Vote Leave in the run-up to the EU referendum and subsequently; and b. how the organisation complies with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

We look forward to discussing these points with you at our meeting and thank you in advance for your cooperation.

Yours sincerely

Steve Wood Head of International Strategy & Intelligence Information Commissioner's Office ------From: Matthew Elliott••••••••••••• Sent: 13 May 2017 00:59 To: Steve Wood Cc:

Subject: Email from Matthew Elliott re VL letter dated 4th May - 13 05 17

Dear Steve,

Apologies for the delay getting back to you. I am on the road at the moment in the US.

The best people to answer your questions are Dominic Cummings and Henry de Zoete, who were Vote Leave's Campaign Director and Digital Director respectively. They are both happy to help you with this, and I have cc'd them to this email.

Best, Matthew

On 4 May 2017 at 04:57, Steve Wood

Dear Matthew,

I'm forwarding this to you, as directed by the out of the office message I received. Grateful if you can confirm receipt.

Regards

Steve

Steve Wood Head of International Strategy & Intelligence

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. T. 01625 545706 www.ico.org.uk

For secure emails over GSI please use ~.leve.woocl('.jiicll.gsi.qoy.uk Matthew Elliott

3 111111111111111______

From: Dominic Cummings Sent: 14 May 2017 05:27 To: Steve Wood Cc:

Subject: Email from Dominic Cummings requesting VL ltr dated 4th may - 14 05 17

Hi Steve

Ifyou send me through your questions I will do my best to answer, the attachment has dropped off the email chain.

I am abroad right now with intermittent email.

Best wishes Dominic

On 13 May 2017 at 00:59, Matthew Elliott wrote: Dear Steve,

Apologies for the delay getting back to you. I am on the road at the moment in the US.

Best, Matthew

On 4 May 2017 at 04:57, Steve Wood wrote:

Dear Matthew,

I'm forwarding this to you, as directed by the out of the office message I received. Grateful if you can confirm receipt.

Regards

Steve

1 The ICO's mission is to uphold information rights in the public interest. To find out more about our work please visit our website, or subscribe to our e-newsletter at i~~~,Q_rg.uk/ncwsli.:tte1:.

Ifyou are not the intended recipient ofthis email ( and any attachment), please inform the sender by return email and destroy all copies without passing to any third parties.

Ifyou'd like us to communicate with you in a particular way please do let us know, or for more information about things to consider when communicating with us by email, visit jc<1.otJ!.uk/crnail

Matthew Elliott

3 ------From: Steve Wood Sent: 17 May 2017 17:22 To: Dominic Cummings Cc:

Subject: Email to Dominic Cummings with VL ltr dated 4th May - 17 05 17 Attachments: Vote Leave Letter 20170504.pdf

Dominic,

Many thanks for getting in touch. I attach the letter we sent to Matthew (addressed to Victoria).

The Commissioner has also made a further announcement about our work on use of data analytics for political purposes (see below). Vote Leave are regarded as part of the wider investigation though individual decisions will be made about the extent of investigation on different elements. As you are unavailable for a meeting at present I would request a written response to the questions as soon as possible and we will then consider what next steps may be required.

httQs: //iconewsbloq. word.Press. corn/2 O17ffi'2L 17/information-commissioner eliza beth-denham-ogens-a-formal-investigation-into-the-use-of-data-analytics-for politica1-gurposes/

Regards

Steve

Steve Wood Head of International Strategy & Intelligence

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. T. 01625 545706 www.ico.org.__u_k

For secure emails over GSI please use ;[email protected]_s_i_._g_pv.uk

From: Dominic Cummings [mailto: Sent: 14 May 2017 05:27 To: Steve Wood

Subject: Re: FW: Letter from the Information Commissioner's Office

Hi Steve

Ifyou send me through your questions I will do my best to answer, the attachment has dropped off the email chain.

I am abroad right now with intennittent email.

Best wishes 1 ~------ From: Sent: 18 September 2018 13:38 To: Subject: FW: FW: Letter from the Information Commissioner's Office

From: Dominic Cummings [mailto: Sent: 16 July 2017 14:28 To: Steve Wood

Subject: Re: FW: Letter from the Information Commissioner's Office

Dear Steve et al

Apologies for the delay I have been abroad and very busy.

A few answers to your questions.

You will appreciate a year has passed and I kept no diary of the campaign and kept very few records so much is fuzzy.

Many nrndi~l reports on these subjects have hurJdy confuser.I \lie issues. In pnr1icul.:ir, the Observer has mc1de m~my accusations Lhat aru false. E.g il has claimed tlrn! there wai; secrtit coorc1i11ation between Vole Leave and Leav0.EU. This is la11ghable. Tl'le author of u,~ dcfini!ive book on the rc.fcrnndurn, Tim Shipm;:in. said th0 probability of this l:J0ino true is 'z.oro percent". Thal ls right. When Arron Banks said he saw Voto Le,we as 'the real enemy·, he was unwisely and regreHably, but horwslly, reve;:iling his actual attitude. The idea that Vote Leave Wi'IS secretly coordii1c1lin9 ,iata and spending with Le;:ive.EU is as plausible as Arron 8.-mks's claim that Vote Leave was really a front operation for David Cameron.

