DATA PRIVACY NOTICE

 

The Parochial Church Councils (PCCs) of St. Mary Mablethorpe,
St. Peter Trusthorpe, St. Clement Sutton on Sea, St. Margaret
Huttoft and St. Andrew Anderby and the Incumbent and Ministry
Team of the Mablethorpe and Sutton Group of Parishes

 

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”).  That data can be held in any way including on paper or electronically.

 

2. Who are we?

Each PCC of the above named parishes is the data controller for their parish records and each subscribes to this same policy which explains how the personal data held by the PCC is processed and for what purposes. 

The Incumbent (Rector) is the data controller for records held by all members of the Ministry Team who minister in these parishes (including him/herself).  The Incumbent also subscribes to this policy which explains how the personal data held by the Ministry Team members is processed and for what purposes.

 

3. How do we process your personal data?

The PCCs of the above-named parishes and the Incumbent and Ministry Team Members comply with their 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

·       by ensuring that appropriate technical measures are in place to protect personal data.

 

Each PCC uses your personal data for the following purposes: -

·       To enable them to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution (ie. the parishes);

·       To maintain registers of Baptisms, Banns of Marriage and Marriage;

·       To administer membership records;

·       To fundraise and promote the interests of the parish/charity;

·       To manage employees and volunteers;

·       To maintain PCC accounts and records (including the processing of Gift Aid applications);

·       To inform people of news, events, activities and services running in the parishes;

·       To publicise “points of contact”.

 

The Incumbent and Ministry Team use your personal data for the following purposes: -

·       To enable them to conduct Baptisms, Marriages and Funerals and other Occasional Offices and provide Pastoral Care to those involved;

·       To enable them to provide general Pastoral Care to those who request it;

·       To inform people of news, events, activities and services running in the parishes;

·       To facilitate the administration of the parishes and their activities (including the management of employees and volunteers and the electronic payment of expenses and disbursements);

·       To publicise “points of contact”.

 

4. What is the legal basis for processing your personal data?

·       PCCs are legally required to maintain an Electoral Roll for membership and electoral purposes and to maintain Registers of Baptisms, Banns of Marriage and Marriages.

·       PCCs will seek the explicit consent of Electoral Roll members so that they can be kept  informed about news, events, activities and services running in the parishes.  This consent will be requested on Electoral Roll Application forms and will be retained on paper.

·       PCCs have a legitimate interest in carrying out processing in respect of the Gift Aid system.

·       Explicit consent will be sought for publicising contact details on public media

·       PCCs and the Incumbent and Ministry Team carry out processing in respect of employees and volunteers (including publication of rotas) as required by law, contract and legitimate interest.

·       The Incumbent and Ministry Team process data in respect of the conduct of baptisms, marriages (including calling banns) and funerals and associated occasional offices on the basis that we have a legitimate interest in doing so and in providing pastoral care in connection with such events.  Data is processed in order to provide general pastoral care on the basis of legitimate interest.

·       Where appropriate we process “Special Category Data” (specifically relating to religious affiliation) on the basis that that the GDPR allows Processing to be carried out by a not-for-profit body with a religious aim (including PCCs) 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
In general, personal data will be treated as strictly confidential. 

·       PCCs will share data with the Incumbent and Ministry Team only in order to facilitate pastoral care or for other purposes connected with the church.

·       The Incumbent and Ministry Team Members will share data between themselves only as required to carry out the requested occasional offices and facilitate pastoral care. 

·       The Incumbent and Ministry Team Members will share data with the PCCs only as required to conduct the occasional offices, to provide pastoral care as requested or for other purposes connected with the church.

·       Neither the PCCs nor the Incumbent and Ministry Team Members will ever share personal data with third parties outside of the parish EXCEPT in the following cases:

o   PCCs may share personal data with HMRC for the purpose of claiming Gift Aid;

o   with explicit consent PCCs may display contact details in/on public media;

o   the Incumbent and Ministry Team may share personal data of volunteers and employees with our banks for the purpose of paying expenses and disbursements and with the Diocese;

o   where required by law: this includes (but is not limited to) data which is required to be shared with the Registrar of Births, Deaths and Marriages; with HMRC and the DBS in connection with employee and volunteers; with the Diocese in respect of permissions and billing; and with the police or other statutory agencies.

 

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*.

Specifically, the PCCs retain electoral roll data (including records of consent) 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, banns and marriages) permanently. 

The Incumbent and Ministry Team Members retain personal records relating to baptisms, marriages and funerals etc. until the conclusion of the relevant occasional office and the pastoral follow-up period; other pastoral records are retained until the end of the process to which they relate; bank details (for payments) will be deleted when the payee leaves the relevant role.

Data on public media will be retained until no longer current or removal is requested.

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 above-named PCCs or the Incumbent and Ministry Team holds about you;

·       The right to request that the relevant PCC and/or Incumbent and Ministry Team Member 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 or legally required for the relevant PCC or the Incumbent and Ministry Team to retain it;

·       The right to withdraw your consent to the (relevant) processing at any time;

·       The right to request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable).

·       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, (where applicable);

·       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. Contact Details

To exercise all relevant rights, queries of complaints please, in the first instance, contact the Incumbent who acts as Data Controller in his own right (for the whole the Ministry Team) and as Data Controller for each of the above-named PCCs:

Click here for contact details.

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.

* Details about data 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

First Edition- Adopted by each PCC and Incumbent May/June 2018