GENERAL PRIVACY NOTICE

(NON-ROLE HOLDERS)

Your 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 St Anne and All Saints, which is the data controller for your data.

The Church of England comprises several different organisations and office-holders who work together to deliver the Church’s mission in each community.  The PCC works together with the following:

• the incumbent of the parish (that is, our vicar);
• the bishops of the Diocese of Southwark; and
• the Diocese of Southwark, which is responsible for the financial and administrative arrangements for the Diocese of Southwark.

As the Church comprises 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 data controller has its 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 behalf and 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, 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 the 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 may suggest your religious beliefs.  In addition, 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 data?

The data controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; do not to 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 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 by the Church Representation Rules);
• To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) by best safeguarding practice from time to time to ensure 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 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 you have requested and may interest you.  These may include information about campaigns, appeals, and 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.

What is the legal basis for processing your 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 through banns.

We may also process data if necessary for the performance of a contract with you or to take steps to enter into a contract.  An example would be processing your data concerning the hiring of church facilities.

Religious organisations can also process information about your beliefs to administer membership or contact details.

We will first get your consent if your information is used other than by one of these legal bases.

Sharing your data

Your data will be treated as strictly confidential.  It will only be shared with third parties where it is necessary to perform our tasks or where you first give us your prior consent.  We will likely 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 Diocese of Southwark bishops to support the Church's mission 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 Southwark, including, where relevant, the Southwark Diocesan Board of Education, Southwark Cathedral and Subsidiary Bodies; there may be other legal entities we share data with within the Church of England who are also data controllers;

On occasion, other churches with which we carry out joint events or activities.

How long do we keep your data?

We will keep some records permanently if legally required to do so. In addition, we may keep some other records for an extended period. For example, keeping financial records for at least seven years is best for supporting HMRC audits.  However, we will generally endeavour to keep data only for as long as needed.  This means that we may delete it when it is no longer needed.

Your rights and your data 

You have the following rights concerning 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 require you to respond with proof of your identity before exercising these rights.

1. The right to access the information we hold on you
   • At any point, you can request the information we hold on you, 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 outdated, 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 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 the 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 can comply or have legitimate grounds to continue processing 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, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time for any data processing to which consent was sought.
   • You can withdraw your consent easily by telephone, email, or post (see Contact Details below).
7. The right to object to the processing of personal data where applicable.
8. The right to complain to the Information Commissioner’s Office.

Transfer of Data Abroad

Any electronic personal data transferred to countries or territories outside the EEA will only be placed on systems complying with measures giving equivalent protection of individual rights through international agreements or contracts approved by the European Union.  Our website is also accessible from overseas, so some personal data (for example, in a newsletter) may be accessed from overseas.

Changes to this notice

We keep this Privacy Notice under regular review and will place any updates on www.stanneandallsaints.org.uk.

This notice was last updated in June 2018.

Further processing

If we want to use your data for a new purpose, this Notice does not cover us. In that case, we will provide a further notice explaining this new use before proceeding and setting out the relevant purposes and processing conditions.  We will seek your consent to the new processing where and whenever necessary.

Contact Details

Please get in touch with 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: St Anne and All Saints PCC, c/o Revd Fraser Dyer, 179 Fentiman Road, London SW8 1JY

Email: revdfraserdyer [at] gmail.com  

You can contact the Information Commissioners' Office on 0303 123 1113 or via email at https://ico.org.uk/global/contact-us/email/ or the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Photo: Cristina Gottardi on Unsplash