There arc many craz.y allegations and theories spinning around the web. I have not tried to answer all these below. If there are further specific ques1ions yt1u want to ask me then please email. I am often abroad at the moment but I will try lo answer.

-1. We hired AIO m,.iinly to c,:xc:cute di

They were given information on who we wanted to communicate with nnd their job was lo come up with creative ideas {working with our in-house team) and execute buying di9ital ads across r:acetmok. Youtube, display etc. and 81so coordin;i!inn such activity with our website, emails and so on. Contra many reports, they are not a 'data science' company and they did not do data science for us. Modelling was prnvided to them L>y Lw, not by them to us. Thay did not \Jt1y pcr'.,On:;il d8t.1 for us. AIO alsu !wiped wilh somti technical issues concerning the integralion of the voter database, lhe inlr~rbce will I cunvas:-mrs ('VICS'). tcrnails to supporter~;. ,mci crowdfunding lhoU\Jll Lhey W(·JrU nol. pr irn.:irily ro~ponsibl8 fur sud1 lhinqs. Tim d,1tr1h;1se itsulf was stored on Amazon's AWS cloutl system and w·~ wer1I lhrollql·1 ri!JOl"(H.IS :st,,:urity c:hed;s. Tl1~, oveiwl1cl111ing majority of the rnormy th,11 went \r, lliem was ,-,1mnt hy llwm ,·m dlvilal mar!wlin:J with cJ retntivelv ~.mall :imounl for fr~B:-, (I think Lhu re!Ev21nl nwnher·s ;cin~ i11 ow nfficial n,tuin ln 1lm EC).

They were subject to the same sl rid controls put on evnrybody in terms of acces,; to r.k1!.a arid rrotoenls to pmlL,ct pr~rs<111c1I (i,11.:1. Claims in the mm.1ia that they SI 1-:irBd our data with o\11er· ,,ompanies. im;hidinn cornpanies relat;::d ln Rc,lir11t M1:,rc81, art.:: wh,.illy f;ilo:c. They wcn) unchC!r strict leqZJI obti[-F:ilior1s {UK and C:c111c1d;:1) not lo sll,ire (lt11 dala with ,mybody 8nd I rnn as conf1clcnt as I can he~ that they did rwl. Alkn,ili irivulvfilllf:nl will I Mr:rcer. El~11111(,n. Tn11111), Puli11 ,.,r ;rnyhotly filt~(" Wr·, an:-' flllngod lo h;.lVe tierm s8cretly working with by LI 1c Ohsmv8r. I h,1v!r) l r::JW' t,,nrn l1;HJ u tolally cliffcre11t ,.1lti\11

2. BeLeave was an independent organisation which conducted its own referendum campaign. As far as I know the only

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1 be possible - that we asked the EC to confirm it in writing which they did. The VL directors could provide you with a copy if it is not already in the public domain.

It is possible that someone from BeLeave attended our regular Steering Group to discuss the campaign or some similar meeting. I do not know if this happened. This meeting is a reflection of how the regulatory system is in some ways Kafka-esque. The EC encouraged such a regular meeting yet at the same time we were prohibited from 'coordinating' in various ways. This duality is essentially illogical: following the EC's advice too enthusiastically would lead to the accusation of illegal coordination. What is 'too enthusiastically'? Nobody knows including the EC. There are many similar examples of how the regulatory structure creates Catch 22s that are impossible to navigate and be sure you are following the rules, not least because the regulatory bodies responsible often cannot say what 'the rules' are or they give answers that are contradictory to other elements or to previous statements. This is fundamentally the fault of senior politicians of all parties and senior officials in central government, not the agencies themselves.

If BeLeave did attend the Steering Committee meeting or equivalent it can in no way reasonably be seen as evidence of 'coordination' in the relevant sense.

3. Answered in ( 1 ).

4. We did some data analytics in-house and hired some consultants to provide specialist data science help. This essentially concerned how to make probabilistic predictions about the electorate so that we could focus our marketing and ground campaign as effectively as possible. The maths and methods were almost totally beyond me and I could not usefully explain them. If you look at my biog you will see some detail about this (htlp.:c,://clrn:nlniccumminqs.com/20 I f.i/ 'I 0/2Won_-th0-rpferendum-20-the-c;_1mpciiqn rtlly_s_i_C§,.":.1.HKI -dc1 la·S\~1enco-vule-lo_

The data science team, like AIQ, was contractually bound to uphold the highest standards in terms of data protection. I think it is the case that no data science consultants held non-anonymised personal data on their company systems. I certainly remember them stressing that they neither needed nor wanted to hold personal data and would prefer everything anonymised (there was a method to anonymise automatically data from our database for analysis). This was certainly the approach we took. I cannot remember if there were any exceptions. If there were then they anyway were under strict obligations to destroy it all and have assured VL post-23/6 that they do not hold any personal data.

