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, this could include (but not limited to) a person’s name, email address, number, postal address or any photographs and videos of the individual. 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).
WHO ARE WE?
The PCC of All Hallows Bow is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes. In the rest of this Privacy Notice, we use the word ‘we’, ‘us’ or ‘our’ to refer to the data controller, as appropriate.
HOW DO WE PROCESS YOUR PERSONAL DATA?
The PCC of All Hallows Bow complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for 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 (including, but not limited to, visiting you when you are ill, bereaved, need emotional or spiritual support) 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;
– To administer the parish, deanery, archdeaconry and diocesan membership records;
– To maintain our own accounts and records;
– To process a donation that you have made (including, but not limited to, Gift Aid information);
– To manage our employees, contractors and volunteers;
– To manage our events, services, courses and activities;
– To seek your views or comments;
– To notify you of changes to our services, courses, events and role holders;
– To inform you of news, events, activities, fundraisers, and services running at All Hallows Bow, the local community or within the diocese;
– 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;
– To operate and manage our website.
WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
Most of our data is processed because it is necessary for our legitimate interests. For example, if a new person enquires about getting involved on a Sunday, we might use the relevant information they have provided us, in order to send them further details about how to get involved, rota requests and to be able to contact them about the service if required. 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, for safeguarding, or 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.
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. We will not share your sensitive personal data publically without your consent.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
We may use a range of different third party providers acting as processors in order to store our data securely and provide website, social media, media and IT and system administration services. These processors include:
– Databases include: Planning Centre Online*, ChurchSuite**, G Suite*, OneDrive*.
– Course and event management systems including Eventbrite*.
– Electronic marketing and research services such as Mailchimp*, SurveyMonkey* and WhatsApp***.
– Social Media platforms including Facebook*, Twitter*, Instagram*.
– Professional advisers including lawyers, bankers, auditors, pension advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
*MailChimp, SurveyMonkey, Eventbrite, Planning Centre Online, G-Suite, OneDrive, Facebook Inc. (includes Instagram and WhatsApp) and Twitter are US based companies and are certified under Privacy Shield. All of these companies, although based in the US have also taken measures to become compliant with GDPR requirements.
Please refer to:
***The team at AHB have put into place WhatsApp guidelines to ensure every official AHB WhatsApp group or broadcast meets GDPR requirements. You can read these guidelines here.
SHARING YOUR PERSONAL DATA
Your personal data will be treated as strictly confidential and will only be shared with other members of the church in order to carry out a service to other church members, or for purposes connected with the church. We will only share your data with third parties outside of the parish with your consent.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will keep some records permanently if we are legally required to do so (baptisms, marriages, funerals). 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 6 years after the calendar year to which they relate, 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.
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.
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.
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 for regulatory and legal purpose(s)).
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.
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.
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).
The right to object to the processing of personal data where applicable.
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.
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.
We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL at firstname.lastname@example.org or writing to:
The Data Lead, All Hallows Bow, 302 The Highway, London, E1W 3DH.
You can contact the Information Commissioner’s Office on 0303 123 1113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.