Data Policies and Consent
DATA PRIVACY NOTICE
1. Your Personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”). The term “data subject” refers to the person about whom data is held and/or processed.
2. Who are we?
Whilst we are a United Benefice, and hold much of our data in common, we are still five distinct parishes in law, and so each of the PCCs of each of our parishes, and our Vicars, are all data controllers. This means they decide how your personal data is processed and for what purposes.
3. How do we process your personal data?
The PCCs and the Vicars comply with their obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes: -
- To provide pastoral care;
- To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
- To administer parish records and electoral rolls;
- To fundraise and promote the interests of the parishes;
- To manage our employees and volunteers (including making and publicising rotas);;
- To maintain our own accounts and records (including the processing of gift aid applications);
- To publicise news, events, activities and services which may be of interest;
- To ensure good safeguarding practise for the protection of all users of our churches.
We process and store most of our data using a company called Churchdesk ApS (www.churchdesk.com), under the conditions of our Data Processing Agreement with them.
Data may also be kept in paper records locally, e.g. Vicar(s) may keep some relevant pastoral data securely in their office or study; records kept for safeguarding purposes are stored and processed on paper locally and securely.
4. What is the legal basis for processing your personal data?
Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations. We differentiate a number of types of consent, which are detailed below.
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract, e.g. weddings and funerals.
- Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
- Processing is necessary for compliance with a legal obligation - e.g. the statutory requirement to make quarterly marriage returns;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
- Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided:-
- the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
- there is no disclosure to a third party without consent.
- Processing relates to personal data manifestly made public by the data subject;
- Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes.
5. What types of Consent do we seek and hold?
- Communications Consent for Internal Events - to receive communications from us about news, events, activities, and services (including paid and fundraising events) organised by, or for, our Churches, Deanery, or Diocese.
- by email
- by phone
- by post
- Communications Consent for External Events - to receive communications from us about news, events, activities, and services (including paid and fundraising events) organised by third parties that may be of interest to members of our churches. For example, charities, schools, or other churches running events locally.
- by email
- by phone
- by post
- 0-18s Consent - consent given by those with parental responsibility for us to hold and process a child’s personal information.
6. Sharing your personal data
Volunteer rotas which may contain names and contact information may be displayed publicly within our churches. If you do not want your contact information to appear in this way, please let us know and we will remove it.
Some volunteer and trustee roles require a DBS check to be carried out. In these instances your data will be shared with The Disclosure and Barring Service for the purpose of carrying out the relevant check.
In other cases, your personal data will be treated as strictly confidential and will only be shared with other members of the church(es) in order to carry out a service to other church members or for purposes connected with the church(es). We will only share your data with third parties outside of the parish with your consent.
7. How long do we keep your personal data?
We keep data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available from the Church of England website [see footnote for link].
Specifically, we retain electoral roll data while it is still current and for six years thereafter; gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate; and parish registers (baptisms, marriages, funerals) permanently.
8. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -
The right to request a copy of your personal data which any of our PCCS or the Vicars holds about you;
The right to request that the PCCs or Vicars correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for the PCCs or Vicars to retain such data;
The right to withdraw your consent to the processing at any time
The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means];
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics];
The right to lodge a complaint with the Information Commissioners Office.
9. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
10. Online Data Collection and Cookies
Information may be collected automatically during use of our online forms, or website. This data can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
‘Cookie’ consent is sought upon a first visit to the website.
11. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact us through the form here. You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.