We also built a canvassing tool that we made free for public download after the campaign. This was a decision of the VL Board which concluded that it would be a public service to make available the result of VL donors' efforts so that others of any political affiliation could engage with the electorate more easily.

5. We did zero or close to zero paid advertising on Twitter (possibly some tiny experiments but if so they were so irrelevant I cannot even remember if they occurred). We spent a lot of money on Facebook (details and numbers on my biog). Some of it was simple (e.g using their standard 'look-alike audience' function) and some of it was sophisticated. Essentially, we derived from our polling an idea about crucial people to target. We then used Facebook's advertising platform to run experimental ads at target audiences. We measured what worked. We then put as much money as we could behind the most effective ones over the last 2-3 weeks. (To complicate things slightly we also used Facebook to run surveys to add to our polling data as part of an exercise to do massive sample polling which you may have seen reference to recently in relation to YouGov's use of similar methods to create the most accurate model for the 2017 election.)

The whole process of coordinating data between all the different sources - web, email, social media, canvassing etc - was very complex and one could write a book about it but I cannot go into it all beyond what is on my biog (to the extent I even understand it, which is limited).

If you have specific questions then please email.

6. We held personal details of all staff who were employed by Vote Leave Ltd including name; address; next of kin; telephone details and some ernploymr~111 records.

We held a list of all donors to Vote Leave Ltd together with their names, addresses and electoral roll reference to support the returns made to the Electoral Commission by Vote Leave Ltd.

Our Nationbuilder account was deleted in the week after the campaign.

We ran a football competition on a separate system (cf. press references to '50 million pound prize offered by Vote Leave' etc). This gathered large amounts of personal data. Almost nobody at VL had access to this and it was entirely deleted shortly after the campaign.

Before the vote we had a database that included the electoral roll, website signups, people who had answered direct mail, canvassing data, social media data and more. The main database on AWS was shut down on 4 July 2016.

We did not, contra some reports, buy any of the big commercial databases like Mosaic. (This was because of the combination of relatively high expense and low quality.) We scraped data for free from the web such as the census.

2 -~------ From: Sent: 09 August 2017 14:22 To: 'Dominic Cummings' Cc: OPCederberg Subject: 2017 08 09 Email acknowledging response to Vote Leave Ltr of 16th July from

Dear Dominic

I am writing on behalf of the Information Commissioner's Office (ICO) to acknowledge your response of 16 July 2017, I apologise for the delay in responding to your email.

Thank you for your response to the ICO's enquiries. We will now consider Vote Leave's responses as part of the ICO's work into the use of data analytics for political purposes.

The ICO may wish to contact Vote Leave again in due course with further enquires however I note from your response that Vote Leave may be shutting down in the near future. If known, it would be appreciated if you could provide the ICO with the anticipated date at which Vote Leave will shut down. If there are any changes to who at Vote Leave the ICO should contact with further enquiries, as described in your previous response, please also inform us of these.

Please send any response to the following email address: [email protected].!5.

Regards

• ICO. Lead Case Officer Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 SAF T. 01625 545815 F. 01625 524510 ico.or_y.uk t~i_lt~.:'_l',_CQrn/iconews _Please consider the environment before printing this email

From: Dominic Cummings [mailto: Sent: 16 July 2017 14:28 To: Steve Wood

Subject: Re: FW: Letter from the Information Commissioner's Office

Dear Steve et al

Apologies for the delay I have been abroad and very busy.

A few answers to your questions.

You will appreciate a year has passed and I kept no diary of the campaign and kept very few records so much is fuzzy 1 Many media reports on these subjects have hugely confused the issues. In particular, the Observer has made many accusations that are false. E.g it has claimed that there was secret coordination between Vote Leave and Leave.EU. This is laughable. The author of the definitive book on the referendum, Tim Shipman, said the probability of this being true is 'zero percent'. That is right. When Arron Banks said he saw Vote Leave as 'the real enemy', he was unwisely and regrettably, but honestly, revealing his actual attitude. The idea that Vote Leave was secretly coordinating data and spending with Leave.EU is as plausible as Arron Banks's claim that Vote Leave was really a front operation for David Cameron.

There are many crazy allegations and theories spinning around the web. I have not tried to answer all these below. If there are further specific questions you want to ask me then please email. I am often abroad at the moment but I will try to answer.

