This Privacy Notice is provided to you by the Parochial Church Council (PCC) of CHRIST CHURCH TURNHAM GREEN which is the data controller for your data on behalf of the church, Christ Church W4. This privacy notice tells you about the information we collect and hold on you. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
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 new legislation, the General Data Protection Regulation “GDPR”.
Who are we?
Christ Church W4 is a multi-site church with three sites, Christ Church Turnham Green, St Alban’s and The Mission Hall. We are governed by the Church of England.
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);
- 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 is processed by the data controllers listed above?
They will process some or all of the following where necessary to perform their tasks:
- Names, titles, and aliases;
- 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 provide a useful resource in the form of an online directory of users. (Using ChurchSuite)
- 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, or except in certain limited situations, such as where we are required to do so by law or to protect members of the public from serious harm.
It is likely that we will need to share your data with some or all of the following, but only on an as-needed basis:
- Internally: We will share your data amongst staff, trustees, treasurers, elders, team and group leaders. When you give us your email address or number, for example, it is stored in our staff-only database (we use the online church database platform ‘ChurchSuite’). The staff use that information for their specific roles and if you join a small group or serving team, the leaders are given access to that basic information, for example. Children’s data is seen by their group leaders on a Sunday.
- Legal compliance: We are legally obliged to share some information to adhere to UK law. For example, as we are a registered charity, we must submit our accounts, which need to be audited by a third part accountant. We must also fulfil our legal requirements for safeguarding, for which it may be necessary to share your information with law enforcement entities.
- Approved third-parties: When we use the term third-party, we mean systems or organisations that are necessary for Christ Church W4 to function, as we are not able to internally do that work. We will carefully vet these before use to ensure they will in turn keep personal data secure in line with the law. We do not give, sell, trade or share any of your personal data to organisations that we think may be of interest to you, ever.
Examples of our approved third parties are:
Diocesan: The London Diocese, The Church of England, other local churches (when carrying out joint events or activities).
IT: Google (staff email, data storage, administrative tools), ChurchSuite (data management), MailChimp (email distribution and design), SurveyMonkey, Doodle (data collection), Xero (financial accounts).
Financial organisations: HMRC (gift aid reporting), CAF (banking), Stewardship (giving), Stripe (online card payment processing).
Venues for Events: for attendees only
How long do we keep your personal data?
In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed. 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.
Your rights and your personal data
Under the GDPR you have a number of rights with regard to your personal data. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
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, Parochial Church Council of Christ Church Turnham Green
You can contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
For any data protection issues please email email@example.com.