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 District Church Council (DCC) of All Saints Whitstable
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 DCC works together with:
·
The
PCC and the incumbent of the parish (that is, our Team vicar and team rector);
·
the
bishops of the Diocese of Canterbury; and
·
the Diocesan Offices (including
the offices of the Archdeacons), which are responsible for the financial and
administrative arrangements for the Diocese of Canterbury.
As the Church
is made up of all 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 has 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 given to you by the DCC 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 types of data, 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
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 (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 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;
What is the legal basis for processing
your personal data?
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 possible that we will need to share
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 Canterbury
to support the mission of the Church in our parish. For example, our clergy are
supported by our area dean, lay chair 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 Canterbury including
but not limited to, where relevant, the Canterbury Diocesan Enterprises Ltd and
Aquila (the Diocese of Canterbury Academies Trust).
·
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
When exercising
any of the rights listed below, 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.
You have the
following rights with respect to your personal data:
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 for 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, Malcolm Waller
Email: Malcolm.waller@outlook.com
Tel, 01227 275947 (Church Office)
We keep this Privacy Notice under
regular review and we will place a copy and any updates on http://www.allsaintswhitstable.com/
This Notice was last updated in May
2018.
You can contact the Information Commissioners
Office on 0303 123 1113, via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF.
What is the lawful basis for processing your personal data?
Contact Details
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.
ELECTORAL ROLL PRIVACY NOTICE
Who are we?
All Saints
Church, Whitstable is the data controller (contact details below). This means it decides how your personal data
is processed and for what purposes.
Why do we process your personal data?
We use the
personal data you provide on the electoral roll application form to enable us
to manage, maintain and publish the electoral roll in accordance with Church
Representation Rules (CRR) to:
· determine
eligibility for attendance and participation at the Annual Parochial Church
Meeting and for election to the Parochial Church Council deanery, diocesan and
general synods where applicable;
· calculate
the number of representatives who may be elected to each of these synods in the
following year;
· undertake
a review and revision of the electoral roll as necessary; and
· publish
your name and address, by exhibiting the roll in the parish church or the
church website.
What is the lawful basis for processing your personal data?
1.
Processing for the
purpose of determining eligibility, creating the electoral roll and use of the
roll to calculate numbers for election to synod is necessary for compliance
with a legal obligation. The processing is a
statutory requirement imposed by the Church Representation Rules, which means
that you must give us this information if you want to be included on the
electoral roll.
2. Processing for the purpose of determining
eligibility and creating or revising the electoral roll is carried out in the course of our legitimate activities, as
this relates solely to members the Church of England in connection with its
purposes.
3.
Processing for the
purpose of publishing the electoral roll relates to personal data which are
manifestly made public by the data subject.
When you apply to have your name added to the church electoral roll, the
automatic legal consequence as stated in the CRR, (Part I Formation of the Roll
1(8) and Revision of Roll and Preparation of New Roll 2(1), 2(3) and 2(7)) is
that your name and address will be published, and by submitting your
application form you are making that data public.
Sharing your personal data
Your
personal data will be shared within the institutional Church of England and with
the general public.
How long do we keep your personal data?
We keep your personal
data for 6 years after a complete review of the electoral roll.
Your rights and your personal data
Unless
subject to an exemption 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 be erased where it is no longer necessary
for us to retain such data;
· The
right, where there is a dispute in relation to the accuracy or processing of
your personal data, to request that a restriction is placed on further
processing;
· The
right to object to the processing of your personal data for direct marketing
and to have that processing stopped;
·
The right to lodge a complaint with
the Information Commissioners Office.
Contact Details
For All Saints - Malcolm Waller (malcolm.waller@outlook.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.
