THE PARISH OF ST DUNSTAN’S WITH HOLY ANGELS CRANFORD
GENERAL
PRIVACY NOTICE
Your personal data – what is it?
“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 Data Protection Bill/Act 2017 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].
Who are we?
This
Privacy Notice is provided to you by the Parochial Church Council (PCC) of the parish of St
Dunstan with Holy Angels Cranford which is the data controller for your data.
The
Church of England is made up of a number of different organisations and
office-holders who work together to deliver the Church’s mission in each
community. The PCC works together with:
·
the incumbent of the parish (that is, our Rector]);
·
the bishops of the Diocese of London; and
·
the London Diocesan Fund, which is responsible for the financial
and administrative arrangements for the Diocese of London.
As
the Church is made up of all of these persons and organisations working
together, we may need to share personal data we hold with them so that they can
carry out their responsibilities to the Church and our community. The organisations referred to above are joint
data controllers. This means we are all responsible
to you for how we process your data.
Each
of the data controllers have their own tasks within the Church and a
description of what data is processed and for what purpose is set out in this
Privacy Notice. This Privacy Notice is
sent to you by the PCC on our own behalf and on behalf of each of these data
controllers. In the rest of this Privacy
Notice, we use the word “we” to refer to each data controller, as appropriate.
What data do the data controllers listed
above process? They will process some or all of the
following where necessary to perform their tasks:
·
Names, titles, and aliases, photographs;
·
Contact details such as telephone numbers, 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, hobbies, 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, payment/transaction identifiers, policy numbers, and claim numbers;
·
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: racial or ethnic
origin, sex life, mental and physical health, details of injuries,
medication/treatment received, political beliefs, labour union affiliation,
genetic data, biometric data, data concerning sexual orientation and criminal
records, fines and other similar judicial records.
How do we process your personal data?
The
data controllers will comply with their legal obligations 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 carry out comprehensive safeguarding procedures (including due
diligence and complaints handling) in accordance with best safeguarding
practice from time to time with the aim of ensuring that all children and
adults-at-risk are provided with safe environments;
·
To minister to you and provide you with pastoral and spiritual
care (such as visiting you when you are gravely ill or bereaved) and to organise and perform ecclesiastical
services for you, such as baptisms, confirmations, weddings and funerals;
·
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 the constitution and statutory framework of each data
controller;
·
To administer the parish, deanery, archdeaconry and diocesan
membership records;
·
To fundraise and promote the interests of the Church and charity;
·
To maintain our own accounts and records;
·
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.
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. We will always take into account your
interests, rights and freedoms.
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.
Where
your information is used other than in accordance with one of these legal
bases, we will first obtain your consent to that use.
Sharing your 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 likely 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 including the
other data controllers;
·
Our agents, servants and contractors. For example, we may ask a
commercial provider to send out newsletters on our behalf, or to maintain our
database software;
·
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 including, where relevant, the London Diocesan Board for Schools and
Subsidiary Bodies;
·
On occasion, other churches with which we are carrying out joint
events or activities.
How long do we keep your 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.
Your rights and your personal data
You
have the following rights with respect to your personal data:
When
exercising any of the rights listed below, in order to process your request, we
may need to verify your identity for your security. In such cases we will need you to respond
with proof of your identity before you can exercise these rights.
1.
The right to access information we hold on you
·
At any point you can contact us to request the information we hold
on you as well as why we have that information, who has access to the
information and where we obtained the information from. Once we have received your request we will
respond within one month.
·
There are no fees or charges for the first request but additional
requests for the same data may be subject to an administrative fee .
2.
The right to correct and update the information we hold on you
·
If the data we hold on you is out of date, incomplete or
incorrect, you can inform us and your data will be updated.
3.
The right to have your information erased
·
If you feel that we should no longer be using your data or that we
are illegally using your data, you can request that we erase the data we hold.
·
When we receive your request we will confirm whether the data has
been deleted or the reason why it cannot be deleted (for example because we
need it for our legitimate interests or regulatory purpose(s)).
4.
The right to object to processing of your data
·
You have the right to request that we stop processing your data.
Upon receiving the request we will contact you and let you know if we are able
to comply or if we have legitimate grounds to continue to process your
data. Even after you exercise your right
to object, we may continue to hold your data to comply with your other rights
or to bring or defend legal claims.
5.
The right to data portability
·
You have the right to request that we transfer some of your data
to another controller. We will comply with your request, where it is feasible
to do so, within one month of receiving your request.
6.
The right to withdraw your consent to the processing at any time
for any processing of data to which consent was sought.
·
You can withdraw your consent easily by telephone, email, or by
post (see Contact Details below).
7.
The right to object to the processing of personal data where
applicable.
8.
The right to lodge a complaint with the Information Commissioner’s
Office.
Transfer of Data Abroad
Any
electronic personal data transferred to countries or territories outside the EU
will only be placed on systems complying with measures giving equivalent
protection of personal rights either through international agreements or
contracts approved by the European Union. Our website is also accessible from overseas
so on occasion some personal data (for example in a newsletter) may be accessed
from overseas.
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.
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:
The
Data Controller, Father Michael Gill SSC, Rector.
Email: fathermichaelgill@gmail.com
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.
