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Data Privacy Policy

DATA PRIVACY POLICY

The Parochial Church Council (PCC) of the Parish of Cove, Guildford Diocese

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”).

2. Who are we?

The PCC of the Parish of Cove (“the PCC”) is overall responsible for compliance with the GDPR. This means it decides how your personal data is processed and for what purposes. A member of the PCC is appointed as Data Controller (contact details below).

3. How do we process your personal data?

The PCC complies with its obligations under the GDPR by:

  • keeping personal data up to date;
  • storing and destroying it securely;
  • not collecting or retaining excessive amounts of data;
  • protecting personal data from loss, misuse, unauthorised access and disclosure;
  • ensuring that appropriate technical measures are in place to protect personal data.

We use your personal data for the following purposes:

  • To administer membership records;
  • To manage our employees and volunteers;
  • To maintain our own accounts and records including the processing of gift aid applications;
  • To inform you of news, events, services and other activities;
  • 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 carry out comprehensive 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 minister to you by providing pastoral and spiritual care (including, but not limited to, visiting you when you are ill, bereaved, need emotional or spiritual support) and to organise and perform ecclesiastical 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;
  • To share your contact details with the Diocesan office so they can keep you informed about news in the diocese and events, services and other activities that will be occurring in the diocese and in which you may be interested.

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

  • Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations and keep you informed about diocesan events.
  • Processing is necessary for carrying out obligations under employment, 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.

5. Sharing your personal data

Your personal data will be treated as confidential and will only be shared with other members of the church in order to carry out a service to other church members or for purposes connected with the church. We will only share your data with third parties outside of the parish with your consent or as required by law.

You may choose to join our Parish of Cove on-line directory, called ChurchSuite, to facilitate sharing of parish information and personal data. This requires your consent using our Parish of Cove Personal Data consent form.

6. Data Processors we use

We may use a range of different third party providers acting as processors in order to store our data securely and provide website, social media, media and IT and system administration services. These processors include:

  • Databases include: ChurchSuite**, Microsoft 365*, OneDrive*;
  • Course and event management systems including Eventbrite*;
  • Electronic marketing and research services such as Mailchimp*;
  • Social Media platforms including Facebook*, Twitter*, Instagram*.

In addition, please note this includes:

  • Professional advisers including lawyers, bankers, auditors, pension advisors and insurers based in the United Kingdom who provide their respective services;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • 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.

*MailChimp, Microsoft 365 (includes OneDrive and Teams), Facebook Inc. (includes Instagram and WhatsApp) and Twitter are US based companies and are certified under Privacy Shield. All of these companies, although based in the USA, have also taken measures to become compliant with GDPR requirements.

Please refer to:

  • MailChimp’s GDPR Information and Privacy Policy here.
  • Microsoft and OneDrive GDPR Information and Privacy Policy here.
  • Facebook’s GDPR Information and Privacy Policy here & here.
  • Twitter’s GDPR Information and Privacy Policy here.

**ChurchSuite is a UK based processor and is GDPR compliant. Please see their GDPR Information and Privacy Policy here.

7. 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 here.

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; see also Section 10. Exceptions.

8. 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 PCC holds about you;
  • The right to request that the PCC 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 PCC to retain such data (but see Section 10. Exceptions);
  • 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 your personal data and where possible, to transmit that data directly to another data controller (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.

9. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Policy, 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.

10. Exceptions

The right to erasure does not apply if processing is necessary for one of the following reasons:

  • to exercise the right of freedom of expression and information;
  • to comply with a legal obligation;
  • for the performance of a task carried out in the public interest or in the exercise of official authority;
  • for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
  • for the establishment, exercise or defence of legal claims.

In such circumstances, we will inform you within one month of receipt of the erasure request.

11. Exclusions

This Data Privacy Policy covers information provided to the Parish of Cove for the purposes described above. It does not cover all information that may be provided to members of the Parish. In particular:

Information disclosed in confidential discussions with clergy or other licensed officials of the Parish is subject to tighter restrictions and not directly covered by this policy, though similar principles apply.

Similarly, information provided for safeguarding purposes is subject to tighter restrictions and is not directly covered by this policy.

Information provided “unofficially” to members of the Parish (e.g. the sharing of addresses, phone numbers, WhattsApp contacts and email addresses between friends for the purposes of informal communication) is not covered by this policy and is not policed in any way. No data protection rights can be applied to this kind of information sharing.

12. Retaining your data to assist NHS Test and Trace

In compliance with UK Government guidelines we will, from time to time as directed by external authorities, keep temporary data records of those attending certain gatherings on our sites. We would do this, for example, in order to assist NHS Test or Trace services with requests for data if it is needed.

13. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the Parish Administrator at info@parishofcove.org.uk

The Parish of Cove Data Controller is a member of the PCC appointed at the Annual Parish Church Meeting; contact details are available from the Parish Administrator.

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.