DATA PRIVACY NOTICE
The Incumbent and Trustees of Emmanuel Church Wimbledon (the Church”)
- Your personal data – what is it?
“Personal data” is any information relating 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 primarily governed in this country by the Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation 2016 (GDPR).
Who are we?
The Incumbent and Trustees of the Church (We”) are the data controllers1 and decide how your personal data is processed and for what purposes. Contact details are provided in paragraph 9 below.
How do we process your personal data?
We comply with our obligations under the 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 (including maintaining the electoral roll);
- To enable us to provide a Christian witness for the benefit of the community of Wimbledon and beyond;
- To carry out comprehensive safeguarding procedures in accordance with best safeguarding practice from time to time with the aim that all children and adults-at-risk are provided with safe environments;
- To minister to you and provide you with pastoral care, including services such as weddings and funerals;
- To administer membership records and to provide a church directory to facilitate church members communicating with one other;
- To promote the interests of the Church, including financial interests;
- To manage our employees and volunteers;
- To maintain our own accounts and records (including gift aid applications);
- To inform you of news, events, activities and services relating to or provided through the Church.
What is the legal basis for processing your personal, and special category, data?
- We request your explicit consent as the data subject2, to process your personal data for the purposes listed in 3 above but, in particular, so that we can keep you informed about such news, events, activities and services;
- Most of our data is processed because it is necessary for our legitimate interests. Some processing of your personal data is necessary for carrying out our legal obligations in relation to Gift Aid or under employment, social security or social protection law;
- The processing is carried out by a not-for-profit body with a religious aim; and
- the processing relates only to the Church fellowship (comprising members or former members of the Church or those who have regular contact with it in connection with that aim), and
- there is no disclosure to a third party unless either the consent of the data subject is obtained or the disclosure is required to meet our legal obligations.
Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the Church fellowship in order to carry out a service to other church fellowship members or for purposes connected with the Church. We will only share your data with third parties outside the Church where we are legally obliged to, e.g. Her Majesty’s Revenue and Customs (HMRC) for gift aid details, or with your consent.
1 The entity that determines the purposes, conditions and means of the processing of personal data.
2 The living or ‘natural person’ whose personal data is processed by a data controller or processor is known as the data subject.
How long do we keep your personal data3?
We keep data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Church Records” which is available from the Church of England website [see footnote below for link]. Note that all processing of your personal data will cease once you have withdrawn consent, other than where this is required by law, but this will not affect any personal data that has already been processed prior to this point.
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 Church registers (baptisms, marriages, funerals) permanently.
Your rights and your personal data
Unless subject to an exemption under the DPA 2018, you have the following rights with respect to your personal data: -
- The right to request a copy of the personal data which the Church holds about you;
- The right to correct and update the information we hold on you or 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, and to the extent that, it is no longer necessary for the Church to retain such data, where you gave your consent to the processing of that data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the data controller provide you with a copy of your personal data and, where possible, to transmit that data directly to another data controller in accordance with your right to ‘data portability’. Note that this 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 where the data controller processes the data by automated means;
- 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. Note that this 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;
- The right to lodge a complaint with the Information Commissioner’s Office (ICO).
If we wish to use your personal data for a new purpose, not covered by this Data Privacy 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.
To exercise all relevant rights, to raise queries or complaints please in the first instance contact the Church Manager; email: email@example.com telephone: 020 8879 7400.
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.
3 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