Data Privacy Notice – The Downs Benefice
The Parochial Church Councils of St Stephen’s with Lainston, Sparsholt; St Mary’s, Crawley;
St Catherine’s, Littleton; St Peter and Holy Cross, Wherwell and St Mary the Less, Chilbolton
Your personal data – what is it?
Personal data is data that 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 their possession. It includes data in all forms – computer based, hard copy and the spoken word. The processing of personal data will be governed by the General Data Protection Regulation, the GDPR, which is being introduced on 25 May 2018.
Who are we and what is our role?
Within the Downs Benefice, individual PCCs and the Benefice Office are the Data Controllers. This means it decides how your personal data is processed and for what purposes and is responsible for ensuring that the management of all our personal data within the benefice and parishes is legally carried out. Data protection activities will, however, be co-ordinated through the Benefice Council.
How do we process your personal data?
We comply with our obligations under the GDPR by:
- keeping personal data up to date
- storing and destroying it securely
- not collecting or retaining excessive amounts of data
- protecting personal data from loss, misuse, unauthorised access and disclosure
- ensuring that appropriate technical measures are in place to protect personal data.
What do we use your personal data for?
We use your personal data for the following purposes: -
- to enable us to provide a voluntary service for the benefit of the public primarily in our parish but across the Benefice also
- to administer membership records
- to fundraise and promote the interests of work of the Church
- to manage our 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 within the Benefice;
- to share your contact details with the Diocesan and Benefice offices so they can keep you informed about news in the diocese and events, activities and services in which you may be interested.
What is the legal basis for processing your personal data?
Data Controllers are permitted to process personal data by the GDPR as long as either:
- processing, in our case, is carried out by a not-for-profit body with a religious aim provided that the processing relates only to members or former or new/potential members or those who have regular contact with it in connection with those purposes and there is no disclosure to a third party without consent or ….
- explicit consent of the data subject is obtained for use of the data - so that we can correspond with you so you can be involved in the life and mission or our church or ….
- processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.
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 purpose connected with the church. We will only share your data with third parties outside of the Benefice with your consent unless legally required to do so.
How long do we keep your personal data?
Data will be kept in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available from the Church of England website; https://www.churchofengland.org/more/libraries-and-archives/records-management-guides. A basic principle of the GDPR is that data will not be kept for longer than is absolutely necessary.
Specifically, we will 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.
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 request a copy of your personal data which the PCC holds about you
- The right to request that any PCC or the Benefice Office corrects any personal data if it is found to be inaccurate or out of date
- The right to request that your personal data is erased where it is no longer necessary to retain such data
- The right to withdraw your consent to the processing or use of your data 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. This 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 that a restriction is placed on further processing;
- The right to object to the processing of personal data. This 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.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice or the consent you have given, 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.
To exercise all relevant rights, queries or complaints please in the first instance contact the Church Wardens or the Chairman of the PCC
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.
Downs Benefice GDPR Working Party. 13th April 2018