DATA PRIVACY NOTICE
The Parochial Church Council (PCC) of St Peter & St Paul, Deddington with St John the Evangelist Hempton, and Clifton
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 PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
3. How do we process your personal data?
The PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, complies with its 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 charity;
· To manage our employees and volunteers;
· To maintain our own accounts and records (including the processing of gift aid applications);
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 keep you informed about diocesan events.
· Processing is necessary for carrying out legal obligations in relation to Gift Aid or 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.
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.
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 Parish 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 request a copy of your personal data which the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, holds about you;
· The right to request that the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, corrects any personal data if it is found to be inaccurate or out of date;
· The right to request your personal data is erased where it is no longer necessary for the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton 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, this is known as the right to data portability;
· 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;
· 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.
9. Data subjects’ rights
Data modification proceduresWe will process personal data in line with data subjects' rights, including their right to:· request access to any of their personal data held by us (known as a Subject Access Request);· ask to have inaccurate personal data changed;· restrict processing, in certain circumstances;· object to processing, in certain circumstances, including preventing the use of their data for direct marketing;· data portability, which means to receive their data, or some of their data, in a format that can be easily used by another person (including the data subject themselves) or organisation;· not be subject to automated decisions, in certain circumstances; and· withdraw consent when we are relying on consent to process their data.
If someone within the church receives any request from a data subject that relates or could relate to their data protection rights, this will be forwarded to our Data Protection Officer immediately, or the Vicar in their absence.
The Data Protection Officer will use the checklist on the ICO website to determine what you need to do and contact the Diocesan Data Protection Officer (or take legal advice) if there is an uncertainty about what they need to do or what they can provide.
The Data Protection Officer will act on all valid requests as soon as possible, and at the latest within one calendar month, unless they have reason to, and can lawfully extend the timescale. This can be extended by up to two months in some circumstances.
All data subjects’ rights are provided free of charge.
Any information provided to data subjects will be concise and transparent, using clear and plain language.
10. Data breach procedures
Where staff, volunteers, or contractors working for us, think data might have been breached or lost, this will be reported immediately to the Data Protection Officer.
The Data Protection Officer will keep records of personal data breaches, even if they do not report them to the ICO.
The Data Protection Officer will report all data breaches which are likely to result in a risk to any person, to the ICO. Reports will be made to the ICO within 72 hours from when someone in the church becomes aware of the breach.
In situations where a personal data breach causes a high risk to any person, The Data Protection Officer will (as well as reporting the breach to the ICO), inform data subjects whose information is affected, without undue delay. This can include situations where, for example, bank account details are lost or an email containing sensitive information is sent to the wrong recipient. Informing data subjects can enable them to take steps to protect themselves and/or to exercise their rights.
11. Risk assessment
When we are planning to carry out any data processing which is likely to result in a high risk we will carry out a Data Protection Impact Assessment (DPIA). These include situations when we process data relating to vulnerable people, trawling of data from public profiles, using new technology, and transferring data outside the EU. Any decision not to conduct a DPIA will be recorded.
When processing non-sensitive personal information (e.g. contact details for the church database or financial giving) the risk management is included within the data audit - under security controls.
12. Contact Details
To exercise all relevant rights, queries or complaints please, in the first instance, contact Stanley Nelson, The Data Protection Officer, Rothbury House, Bullring, Deddington, Banbury, Oxfordshire OX15 0TT [email protected]
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.
13. Review
The PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, will review this Data Privacy Notice annually or sooner if there are significant changes in legislation or advice.
[1] Details about retention periods can currently be found in the Record Management Guides located on the Church of England website at: - https://www.churchofengland.org/more/libraries-and-archives/records-management-guides
Updated January 2021
The Parochial Church Council (PCC) of St Peter & St Paul, Deddington with St John the Evangelist Hempton, and Clifton
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 PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
3. How do we process your personal data?
The PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, complies with its 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 charity;
· 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 St Peter & St Paul Deddington and St John the Evangelist, Hempton
- To inform you of news, events, activities and services running at other churches in the Benefice;
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 keep you informed about diocesan events.
· Processing is necessary for carrying out legal obligations in relation to Gift Aid or 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.
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.
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 Parish 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 request a copy of your personal data which the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, holds about you;
· The right to request that the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, corrects any personal data if it is found to be inaccurate or out of date;
· The right to request your personal data is erased where it is no longer necessary for the PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton 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, this is known as the right to data portability;
· 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;
· 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.
9. Data subjects’ rights
Data modification proceduresWe will process personal data in line with data subjects' rights, including their right to:· request access to any of their personal data held by us (known as a Subject Access Request);· ask to have inaccurate personal data changed;· restrict processing, in certain circumstances;· object to processing, in certain circumstances, including preventing the use of their data for direct marketing;· data portability, which means to receive their data, or some of their data, in a format that can be easily used by another person (including the data subject themselves) or organisation;· not be subject to automated decisions, in certain circumstances; and· withdraw consent when we are relying on consent to process their data.
If someone within the church receives any request from a data subject that relates or could relate to their data protection rights, this will be forwarded to our Data Protection Officer immediately, or the Vicar in their absence.
The Data Protection Officer will use the checklist on the ICO website to determine what you need to do and contact the Diocesan Data Protection Officer (or take legal advice) if there is an uncertainty about what they need to do or what they can provide.
The Data Protection Officer will act on all valid requests as soon as possible, and at the latest within one calendar month, unless they have reason to, and can lawfully extend the timescale. This can be extended by up to two months in some circumstances.
All data subjects’ rights are provided free of charge.
Any information provided to data subjects will be concise and transparent, using clear and plain language.
10. Data breach procedures
Where staff, volunteers, or contractors working for us, think data might have been breached or lost, this will be reported immediately to the Data Protection Officer.
The Data Protection Officer will keep records of personal data breaches, even if they do not report them to the ICO.
The Data Protection Officer will report all data breaches which are likely to result in a risk to any person, to the ICO. Reports will be made to the ICO within 72 hours from when someone in the church becomes aware of the breach.
In situations where a personal data breach causes a high risk to any person, The Data Protection Officer will (as well as reporting the breach to the ICO), inform data subjects whose information is affected, without undue delay. This can include situations where, for example, bank account details are lost or an email containing sensitive information is sent to the wrong recipient. Informing data subjects can enable them to take steps to protect themselves and/or to exercise their rights.
11. Risk assessment
When we are planning to carry out any data processing which is likely to result in a high risk we will carry out a Data Protection Impact Assessment (DPIA). These include situations when we process data relating to vulnerable people, trawling of data from public profiles, using new technology, and transferring data outside the EU. Any decision not to conduct a DPIA will be recorded.
When processing non-sensitive personal information (e.g. contact details for the church database or financial giving) the risk management is included within the data audit - under security controls.
12. Contact Details
To exercise all relevant rights, queries or complaints please, in the first instance, contact Stanley Nelson, The Data Protection Officer, Rothbury House, Bullring, Deddington, Banbury, Oxfordshire OX15 0TT [email protected]
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.
13. Review
The PCC of St Peter & St Paul, Deddington, with St John the Evangelist Hempton and Clifton, will review this Data Privacy Notice annually or sooner if there are significant changes in legislation or advice.
[1] Details about retention periods can currently be found in the Record Management Guides located on the Church of England website at: - https://www.churchofengland.org/more/libraries-and-archives/records-management-guides
Updated January 2021