The Data Protection Regulation – Privacy statement updated
We do have a legal obligation to keep registers of baptisms, marriages and funerals, but for anything else, specific consent is required. In accordance with the General Data Protection Regulation (GDPR) we have to display our joint PCC Privacy statement which identifies the key criteria in the spirit of transparency. It explains how and why we keep information and also points out your rights under the legislation. It is important that you read this please.
For any further questions please contact Mrs Gill Cowley, the Church Data Controller/ Church Secretary on 0121 423 3822 or by email to
DATA PRIVACY NOTICE
1. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
2. Who are we?
The main Church records are held jointly by the Church Secretary, Gill Cowley (as data controller) who decide how your personal data is processed and for what purposes and _________________________(as data processor).
3. How do we process your personal data?
Gill Cowley (as data controller), and _____________________________(as data processor) must comply with their 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 provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
• To administer membership records;
• To fundraise and promote the interests of the Church;
• To manage our employees and volunteers;
• To maintain our own accounts and records (including the processing of gift aid applications);
• To inform you of news, events, activities and services running at the church;
4. What is the legal basis for processing your personal data?
• Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations and keep you informed about events
• Legal obligation in regard to Church records of Birth, Marriage and Death.
• Legitimate interest insofar as safeguarding issues may need to be disclosed if and when necessary.
• Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
• Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided: –
o the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
o there is no disclosure to a third party without consent (except in a medical emergency or in an issue relating to safeguarding or legal process). ** Please also see note below.
5. 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. Please see exceptions as described in clause 4 above.
6. How long do we keep your personal data
We keep data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Records” which is available from the Church of England website [see footnote for link].
Specifically, we retain electoral roll data while it is still current; gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate; and parish registers (baptisms, marriages, funerals) permanently.
7. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
• The right to be informed and to request a copy of your personal data.
• The right to request correction of any personal data if it is found to be factually inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time
• The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
• The right to lodge a complaint with the Information Commissioners Office.
8. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection 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.
** In the event of a law enforcement request for information, the release of your data, without your prior consent, may be made, but only if the withholding of said information would prejudice the criminal investigation.
9. Contact Details
To exercise all relevant rights, raise queries or complaints, please, in the first instance, contact the Church Secretary Gill Cowley (The Church Administrator/Data Controller) on 0121 423 3822; or the Data Processor on ________________________________.
You can contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
Transparency is a fundamental part of the GDPR and the Data Protection Act, in that data must be processed lawfully, and fairly, as expressed in article 8 of the Charter of Fundamental Rights of the European Union.