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) or in conjunction with any other information. 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].
Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of All Souls Church which is the data controller for your data.
The parish of All Souls, Langham Place is made up of a number of different organisations and office-holders who work together. The PCC works together with:
As the parish 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 parish 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 has their own tasks within the parish and a description of what data is processed and for what purpose is set out in this Privacy Notice. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.
How do we process your personal data?
We will comply with our legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data or store data for longer than is necessary; 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: -
What data do we process?
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.
We will also process your data in order to assist you in fulfilling your role in the church including pastoral and administrative support or if processing is necessary for compliance with a legal obligation.
Religious organisations are permitted to process information about your religious beliefs to administer membership or contact details.
Religious organisations are also permitted to process special categories of data in the course of legitimate activities with appropriate safeguards and on condition that the processing relates solely to the members, to former members or to people who have regular contact with us in connection with our purposes and that their personal data are not disclosed to outside bodies without their consent.
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 including other data controllers where it is necessary for the performance of the data controllers’ tasks or where you first give us your prior consent. We may need to share your data with
How long do we keep your personal data?
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 6 years to support HMRC audits. 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.
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.
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 a newsletter) may be accessed from overseas.
Changes to this notice
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 Protection Manager, All Souls Church, 2 All Souls Place, London, W1B 3DA
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.