Who are we?
The Church of St Stephen’s, Cinderford (‘“we”, “us”) is the “data controller”. This means we are responsible for how your personal data is processed and for what purposes. Formally “the Church” in this Notice is the Vicar and Parochial Church Council (PCC) of St Stephen’s, Cinderford. Personal data is handled on our behalf by Office Holders (Vicar, any Curates, Lay Readers, members of the PCC), and some volunteers.
Your personal data – what is it?
Personal data relates to a living individual (the ‘“data subject”) 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 Act (1988) and the newer General Data Protection Regulations (GDPR) (2018).
How do we process your personal data?
The Church 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 for the following purposes:
- To enable us to provide a voluntary service for the benefit of the public in the particular geographical area as specified in our constitution;
- To administer membership records;
- To fundraise and promote the interests of the charity;
- To manage our employees and volunteers;
- To maintain our own accounts and records (including the processing of gift aid);
- To inform you of news, events, activities and services organised by the Church;
- To prevent, detect and prosecute crime (through our CCTV system).
What is the legal basis for processing your personal data?
The personal data held and processed by us is classed as sensitive because it relates to ‘religious belief’, either directly or indirectly. We can maintain and process personal data through several different authorisations, as defined by the ICO:
- Processing is necessary for carrying out obligations under national church, employment, charity, tax, social security or social protection law, or a collective agreement;
- 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;
- Explicit consent from the data subject.
Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the church to carry out a service to other church members or for purposes connected with the church – for example our service rotas.
We will only share your data with third parties outside of the parish with your consent, or where required to do so by law. This includes public display of the Electoral Roll, which includes names and addresses, for a period before the Annual Parochial Church Meeting, as required by law.
How long do we keep your personal data?
We keep data in accordance with the Church of England guidance1. Specifically, we retain:
- electoral roll data while it is still current (i.e. up 7 years);
- membership and involvement details between 2-6 years;
- details of gift aid declarations and other financial gifts for up to 7 years after the tax year to
which they relate;
- parish registers (baptisms, marriages, funerals, banns, confirmations and services)
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 Church holds about you;
- The right to request that the Church 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 for the
Church to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the data controller provide the data subject with his/her personal
data and where possible, to transmit that data directly to another data controller, (known
as the right to data portability) (where applicable2)
- 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 applicable3)
- The right to lodge a complaint with the Information Commissioners Office.
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.
Our Contact Details
To see a copy of your data, to opt out from communications, or to exercise your other rights, please contact the PCC at email@example.com or 01594 822286.
You can also 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.
1 The Church of England guide https://www.churchofengland.org/more/libraries-and-archives/records- management-guides
2 Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means.
3 Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics.