St Luke’s Church, St Albans
46 Cell Barnes Lane, St Albans AL1 5QJ
DATA PRIVACY NOTICE
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 Data Controller for St Luke’s Church, St Albans is its Parochial Church Council (hereafter referred to as ‘The PCC’) contact details below. As Data Controller, the PCC decides how your personal data is processed to deliver the church’s mission in the local community. The PCC works together with the Vicar, who is joint data controller. That means that both PCC and Vicar are responsible to you for how we process your data.
3. What data do we hold / process?
This could include:
Names, contact detail (addresses, email addresses, telephone numbers), photographs.
Where they are relevant to our mission (or where you provide them to us) we may process demographic information such as gender, age, date of birth, marital status, family composition, and dependants.
Where you make donations – your name, address, signature and financial identifiers such as bank details (branch address, bank sort-code, account number), payment card numbers, payment / transaction identifiers.
The data we process is likely to constitute sensitive personal data because, as a church, the fact that we process your data at all may be suggestive of your religious beliefs.
4. How do we process your personal data?
The PCC complies with its obligations under the “GDPR” by keeping personal data up to date (except in the case of one-off Gift Aid declarations, where the original declaration will be retained as required by HMRC); by storing and destroying personal data 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 physical and 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 a particular geographical area as specified in our constitution;
To administer membership records;
To fundraise and promote the interests of the church;
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, activities and services running at St Luke’s;
To share your contact details as appropriate with the Diocesan office and other local Anglican organisations so they can keep you informed about news in the area / diocese and events, activities and services that will be occurring locally / in the diocese and in which you may be interested;
To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) 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 and provide you with pastoral and spiritual care (such as visiting you when you are gravely ill or bereaved) 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 as provided for in the constitution and statutory framework of each data controller;
To seek your views or comments;
To notify you of changes to our services, events and role holders;
To send you communications 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;
5. 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 would also process data for carrying out obligations under employment, social security or social protection law, or a collective agreement;
As a religious organisation, we are also permitted to process information about your religious beliefs to administer membership or contact details. Our processing may include both current and former members (together with those who have regular contact or connection with us).
Where your information is used other than in accordance with one of these legal bases, we will first obtain your explicit consent to that use.
6. Sharing your personal data
Your personal data will be treated as strictly 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.
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 [see below for link].
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.
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 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;
The right to withdraw your consent to the PCC processing this data at any time;
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 lodge a complaint with the Information Commissioners Office.
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 Administrator at firstname.lastname@example.org.
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.
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/about-us/structure/churchcommissioners/administration/librariesandarchives/recordsmanagementguides.aspx
St Luke’s Data Privacy Notice (PDF file)