This privacy policy sets out how the Parochial Church Council (PCC) of St Mary the Virgin, Bletchingley, uses and protects your personal data. This policy was updated 7th March 2024.
1. WHO ARE WE?
The PCC of St Mary the Virgin, Bletchingley (the PCC) is the data controller and is responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at parishofmarypeterpaul@outlook.com
2. 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 UK-retained version of the General Data Protection Regulation (UK GDPR”) and the Data Protection Act 2018 (DPA).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
• Identity Data: includes first name, last name, any previous names, marital status, title, date of birth and gender.
• Contact Data: includes home address, email address and telephone numbers.
• Financial Data: includes bank account details.
• Transaction Data: includes details about payments to and from you and us.
• Technical Data: includes internet protocol (IP) address, your login data if you
use IKnow, browser type and version, time zone setting and location, browser
plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Usage Data: includes information about how you interact with and use our website.
• Communications Data: includes your preferences in receiving communications from us and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' identity data to calculate the demographic of individuals receiving our communications to help make our communications more relevant.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through:
• Your interactions with us: You may give us your personal data by filling in online or paper forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy CLICK HERE for further details.
4. HOW DO WE USE YOUR PERSONAL DATA AND WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Legitimate interests: We may use your personal data where it is necessary to pursue our legitimate interests, for example to prevent fraud and to enable us to provide a good service to you. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
We will process your personal data on the basis of legitimate interest for the following purposes:
• Sending communications which you have requested, and which may be of interest to you, including information about our services, events, campaigns, appeals and other fundraising activities.
• Sending information related to fundraising and promotion of the interests of the PCC.
• Where you have taken part in one of our events or activities, we may use photographs in which you are identifiable to promote our activities (please note that we will not use photographs of children in which they can be identified without the express consent of their parent or guardian).
• To seek and process your views, feedback or comments on events or services.
• To keep our membership records up to date.
• To manage our employees and volunteers.
• To maintain our own accounts and records.
• Where you make donations, or where we reimburse you for expenses, to process financial identifiers such as bank account numbers.
Legal Obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will process your personal data on the basis of legal obligations for the following purposes:
• To enable us to claim gift aid on your donations.
• In relation to our employees and contractors, under employment and social security law.
• Under social protection law and where required as part of our safeguarding obligations and procedures (including due diligence and
Disclosure Barring Services (DBS) checks and complaints handling). We will process such data in accordance with the Diocese of Southwark’s Safeguarding Policy which we have adopted, and a copy of which can be found here: Diocesan policies and procedures - The Diocese of Southwark (anglican.org).
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purposes, for example if you expressly subscribe to our communications.
Special Category Data
The data we process is likely to constitute special category (sensitive) personal data because, as a church, the fact that we process your data at all is suggestive of your
In processing special category data we rely on Article 9(2)(d) of the UK GDPR, which allows us to process special category data in the course of our legitimate activities with appropriate safeguards as a not-for-profit body with a religious aim provided that:
• there is no disclosure to a third party without consent.
Processing for a new purpose
If we wish to use your personal data for a new purpose, not covered by this 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.
5. SHARING YOUR PERSONAL DATA
Your personal data will be treated as strictly confidential and will only be shared with third parties where necessary for the performance of our tasks, or where you give us your prior consent. It is likely that we will need to share your data with some or all of the following:
• Members of the church in order to carry out a service to other church members or for purposes connected with the church.
• Our agents and contractors, for example we use third parties to administer repairs and maintain our property; we use a third party for DBS checks; we use commercial software to manage newsletter and email lists; and we use third -party software to manage our records.
• The Chairty Commission where you are a trustee of our PCC.
• HM Revenue & Customs, regulator and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Our professional advisers.
• Within the Benefice we share the same database and as such will need to access information to facilitate Worship Agreements and legal obligations of individuals within these groups (particularly in connection with safeguarding, complaints or discipline cases) and with contracted advisers, lawyers, legal personnel and the relevant authority if so required by law. We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside of the UK.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those volunteers, employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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: Records management guides | The Church of England. We will keep some records permanently if we are legally required to do so.
Where we no longer need to process your personal data for the purposes set out in this Privacy Policy, we will delete your personal data from our systems.
8. YOUR RIGHTS AND YOUR PERSONAL DATA
Your rights
You have a number of rights under data protection laws in relation to your personal data. You have the right to:
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
o If you want us to establish the data's accuracy.
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Exercising your rights
If you wish to exercise any of the rights set out above, please contact us at parishofmarypeterpaul@outlook.com.
No fee usually required
You do not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on 7th March 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
11. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
12. CONTACT DETAILS
Please contact us if you have any questions about this Privacy Policy or the information we hold about you at parishofmarypeterpaul@outlook.com
To exercise all relevant rights, queries or complaints, please contact us at parishofmarypeterpaul@outlook.com
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.
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