1. We hired AIQ mainly to execute digital marketing. We started speaking to them in, I think, March 2016 and we hired them mid April until the vote. Some of their staff sat in our HQ, others worked remotely from Canada. I hired them because our data science team and Henry de Zoete, who interviewed them via phone/Skype, advised that they were the best company we could find for what we wanted in the time available.

They were given information on who we wanted to communicate with and their job was to come up with creative ideas (working with our in-house team) and execute buying digital ads across Facebook, Youtube, display etc, and also coordinating such activity with our website, emails and so on. Contra many reports, they are not a 'data science' company and they did not do data science for us. Modelling was provided to them by us, not by them to us. They did not buy personal data for us. AIQ also helped with some technical issues concerning the integration of the voter database, the interface with canvassers ('VICS'), emails to supporters, and crowdfunding though they were not primarily responsible for such things. The database itself was stored on Amazon's AWS cloud system and we went through rigorous security checks. The overwhelming majority of the money that went to them was spent by them on digital marketing with a relatively small amount for fees (I think the relevant numbers are in our official return to the EC).

They were subject to the same strict controls put on everybody in terms of access to data and protocols to protect personal data. Claims in the media that they shared our data with other companies, including companies related to Robert Mercer, are wholly false. They were under strict legal obligations (UK and Canada) not to share our data with anybody and I am as confident as I can be that they did not. Allegations that AIQ was under legal obligations to share our data with Robert Mercer are false: they were under no such obligations and even if they had been that would have been superseded by their legal obligations regarding our data. (We had zero involvement with Mercer, Bannon, Trump, Putin or anybody else we are alleged to have been secretly working with by the Observer. I have spent over 15 years publicly opposing those in UK public life, ironically often pro-EU, who have argued for treating Putin in a friendly way. The Vote Leave team had a totally different attitude than Farage and Banks.)

2. Beleave was an independent organisation which conducted its own referendum campaign. As far as I know the only '.relationship' wasJhat we made a donation -to them after the Electoral Commission saidwe could with a few weeks to go. This was volunteered to us by the EC in response to complaints made by us about the conduct of the Government, the Cabinet Secretary Jeremy Heywood, and the IN campaign. This was such a surprise to us - there had never been any indication such a thing might be possible - that we asked the EC to confirm it in writing which they did. The VL directors could provide you with a copy if it is not already in the public domain.

It is possible that someone from Beleave attended our regular Steering Group to discuss the campaign or some similar meeting. I do not know if this happened. This meeting is a reflection of how the regulatory system is in some ways Kafka-esque. The EC encouraged such a regular meeting yet at the same time we were prohibited from 'coordinating' in various ways. This duality is essentially illogical: following the EC's advice too enthusiastically would lead to the accusation of illegal coordination. What is 'too enthusiastically'? Nobody knows including the EC. There are many similar examples of how the regulatory structure creates Catch 22s that are impossible to navigate and be sure you are following the rules, not least because the regulatory bodies responsible often cannot say what 'the rules' are or they give answers that are contradictory to other elements or to previous statements. This is fundamentally the fault of senior politicians of all parties and senior officials in central government, not the agencies themselves.

If Beleave did attend the Steering Committee meeting or equivalent it can in no way reasonably be seen as evidence of 'coordination' .in the relevant sense.

3. Answered in (1 ).

4. We did some data analytics in-house and hired some consultants to provide specialist data science help. This essentially concerned how to make probabilistic predictions about the electorate so that we could focus our marketing and ground campaign as effectively as possible. The maths and methods were almost fotally beyond me and I could not usefully explain them. If you look at my biog you will see some detail about this (t.1Uris://

This team has experience of working with sensitive data and has built state-of-the-art secure systems for handling it to avoid errors, loss, theft etc, including penetration testing far beyond what is normal in political campaigns. Although there were inevitably occasional cases of VL staff making errors with data, some of which were the object of correspondence with the ICO during the campaign, there were no errors or problems with our data science team who handled everything with extreme professionalism. 2 We also built a canvassing tool that we made free for public download after the campaign. This was a decision of the VL Board which concluded that it would be a public service to make available the result of VL donors' efforts so that others of any political affiliation could engage with the electorate more easily.

5. We did zero or close to zero paid advertising on Twitter (possibly some tiny experiments but if so they were so irrelevant I cannot even remember if they occurred}. We spent a lot of money on Facebook (details and numbers on my biog). Some of it was simple (e.g using their standard 'look-alike audience' function) and some of it was sophisticated. Essentially, we derived from our polling an idea about crucial people to target. We then used Facebook's advertising platform to run experimental ads at target audiences. We measured what worked. We then put as much money as we could behind the most effective ones over the last 2-3 weeks. (To complicate things slightly we also used Facebook to run surveys to add to our polling data as part of an exercise to do massive sample polling which you may have seen reference to recently in relation to YouGov's use of similar methods to create the most accurate model for the 2017 election.)

If you have specific questions then please email.

