This page of our website contains Data Protection notices for office holders and non office holders of the parish church. A paper copy is available on request from the church.
Saint Matthew’s Willesden
PRIVACY NOTICE
ROLE HOLDERS
(e.g. Churchwardens, PCC Secretaries, PCC Treasurers, Deanery Synod
reps, Safeguarding officers etc.
See explanatory note on Privacy Notices on p.8)
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 Saint Matthew’s Willesden 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 or rector]);
·
the bishops of the Diocese
of London; and
·
the London Diocesan Fund,
which is responsible for the financial and administrative arrangements 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 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.
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 as appropriate (e.g. visiting the bereaved);
·
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 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 our employees and
volunteers;
·
To maintain our own accounts
and records;
·
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;
·
To share your contact
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 your
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
personal data relating to Role Holders including, as appropriate:
·
Our processing also includes
the use of CCTV systems for the prevention and prosecution of crime.
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 dependants.
·
Non-financial identifiers
such as passport numbers, driving license numbers, vehicle registration
numbers, taxpayer identification numbers, employee identification numbers, tax
reference codes, and national insurance numbers.
·
Financial identifiers such
as bank account numbers, payment card numbers, payment/transaction identifiers,
policy numbers, and claim numbers.
·
Financial information such
as salary, bonus, record of earnings, tax code, tax and benefits contributions,
expenses claimed, creditworthiness, car allowance (if applicable), amounts
insured, and amounts claimed.
·
Other operational personal
data created, obtained, or otherwise processed in the course of carrying out
our activities, including but not limited to, CCTV footage, recordings 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/certificates,
citizenship, immigration 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: 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.
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.
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 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 including other data controllers where it is
necessary for the performance of the data controllers’ tasks or where you first
give us your prior consent. It is likely
that we will need to share your data with
·
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 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 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 London including, where relevant,
the London Diocesan Board for Schools and Subsidiary Bodies
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 Commissioners 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 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.
Changes to this notice
We keep this Privacy Notice under
regular review and we will place any updates on our website. This Notice was
last updated in November 2017.
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, Saint Matthew’s
Willesden
Email: andrewteather@gmail.com
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.
GENERAL
PRIVACY NOTICE
(Note: This Privacy Notice is for non-role holders. See explanatory note on Privacy Notices on p.8)
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 Saint Matthew’s Willesden
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 or rector]);
·
the
bishops of the Diocese of London; and
·
the
London Diocesan Fund, which is responsible for the financial and administrative
arrangements 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 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 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 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 London including,
where relevant, the London Diocesan Board for Schools and Subsidiary Bodies;
·
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, Saint Matthew’s Willesden
Email: andrewteather@gmail.com
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.
