PRIVACY
NOTICE
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 Parochial Church Council (PCC) of St Peter
Tunbridge Wells, 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 vicar Mike Warren);
·
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.
Changes to this notice
We keep this Privacy Notice under
regular review and we will place any updates on this web page This Notice was last updated in September 2020.
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 Peter’s Church Office, St Peter’s
Street, Tunbridge Wells, Kent TN2 4UX
Email: office@stpeterstw.com
You can contact the Information Commissioners
Office on 0303 123 1113 or via email (href=https://ico.org.uk/global/contact-us/email/)https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF.