GENERAL
PRIVACY NOTICE
Your personal data – what is it?
Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of
Wrotham 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 Rochester; and
·
the
Diocesan Office,
which is responsible for the financial and administrative arrangements for the
Diocese of Rochester.
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 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 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.
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
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 Rochester 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 Rochester
including, where relevant, the Rochester Diocesan Board of Education;
·
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, St. Georges Church, The Rectory, Borough Green Road,
Wrotham TN15 7RA
Email: rector@wrothamchurch.org
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.