6. We held personal details of all staff who were employed by Vote Leave Ltd including name; address; next of kin; telephone details and some employment records.

We held a list of all donors to Vote Leave Ltd together with their names, addresses and electoral roll reference to support the returns made to the Electoral Commission by Vote Leave Ltd.

Our Nationbuilder account was deleted in the week after the campaign.

It was agreed at the last Board that I attended (the week after the vote) that everything remaining would be deleted about a year after the vote. I do not know the current status of data that I have not said above was deleted. It should be easy for those copied in to answer this question. I cannot easily coordinate with them and it is better the directors answer this themselves to avoid confusion.

7. The database was on Amazon's AWS cloud system. We also used Nationbuilder for activist management. Both of these were closed down shortly after the vote as per above.

8. See (6).

9. I don't understand this question well. Before the vote we fully complied with any relevant laws on this. After the vote VL had zero interest in gathering new data, only in deleting it and closing down (with thank you letters etc). Almost all staff rapidly dispersed. VL is not gathering data about people and has not been since the vote. VL only exists now to comply with various laws and the plan has been to shut it down as soon as possible while behaving reasonably in relation to the law as far as the law can be discerned.

10. Nothing further to add beyond pointing you to our official policies with which we strictly complied. There were inevitable cockups (overzealous or careless staff making mistakes etc) but we always acted swiftly to clear these up and keep relevant authorities informed. There were inevitably attempts to hack into our systems. As far as we know these failed but by definition we cannot know if very sophisticated actors succeeded. I have seen no evidence of this. Our security worked better than I assumed it would and the view of the professionals involved was that AWS did a great job.

Overall it is clear that the entire regulatory structure around national elections including data is really bad.

There are so many contradictions, gaps, logical lacunae that it is wide open to abuse.

For example, the Electoral Commission took no action in response to widespread public claims by people on social media that they had voted illegally to stay IN. Their response to us providing photographic evidence (literally of people posting photos of themselves saying 'I've voted illegally to stay IN') was 'there is no evidence'. If we had lost by a small margin, I would have sought to challenge the result as invalid. There has been no proper audit by anybody of how the rules could be exploited by an internal or foreign force to swing close elections. These problems were not fixed for the 2017 election and I doubt they will be imminently.

The system cannot cope with the fast-changing technology.

Much of the regulation was set up by Blair in a rush in 2000 to give him a big advantage in a euro referendum, and this process led to many oddities such as the 'official/deliberate loopholes' left by Blair to allow Sinn Fein to continue raising money in North 3 America. It was altered by Cameron to give the Establishment advantages in the EU referendum. The powers of the EC and you (ICO) are clearly not well-defined because the politicians have not done their jobs properly.

Given the problems and deep confusion among journalists about the law and particularly the EC's decisions on donations, it is unsurprising that there have been claims that we 'cheated' things. The EC allowing donations was weird to say the least. But we at all times sought to stick to what we thought reasonable people would think 'the law' was given the opacity we were faced with. In English law this 'reasonableness' test has always been vital and I am confident we passed it. The EC's response to our claims that the GovernmenUIN were behaving unfairly/illegally was to tell us we could donate to other entities: such peculiarities of a system created by those in power to keep us in the EU can hardly be blamed on us.

Our view during the campaign was that there were serious abuses of the rules by the Government. There are also many unanswered questions about the connections between Lynton Crosby, Jim Messina, who owned what data for the 2015 election, how much of this data was used by Messina in the referendum, and how much of both 2015 election data and 2016 referendum data was used by Crosby and Messina in the 2017 election. Because the Government lost the referendum the media interest has been on Vote Leave but VL involves no such questions of public interest regarding 2015 or 2017 that the relationships between the IN campaign/Crosby/Messina/CCHQ clearly do involve. The media debate, therefore, has been very badly skewed away from real issues towards secondary issues and inventions.

In terms of further questions, it is relevant that none of the current directors of Vote Leave were involved in the data science I digital marketing operations. It would therefore not be fair to expect them to answer detailed questions about them as they are simply not in a position to answer most things. They are of course the right people to answer questions about official policies and also about what the VL structure is doing now before it finally closes.

Best wishes

Dominic Cummings Ex-campaign director of VL

On 17 May 2017 at 17:22, Steve Wood <-;:tcvc. Wood(ajcl1.on;.uJs;·> wrote:

Dominic,

Many thanks for getting in touch. I attach the letter we sent to Matthew (addressed to Victoria).

b.ttps: //iconewsbloo.wordore~s.cor11/2017/05/17/informqtion-commissioner elizabeth-denham-ooens-a-formal-investiaation-into-the-use-of-data-analvtics-for QO 1iUca 1-Qu rposes/

Regards

Steve

4 ------From: Dominic Cummings < Sent: 06 July 2018 11:06 To: Danielle Whalley Subject: attachments to Cummings response Attachments: imageOOl.jpg; vote-leave-memo-inhouse-services.pdf; AIQ - Portobello - UK EU Referendum.pdf

D -- I am replying today. For the moment here are two relevant attachments, context explained in my letter shortly... d

On Tue, 3 Jul 2018 at 11 :01, Danielle Whalley wrote:

Dear Mr Cummings,

I write further to my email dated 19 June.

