General Data Protection Regulation

Diocese of London Deanery of Harrow

S^t Andrew's Church, Roxbourne

Malvern Avenue, Harrow

www.standrewsroxbourne.org.uk

Registered Charity N^o 1131727

Privacy Notice

Note that text labelled with an asterisk (*) only applies to Role Holders, and text labelled (†) applies specifically to non-role-holders. These are people who are either paid by St Andrew’s PCC on a regular basis (for example, the Parish Secretary, Organist, Caretakers or Vergers) or whose work in voluntary capacity for PCC makes it necessary for the PCC to hold some of their personal data, or whose role in turn requires them to hold data on others (for example, they may hold data on members of the congregation who are on a rota, or contractors)

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 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 Andrew’s, Roxbourne, 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 Reverend Lyndon North);
the bishops of the Diocese of London; and
the London Diocesan Fund, which is responsible for he financial and administrative arrangement for the Diocese of London.

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 has 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 compiles 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.

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 (*for example some of the role-holders are volunteers and no financial information will be processed for these role-holders):-

*to enable those who undertake pastoral care duties to do so as appropriate (e.g. visiting the bereaved);
†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 enable us to meet all 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 of abuse and neglect are provided with safe environments;
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 manage employees and volunteers;
to maintain our own accounts and records;
†to process a donation you have made (including Gift Aid information)
to seek your view 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, and other fundraising activities;
to process a grant application 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 share your details with the Diocesan Office so they can keep you informed about news in the diocese, and events, activities, and services that will be occurring in the diocese and in which you may be interested.
*We will process data about role-holders for legal, personnel, administrative and management purposes and to enable us to meet our legal obligations, .for example to pay role-holders, monitor their performance and to confer benefits in connection with you engagement as a Role-holder. “Role-holders” includes volunteers, employees, contractors, agents, staff, retirees, temporary employees, beneficiaries, workers, treasurers and other role-holders.
*We may process sensitive data relating to role-holders including, as appropriate: information about a role-holder’s physical or mental health or condition in order to monitor sick leave and take decisions as to the role-holder’s fitness for work; the role-holder’s racial or ethnic origin or religious or other similar information in order to monitor compliance with equal opportunities legislation; in order to comply with legal requirements and obligations to third parties.
Our processing does not currently include the use of CCTV but may do in future, though there are currently no plans for this.

What data do the data controllers listed above process?

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, employment details, hobbies, family composition and dependents.
*Non-financial identifiers such as passport numbers, driving licence numbers, vehicle registration numbers, taxpayer identification numbers, employee identification numbers, tax reference codes and national insurance numbers
†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;
*Other operational personal data created, obtained, or otherwise processed in the course of carrying out our activities, including but not limited to, CCTV footage, recording of telephone conversations, IP addresses and website visit histories, logs of visitors and logs of accidents, injuries and insurance claims.
*Other employee data (not covered above) relating to role-holders, including emergency contact information, gender, birth date referral source (e.g. agency, employee referral); level, performance management information, languages and proficiency; licences and certificates, citizenship, immigrations status, employment status, retirement date, billing rates, office location, practice and speciality; publication and awards for articles, books etc.; prior job history, employment references and personal biographies.
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, for example praying for you if you are sick or celebrating birthdays or anniversaries, or the outcome of DBS checks if your role requires this.

What is the legal basis for processing your personal data?

Most data is processed because it is necessary for our legitimate interests, or in 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 of abuse and neglect. 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. *The Charity Commission requires us to send to them details of members of the PCC, because all PCC members are trustees of the Charity.

We may also process your data if it is necessary for the performance of a contract with you or to take steps to enter into contract. An example of this would be processing your data in connection with hire of church facilities (including renting the church flat).

*We will also process your data in order to assist you in fulfilling your role in the church including pastoral and administrative support, or if processing is necessary for compliance with a legal obligation.

Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.

Where you information is used other than in accordance with one of these legal bases, we will first of all 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 (*including other data controllers) where it is necessary for the performance of the data controller’s 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 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 (though we have no plans to do this at present);
other clergy or lay persons nominated or licensed by the Bishops of the Diocese of London 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 person with Bishop’s Permissions may participate in our mission in support of our regular clergy;
other persons or organisations operating within the Diocese of London including, where relevant, the London Diocesan Board for Schools and Subsidiary Bodies.
†On occasions, 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 extended periods 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 we may delete it when it is no longer required.

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 (and verified your identity), 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 administration fee.

The right to correct and update the information we hold on you:-

If the information e 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 that we hold.
When we receive you request we will confirm whether the data has been deleted, or the reason why it cannot be deleted (for example because we hold it for our legitimate interests or regulatory purpose(s)).

The right to object to processing of your data where applicable

You have the right to request that we stop processing your data. Upon receive their quest 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 your consent forms the legal basis for our processing of your personal data.

You can withdraw your consent easily by telephone, email, or by post (see Contact Details below)

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 E.U. will only be placed in systems complying with measures giving equivalent protection of personal rights either through international agreements or contract 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 Data Protection Privacy 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 consent to the new processing.

*Changes to this notice

*We will keep this Privacy Notice under regular review and we will place any updates on http://www.standrewsroxbourne.org.uk/ . This notice was last updated in May 2018.

Contact Details

Please contact up if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, or complaints at:

The Data Controller, St Andrew’s Roxbourne, standrewsrox@dsl.pipex.com or ring 0208 422 3633 or use the contact form on our website:- http://www.standrewsroxbourne.org.uk/

You can contact the Information Commissioner’s 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