Privacy Policy – role-holders

 

DATA PRIVACY NOTICE

Role holders

 

The Parochial Church Council (PCC) of St Bene’t’s Church, Cambridge

 

  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 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.

 

  1. Who are we?

The PCC of St Bene’t’s Church, Cambridge is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.

 

  1. How do we process your personal data?

The PCC of St Bene’t’s Church, Cambridge 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 to perform 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) and trusteeship of the PCC;
  • 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 manage our employees and volunteers;
    • To communicate with you as part of your involvement with a group, rota or event at the church.
    • 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 communicate with you as part of your involvement with a group, rota or event at the church;
    • 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:
      • information about an 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 similar information in order to monitor compliance with equal opportunities legislation;
      • in order to comply with legal requirements and obligations to third parties.

 

We use your personal data to process some or all of the above functions, examples of which are shown, where necessary to perform tasks. In order to facilitate the above, we may use the following:

  • 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;
  • 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, 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.
  • Where you make donations or pay for activities such as use of the church, 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.

 

 

  1. 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. Processing is carried out by a not-for-profit body with a religious aim provided:

  • the processing relates only to members or former 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.

 

  1. 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.

 

  • The appropriate bodies of the Church of England including the other data controllers;
  • Other clergy or lay persons nominated or licensed by the bishops of the Diocese of Ely 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;
  • On occasion, other churches with which we are carrying out joint events or activities.

 

  1. How long do we keep your personal data[1]?

We keep data in accordance with the guidance set out in the guide ‘Keep or Bin: Care of Your Parish Records’ 1 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.

 

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.

  1. 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 requesting information.

 

  1. 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.

 

  1. 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)).

 

 

  1. 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.

 

 

  1. 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.

 

  1. 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).

 

  1. The right to object to the processing of personal data where applicable.

 

  1. The right to lodge a complaint with the Information Commissioner’s Office.

 

 

  1. 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 Tidings) may be accessed from overseas.

 

  1. 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.

 

  1. 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:

 

PCC Secretary/Parish Administrator: Philippa Pearson

St Bene’t’s Church, Bene’t Street, Cambridge CB2 3PT

Telephone: 01223 351927

Email: info@stbenetschurch.org

 

 

You can contact the Information Commissioners Office on 0303 123 1113 or via email www.ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

 

 

 

 

 

 

 

 

 

May 2018: Next review, May 2019

[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/about-us/structure/churchcommissioners/administration/librariesandarchives/recordsmanagementguides.aspx