I would be grateful ifyou would provide an update as to when you will provide us with the information we have requested from you.

I look forward to your reply.

Yours sincerely,

Danielle

Danielle Whalley

Lead Case Officer - Enforcement Department

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

T. 03304146461 F. 01625 524510 jco.t)l"!t.uk twijter.com/iconews

Please consider the environment before printing this email

1 i,euno1a beautifully thought

Project alternatives

Retaining our advisory services in-house.

~0uno1a ~ Vote Leave The timing issue.

The Prime Minister could call the Referendum in June or he could wait until 2017 This causes understandable planning challenges for Vote Leave, as the campaign does not know what the tempo of spending should be for the first half of 2016

Targeting should remain a priority

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A flexible1 iterated solution.

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January to June 2016: Microtargeting essentials

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1. Euroscepticism score This score would predict how like~ the voter would support Leave in the Referendum (i.e. baseline support}

2. Persuadability score This score would predict how like~ an undecided voter would be persuaded by apre-tested Leave message.

3. Turnout propensity score This score would predict how likely the voter will turn out to vote in the Referendum Targeting Phase 02

Summer to Autumn 2016: Advanced psychographics

This is the phase in which we would pilot the project originally 1)n-.pcst'd l\°i V(Tr: Leave. If the Referendum is not called for

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There is a well-researched and empirical basis for this approach, as personali-ty is now recognised as foundational to political behaviour (cf Mondak et al 2070). We1re more than a one-trick pony

We are a versatile team that can support Vote Leave on a range of needs - from creative to focus groups to digital st1<1 l:cgy As the project is underway, we can offer other types of supplemental support beyond microtargeting.

Message development, creative and copywriting

We have run targeted message campaigns in countless national elections in the UI\ USA Canada and elsewhere. We are leading experts in taking a campaign's core messaging and creative output, and creating concepts and creative material for given audiences, whether demographic or psychographic, across all channels.

We have worked on creative for direct mail, television and digital. Familiar with a suite of professional design tools, we can provide Vote Leave with high quality creative concepts and output

Message testing and polling

Although we focus most of our work on individual-level data, we are still very familiar with polling project management and qualitative research methods, such as focus groups and stakeholder in-depth interviews.

Digital support

We are full stack developers with a solid working knowledge of the same front and backend programming languages used by Vote Leave: Nodejs, SQL/NoSQL, HTMLS, CSS3 and JavaScript - as well as some newer JS frameworks such as Angularj.5; Expressjs and 03js that could additionally benefit Vote Leave's online presence.

We are also familiar with MEAN stack applications, RESTful APls and MVC architectures. Beyond development, online and social advertising is our bread and butter and we could support ad placements and management.

Nation Builder

We have used and worked with NationBuilder products for many years and have an excellent working relationship with the company

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Showcasing our work

Client confidentiality is of the utmost importance to us. Any pc:-liI1C,1lly c,1 ··,[1 ,Ht_',islC,Ji[y :,Cl t;i i iv1~ ,I pt-'(I ·. ,-,r 1~:r.11 cn~;d?,t:1 · 11:::'f ii WI Ih vu11 \Viii b,., 1-,"pl: Y:"u,·t I ic)\At\_-v,··1. 11.,,1~ v;,_.1 ii, l 1-':, 111,-".: 1l 1at \Vr· c·w,

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Voter Contact through highly targeted online messaging is a key tool used to enhance Turnout, Persuasion, Inoculation, and Fundraising campaigns. Over the last 5 years, AggregateIQ has managed millions of dollars in targeted online ad spend designed to deliver on specific campaign objectives and KPis. Our engagement strategies leverage the scale and pervasiveness of Social Media Marketing through Facebook and Twitter, while providing additional supporting coverage through highly targeted Search and Display networks. We are device agnostic and identify pools of high-conversion traffic sources where the messaging will have the greatest impact with your existing and perspective supporters.

Through our highly disciplined Microtargeting program, AggregateIQ can develop and deploy a variety of messages designed to resonate with different audience attributes to generate unprecedented levels of engagement. We have a significant and collaborative working history with Mark Gettleson and Portobello Communications and together have delivered highly effective digital ad and social media campaigns and are excited by the prospect of working on the UK's EU Referendum.

We propose to deploy a highly targeted digital messaging campaign for an audience of existing and prospective supporters across email, social media, search, and display ad networks. We can both develop communication materials for all web advertisements and emails and manage the distribution of your digital creative content.

