Data Privacy Notice – Immanuel Church Angmering
This document concerns the use and holding of any personal data that you hold as a result of your position in Immanuel Church Angmering Ltd, or your involvement in any activity under the auspices of Immanuel Church Angmering Ltd. Any personal information that you may hold about members or other people connected with Immanuel Church Angmering Ltd which you have received as a result of your personal, private or other business connection with that person is not subject to these rules.
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? Immanuel Church Angmering Ltd (ICA) is the data controller (contact details back page). This means it decides how your personal data is processed and for what purposes.
3. How do we process your personal data? ICA 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 minister to you and provide you with pastoral and spiritual care (such as visiting you when you are ill or bereaved) and to organise and perform ecclesiastical services for you, such as baptisms and funerals,To inform you of news, events, activities, and services running at Immanuel Church, • To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities, • To administer membership records and provide a membership directory, • To recruit, support and manage our employee(s) and volunteers (including church groups, clubs and other activities), • To fundraise and promote the interests of the charity, • To operate our website and forum, and deliver the services that individuals have requested, • 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 maintain our accounts and records (including the processing of Gift Aid applications and donations you make), • To enable us to meet all legal and statutory obligations, • To seek your views and comments. We collect personal data in some, or all of the following ways: • Names, titles, and aliases, • Contact details such as telephone numbers, addresses, and email addresses, • 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, nationality, education/work histories, academic/ professional qualifications, family composition, and dependants, • Where you make donations or pay for activities, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers. 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. Where you provide this information, we may also process other categories of sensitive personal data: racial or ethnic origin. And, where this is relevant, mental and physical health, details of injuries, medication/ treatment received, and criminal records, fines and other similar judicial records.
4. What is the legal basis for processing your personal data? • Most of our data is processed because it is necessary for our legitimate interests. • We will seek explicit consent to keep you informed about news, events, activities and services.• Processing is necessary for carrying out legal obligations in relation to Gift Aid or under employment, social security or social protection law, HMRC and other statutory requirements. • Where we have employees, we may process information in line with payroll and pension, HMRC, safer recruitment including DBS (‘Disclosure and Barring Service’) checks, and other statutory requirements. • Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details. • Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
5. Sharing your personal data Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary): • On occasion, other churches with which we are carrying out joint events or activities, • External statutory bodies (police, social care etc.) where this is legally required, • In the event of employee-related tasks, payroll, pension and other employment service providers.
6. How long do we keep your personal data? We keep data in accordance with the guidance set out in the guide on “Documentation” which is available on the Information Commissioner’s website at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-thegeneral-data-protection-regulation-gdpr/ Specifically, we retain Gift Aid declarations and associated paperwork for up to 6 years after the final financial year to which they relate.
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 Immanuel Church holds about you, • The right to request that Immanuel 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 Immanuel 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 applicable) [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], • 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) [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.
8. Transfer of Data Abroad Any electronic personal data transferred to countries or territories outside the UK will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the UK. Our website is also accessible from overseas so on occasion some personal data may be accessed from overseas.
9. Further processing 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.
10. Changes to this Privacy Notice We will review this Privacy Notice regularly and may update it at any time – for example in the event of legal changes, to improve how we manage data, where an issue or concern has come to light that needs appropriate response. If there are any significant changes in the way Immanuel Church processes your personal information, we will provide a prominent notice on our website or send you a notification. 11. Contact Details To exercise all relevant rights, queries of complaints please in the first instance contact the Church Secretary at firstname.lastname@example.org or via our registered office, 36 Cudlow Avenue, Rustington, West Sussex BN16 2HF. 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.