1 INTRODUCTION
This Data Privacy Policy sets out the responsibilities of the Parochial Church Council (PCC) of St Mary’s Church, Sunbury-on-Thames as Data Controller for personal information held by the Church, its employees and volunteers (referred to as “we”). It also set out the rights of individuals (referred to as “you”) whose data is being held or processed.
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
2 SCOPE OF PERSONAL DATA
The PCC as Data Controller will process some or all of the following where necessary to perform its tasks:
• Names, titles and photographs;
• Contact details such as telephone numbers, postal addresses, and email addresses;
• Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education / work histories, academic / professional qualifications, family composition, and dependants;
• Where you make donations or pay for activities such as use of a church hall, financial identifiers such as bank account numbers, payment card numbers and payment / transaction identifiers;
• The data we process is likely to constitute sensitive personal data because, as a church, the fact that we process your data at all may be suggestive of your religious beliefs. Where you provide this information, we may also process other categories of sensitive personal data such as racial or ethnic origin, mental and physical health, medication details and details required for employment or criminal records checks.
3 USE OF PERSONAL DATA
We will comply with the legal obligations under the GDPR to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
• To deliver the Church’s mission to our community, and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in our constitution and statutory framework;
• To minister to you and provide you with pastoral and spiritual care and to organise and perform ecclesiastical services for you, such as baptisms, confirmations, weddings and funerals;
• To enable us to meet all legal and statutory obligations (which include maintaining and publishing our electoral roll in accordance with the Church Representation Rules);
• To carry out comprehensive safeguarding procedures in accordance with best safeguarding practice with the aim of ensuring that all children and adults-at-risk are provided with safe environments;
• To administer the parish membership records;
• To maintain our own accounts and records;
• To fundraise and promote the interests of the Church and charity;
• To process a donation that you have made (including Gift Aid information);
• To seek your views or comments;
• To notify you of changes to our services, events and role holders;
• To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities;
• To process a grant or application for a role;
• To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
• Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
4 LEGAL BASIS FOR DATA PROCESSING
We will obtain your explicit consent to hold your personal data and use it only for the purpose(s) for which you have agreed.
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as another organisation in the Church of England). An example of this would be our safeguarding work to protect children and adults-at-risk. Some of our processing is necessary for compliance with a legal obligation. For example, we are required by the Church Representation Rules to administer and publish the electoral roll, and under Canon Law to announce forthcoming weddings by means of the publication of banns.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the hire of church facilities.
Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.
5 SHARING OF PERSONAL DATA
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is possible that we will need to share your data with some or all of the following (but only where necessary):
• The appropriate bodies of the Church of England;
• Other clergy or lay persons nominated or licensed by the bishops of the Diocese of London to support the mission of the Church in our parish. For example, our clergy are supported by our area dean and archdeacon, who may provide confidential mentoring and pastoral support. Assistant or temporary ministers, including curates, deacons, licensed lay ministers, commissioned lay ministers or persons with Bishop’s Permissions may participate in our mission in support of our regular clergy;
• Other persons or organisations operating within the Diocese of London;
• On occasion, other churches with which we are carrying out joint events or activities.
6 RETENTION OF PERSONAL DATA
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
7 RIGHTS TO 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 we hold about you;
• The right to request that we 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 us to retain such data;
• The right to withdraw your consent to the processing at any time
• 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 lodge a complaint with the Information Commissioners Office.
8 FURTHER PROCESSING
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new 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.
9 CONTACT DETAILS
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
Address: Parish Office, Green Street, Sunbury-on-Thames TW16 6RN
Telephone: 01932 785448
Email: [email protected]
You can contact the Information Commissioners Office at:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113
Email: https://ico.org.uk/global/contact-us/email/