Sample Pricing

Agency Retainer £5,000 per Month* Digital Outreach 5°/o of Gross Monthly Expenditure**

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LOOKALIKES Find more voters that look like your existing supporters

ISSUE ADVOCACY Connect with voters on issues that matter to them

FUNDRAISING Maxi_mize your ROI with cross-channel microtargeting L I

- 800.649.7135 I zack.massingham(q)aggregateiq.com I www.aggregateiq.com (t) AGGREGATEiQ 1 • .,..,,.; Danielle Whalley

From: Danielle Whalley Sent: 10 July 2018 07:11 To: 'Dominic Cummings' < > Subject: correspondence with Dominic Cummings i.e. Vote Leave

Dear Mr Cummings,

Thank you for your below correspondence and for providing the information requested. This has been helpful to our investigations.

It may be that I may need to write to you again with questions in the near future.

Yours sincerely,

Danielle

From: Dominic Cummings [mailto: Sent: 06 July 2018 16:19 To: Danielle Whalley Subject: vote leave

Dear Danielle

Re your letter. Please also refer to my email earlier today with 2 attachments.

I &2.

My whole correspondence with Wylie is on my biog which you have. The only other email with him that I have is me replying to his last email 'Will do, thanks again for the generous time you gave us. D'

I have no further correspondence with Wylie.

BUT I did not post on my biog the 'supplemental memo' referred to. I attached that to my previous email today.

In it Wylie suggests:

'This second phase would be based heavily on integrating psychological and behavioural science into Vote Leave's campaign tactics. We would identify and then model core psychological traits of voters, such as openness to change, risk tolerance, personal identity (self-concept), anxiety proneness, social sensitivity, etc ...

He also offers a 'significant discount' which is 'warranted given the huge potential this project has to make a mark on British politics. We know that in partnering with you, our work will get noticed - making this a prime opportunity to showcase our capabilities in the UK market.'

Wylie also reassures that 'Client confidentiality is ofthe utmost importance to us. Any politically or strategically sensitive aspects of our engagement with you will be kept secret.' l.e Wylie offers a discount to get me to hire him to do exactly what he now claims we secretly did with AIQ, i.e 'psychographic targeting' - which we did NOT do, and he reassures that it will all be 'secret'.

And this guy is supposedly a reliable 'whistleblower' who should be trusted? And of course as you know his claims that VL used the notorious Facebook data were 100% rejected by Facebook itself.

The actual 'pitch' document is exactly as appears on my biog, there is nothing further to it.

3. l don't have any details about Gettleslon's hiring. I don't have any of the documents you want. I don't remember being involved in hiring him though someone probably mentioned it at the time. l ran a very aggressively decentralised operation and many things were not referred to me. In any event he had an extremely minor role. I doubt l could identify his face in a police lineup.

4 Portobello Communications Ltd rings no bells with me and I don't know what they did. If anything, it must have been very minor. l have none of the documents you want. You say VL 'hired' Portobello. Don't you just mean that we hired Gettleston, or that he invoiced us via a company?

I did not discuss with Gettleston our digital marketing with AIQ and as I've already said I don't remember meetings with him at all, other than he attended at least one in 2015 where he brought some American guy who worked for Obama. I did not pursue that either. NB. I had many dozens of such meetings with people pitching me stuff and 99% led to no action. (Private Eye has reported that Gettleston took this Oba ma guy to pitch the REMAIN campaign too, but I've no idea if this report is true.)

Looking at the attachment referred to in (5) below I see the file name is AIQ-Portobello. My inference from looking at emails while trying to answer your letter is that Gettleston, having been rejected by me in his bid with Wylie, came back to us with AIQ. He wanted to be hired to run this project but I had already hired someone to do this. Obviously we hired AIQ. Parkinson hired him briefly to work on some grassroots stuff- not the AIQ project. That seems like a reasonable inference from documents I have but you should speak to Parkinson if you want to confirm this.

It is also relevant that I understand from conversations recently with VL staff that Gettleston only actually worked in VL for about 2 weeks or so and he left before the official referendum campaign started. 1 do not have any documents proving this but VL will have them.

The only email I have matching your description is this which I was forwarded. My understanding now, perhaps false, is that there were at least two different routes by which people inside VL had come across AIQ but I am not sure about this and have not tried to ascertain the truth as it does not seem important to any of the inquiries.

NB. Gettleston did not manage this project, as he requested.

The document referred to was attached to my previous email today. NB. that 'microtargeting' is confusingly used in this debate. In any event it is relevant that I have said repeatedly we did not really do microtargeting as I understand the term because the market research did not suggest it was necessary or efficient for us.

From: Mark Gettleson <11••••••••• Date: 7 March 2016 at 14:03:20 GMT To: Stephen Parkinson <•••••••••••••• Subject: Digital advertising

Hi Stephen,

··T-ake a look anhe attached. See If It might suit VL's neMs.

