Readers will recall that in the Autumn, the Prime Minister and the Party Board wisely agreed that the Conservative Party – its organisation, infrastructure and money at every level – would remain neutral in the away referendum campaign.

It was the right decision for a Party whose ministers, MPs, donors and members are divided on the question.

But there are concerns that some may not be abiding by it. On his blog, ConservativeHome columnist Andrew Kennedy reports a troubling incident in which he received a heavily pro-EU email from a little-known organisation called the South East Conservatives Europe Network.

On closer inspection, he discovered that SECEN is registered to the office of a Conservative Association – Beaconsfield Conservative Association, to be precise. Its website is registered from the same address, and it is also registered there with the Information Commissioner’s Office for the purposes of data protection.

If SECEN was an arm of that Association – and/or using any of its resources such as its office space, computers or staff time – then sending out such emails would be a pretty clear breach of the Party’s agreed neutrality policy.

However, Philip Dumville, the Beaconsfield Conservative Agent (who works with both BCA and SECEN) tells me they are separate organisations, and that SECEN is not part of the Conservative Party. His argument regarding the shared address is that SECEN has only “a virtual presence”. It’s fair to say it isn’t entirely clear quite how separate the “virtual” SECEN really can be from the Association when its legal registration is to the Association’s own office.

Kennedy has another awkward question for the organisation: where did they get his email address? He says he has never registered to receive communications from SECEN, and the email address they contacted him on is not publicly available. He reports that other Conservatives in the South East have the same concern. If any of these email addresses were obtained from other organisations – the Conservative Party centrally, Conservative Associations or another third party – that would constitute a breach of data protection. Dumville tells me the source of the email address is a “mystery” he hopes to clear up with Kennedy, and further assures ConservativeHome that SECEN only uses email addresses gathered either when people sign up to its online form or by filling out a survey carried out by SECEN on behalf of Richard Ashworth MEP or James Elles (the former MEP who is currently SECEN’s Chairman).

This is a problematic explanation, though. For a start, Kennedy writes that he had “never heard” of the organisation until he received their email this week and certainly never registered with it. Furthermore, had he filled out a survey carried out by SECEN on behalf of a Conservative MEP (which he does not believe he has), he contends that this would have been data gathered clearly for the purposes of re-electing that MEP, not for the purpose of campaigning in an EU referendum.

All this suggests a rather tangled thicket. SECEN is a Conservative-supporting organisation, which is run with the involvement of a previous and a current Conservative MEP in order to “assist secure [sic] the return of Conservative Members to serve in the European Parliament.” It is registered to the office of a Conservative Association, the Agent of which Association is also involved in its running to some degree. It also gathers data by running surveys on behalf of a Conservative MEP. However, it claims to be a non-Party organisation, using no Party resources, which exists only “virtually”. The mystery of quite how it did get hold of the email address of Kennedy and others is at present unresolved, but is equally contentious.

The question therefore must be asked: it’s all very well having a neutrality policy, which most of the Conservative Party is honourably sticking to, but how is it being safeguarded? When a breach is alleged, and technicalities come into dispute, whose job is it to investigate, and what are the penalties if a breach is found to have occurred?