Privacy Notice
St John’s, Doddington in the Benefice of Cleobury Mortimer, Diocese of Hereford.
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 controllers’ possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”) and the Data Protection Act 2018, (the “DPA 2018”).
2. Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of St John’s Doddington in the Benefice of Cleobury Mortimer. The PCCs work together with the incumbent of the parishes (that is, our Rector).
As the church is made up of PCCs, clergy, ministers, together with associated lay volunteers and administrators all 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 communities. The PCC and incumbent referred to above are joint data controllers (this means they decide how your personal data is processed and for what purposes), which means we are all responsible for how we process your data.
In the rest of this Privacy Notice, we use the word “we” to refer to any or all of the above data controllers, as appropriate.
3. How do we process your personal data?
The PCC and incumbent comply with their obligations under the GDPR and DPA 2018 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 meet all legal and statutory obligations (which include maintaining and publishing our electoral roll in accordance with the Church Representation Rules).
- 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 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 in the parish/benefice.
- To enable us to provide a voluntary service for the benefit of the public in our parish/benefice.
- To administer records of our employees, ministers, office-holders and volunteers.
- To fundraise and promote the interests of our Churches and communities.
- To maintain our own accounts and records.
- To process any donations that you have made to us (including the processing of Gift Aid information).
- To seek your views or comments.
- To notify you of our services, events and office-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 carry out safeguarding procedures 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 share your contact details, when necessary, with the Hereford Diocesan Board of Finance which is responsible for the financial and administrative arrangements for the Diocese of Hereford, including the granting of faculty permission for building repairs and maintenance.
4. What is the legal basis for processing your personal data?
The legal basis for processing varies depending on the purpose:
- Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as the Hereford Diocesan Board of Finance). An example of this would be holding office-holder’s personal data to support the day-to-day communications needed to run our churches (this applies to roles such as churchwarden and PCC secretary). 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 a contract for maintenance of our buildings or equipment, or hire of the church hall.
- For other purposes we will process your data with your explicit consent. An example of this would be regular email newsletters providing information about our services and activities in the parish/benefice.
5. 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. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- Other clergy or lay persons nominated or licensed by the bishops of the Diocese of Hereford to support the mission of the Church in our parishes. 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.
- The Hereford Diocesan Board of Finance.
- Other persons or organisations operating within the Diocese of Hereford including, where relevant, the Hereford Diocesan Board of Education.
- Our agents and contractors (such as maintenance contractors, printers and architects).
- On occasion, other churches or community organisations with whom we are carrying out joint events or activities.
- Other Church Bodies[1] in accordance with national policy where safeguarding concerns exist or arise.
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[2]. 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.
We will keep some records permanently if we are legally required to do so. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete or destroy it when it is no longer needed.
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 PCCs hold about you;
- The right to request that the PCCs correct 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 PCCs to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the data controllers 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 Commissioner’s Office.
When exercising any of the rights listed above, 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.
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 or complaints, please in the first instance contact the Parish/benefice Administrator using email cleoburychurch@hotmail.com or by telephoning 01299 272916.
You can contact the Information Commissioner’s 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.
[1] Church Bodies includes PCCs, diocesan bodies, cathedrals, religious communities, theological training institutions and the National Church Institutions.
[2] 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