The key point is needing people with huge experience in placing the right adverts in front of the right people at the right time whether that's through Facebook, Twitter and Google or display networks.

I consider AIQ among the best in the world for doing that. Between us, they're who Ted Cruz is using for their very very clever stuff.

I am very happy to manage this relationship and this programme, as I have done before. The key thing good digital advertising requires is a significant increase in the content you're pushing out - to see which people are clicking through to which content and optimising that.

Best wishes,

Mark

This is a huge question. I answered it to you as well as I could last year. My memory then was better than it is now. Ifyou want to know the details of this you should speak to VL as they have access to the documents and I don't.

Your question has missing words so I cannot answer it properly: 'Did AIQ allow Vote Leave, or any ofits representatives, to , have access or knowledge ofthe work they did on behalf of Bel eave or Veterans for Britain?'

Trying to guess what your question means ... I did not coordinate anything viz AIQ/BeLeave/VfB. Sanni's allegations are false. I will give evidence to this effect under oath if necessary. To the best of my knowledge, everybody at VL behaved legally and ethically. My discussions since Wylie et al went public have made me even more confident about this. As you know, many of their claims are provably false. In particular, the claim about Woodcock deleting files - as VL has made clear, that GIF could not have been her because she had been removed from the system. She is the victim of many false accusations and always behaved legally. Further, she was very tough on staff and the Board in insisting on proper processes to minimise the chances of accidental breaking of the rules.

NB. Over 99% of my discussions about 13eLeave have occurred in the last few months. It was essentially irrelevant to me apart from a brief window between c.6-15 June 2016 when I was involved in discussions over the legality of donations.

8 2 l was unaware of this cockup until it was recently revealed in Canada. l do not know anything about it. As far as 1 understand from what AIQ has said publicly, they spotted this error and the audiences were not used. You must speak to them about this.

I have already referred to a document that appears to be a pitch from AIQ. It was attached to my previous email (Gettleston, 7 March).

My memory is that this was just a preliminary document and that there was another fuller document sent shortly afterwards but my memory may be false. I cannot find any such document. VL may have it.

10.

I had a vague idea that some developers used Github. I'd not heard ofGitlab until very recently. I do not know what it is or whether we used it. I do not know what if anything we shared with AIQ using either. IfI ever knew I've forgotten.

Our electoral database was on A WS and we had extensive meetings with A WS to discuss security arrangements.

Your comment about 'authority' is not right. I have no authority to acquire VL documents. VL directors have refused requests, as is their right, by me to look at/access VL documents. For example, they have not provided me with a copy of the EC's provisional report. This is not a complaint by me about them - it is just a description of the facts. They are under intense pressure from multiple inquiries two years after the vote, they are struggling to find resources to answer the growing list of demands etc. I can see why they are not handing out documents and are focused on trying to deal with the authorities rather than former staff. You must speak to them about further documents you seek. Also please note that I ceased to be a director of VL in early 2016.

Please let me know if I can help further.

Best wishes

3 Danielle Whalley

From: Danielle Whalley Sent: 15 August 2018 13:56 To: 'Dominic Cummings' < Cc: Stephen Flack Subject: email to Cummings for interview dates and copy of the undertaking Attachments: DPA Undertaking - NOM2 Dominic CUMMINGS.DOC

Dear Mr Cummings,

My apologies for the delay in getting back to your email dated 8 August regarding your availability for an interview. Please provide dates and times in September that you are available to be interviewed.

I also attach an undertaking for your attention. Whilst it can be agreed that you can record the interview and a copy of the transcript will be provided to you, we would be grateful that you would agree not to publish any recording or transcript until you are advised in writing by the ICO that our investigations have ceased, and there are no longer concerns that publication may compromise the Commissioners investigations.

Kind regards

Danielle

• Danielle Whalley ICO. Lead Case Officer -Enforcement Department Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF T. 03304146461 F. 01625 524510 it:<1.on:.uk twitter.com/iconews Please consider the environment before printing this email

1 Danielle Whalley

From: Dominic Cummings < Sent: 08 August 2018 12:03 To: Danielle Whalley Subject: email from Dominic Cummings - he will be interviewed Attachments: imageOOl.jpg

Hello. Yes I'm happy to be interviewed on condition that a) I can also record my own interview and b) you will make your recording and transcript available to me. I am out of London until September and intermittently abroad. Best wishes D

On Thu, 2 Aug 2018 at 15:17, Danielle Whalley wrote:

Dear Mr Cummings,

Please see the attached correspondence for your attention.

Kind regards,

Danielle

L:_J Danielle Whalley

Lead Case Officer - Enforcement Department

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

T. 03304146461 F. 01625 524510 ico.c1rg.uk .lY".'i!lcr._!-·n_111~ict1ncws

Please consider the environment before printing this email