GENERAL PRIVACY NOTICE
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Act 2018 and the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of St Paul’s Ealing, which is the data controller for your data.
The Church of England is made up of a number of different organisations and office-holders who work together to deliver the Church’s mission in each community. The PCC works together with:
- the incumbent of the parish (that is, our Senior Pastor);
- the bishops of the Diocese of London; and
- the London Diocesan Fund, which is responsible for the financial and administrative arrangements for the Diocese of London.
As the Church is made up of all of these persons and organisations working together, we may need to share personal data we hold with them so that they can carry out their responsibilities to the Church and our community. The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.
Each of the data controllers have their own tasks within the Church and a description of what data is processed and for what purpose is set out in this privacy notice. This privacy notice is sent to you by the PCC on our own behalf and on behalf of each of these data controllers. In the rest of this privacy notice, we use the word “we” to refer to each data controller, as appropriate.
What data do the data controllers listed above process? They will process some or all of the following where necessary to perform their tasks:
- Names, titles, and aliases, photographs, videos;
- 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, hobbies, family composition, and dependants;
- Where you make donations or pay for activities such as use of a church hall, 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, sex life, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning sexual orientation and criminal records, fines and other similar judicial records.
How do we process your personal data?
The data controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- 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 (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 administer the parish, deanery, archdeaconry and diocesan membership records;
- To fundraise and promote the interests of the Church and charity;
- To maintain our own accounts and records;
- To process a donation that you have made (including Gift Aid information);
- To seek your views or comments;
- To notify you of changes to our services, events and role holders;
- 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 process a grant or application for a role;
- To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
- Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
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.
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.
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):
- The appropriate bodies of the Church of England including the other data controllers;
- Our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software;
- Other clergy or lay persons nominated or licensed by the bishops of the Diocese of London to support the mission of the Church in our parish. For example, our clergy are supported by our area dean and archdeacon, who may provide confidential mentoring and pastoral support. Assistant or temporary ministers, including curates, deacons, licensed lay ministers, commissioned lay ministers or persons with Bishop’s Permissions may participate in our mission in support of our regular clergy;
- Other persons or organisations operating within the Diocese of London including, where relevant, the London Diocesan Board for Schools and Subsidiary Bodies;
- On occasion, other churches with which we are carrying out joint events or activities.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
- You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
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.
If we wish to use your personal data for a new purpose, not covered by this 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.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, St Paul’s PCC, St Paul’s Ealing, Ridley Avenue, Ealing, London. W13 9XW
Call: 020 8579 9444
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.
PRIVACY NOTICE FOR PHOTOGRAPHY AND FILMING IN/BY CHURCH
This privacy notice is provided to explain what to expect when we collect and process your personal information in relation to photography and/ or filming, and streaming of church services in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
The data controller is: Director of Operations, St Paul's Church, Ealing, London. W13 9XW
Personal information is collected for purposes of:
- Recording, uploading or live-streaming services / events from or organised by our church, online, in order to reach out to those who are unable to attend in person, or who wish to participate in our services remotely or
- Images upload to our website or for internally / externally marketing and
- Managing the media release forms in relation to the filming and streaming of church services on-line.
The categories of personal data we collect are:
- Image – We may capture your image whilst filming / photographing a church service / event / etc.
- Name and contact details – we will record your name and contact details provided on the media release.
We also process “special categories” of information that may include:
- Religious belief – By taking part in the service or having an image on our website, this may indicate religious belief.
- Archiving – certain services may be retained permanently for historic purposes.
We collect and use personal data using consent and explicit (written) consent.
By signing the Consent form or Media Release form, you are consenting to us using your data for the purposes set out above.
You may withhold your consent by sitting in a “film free area” of the church before filming or photography starts. Such areas will be clearly marked by notices in the church.
In the filming areas, once live-streaming or filming has started, or group photographs have been taken consent cannot be withdrawn because your data can’t be permanently removed from the internet, nor can a group video or photograph be edited to remove your image.
If you are a regular attendee, your consent will be renewed approximately every 3 years, but you can withdraw your consent at any time to being filmed in future services by contacting the church data controller as set out in section 9 below and sitting in the “film-free” area when attending church services if you do not want to be filmed.
You may be asked to consent on behalf of children aged 16 years or under attending with you. Please consider whether they would want their images to be uploaded to the internet.
We will be sharing photographs and recorded or live-streamed services with the public, by uploading it to social media, our website and other internet sites, such as Vimeo, YouTube, Facebook, Twitter etc.
We will keep your data for up to 3 years, except for certain special services / events or published, which may be retained permanently for archival purposes.
You have the following rights regarding your personal data:
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to withdraw consent – You have the right to withdraw your consent as described in section 4 above*.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete*.
- Your right to request erasure - You have the right to ask us to erase your personal information in certain circumstances*.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances*.
*The rights to withdraw consent, or request erasure or restrict processing are limited, i.e. once the data is uploaded online, we are no longer able to erase or restrict the processing of individual images. In addition, the right to rectification only applies to the processing of your name and contact details, it cannot apply to your image captured on film.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. You can exercise your rights by contacting us at the contact details below.
If you have any complaints or queries regarding this processing activity or wish to exercise your rights, please contact St Paul's Data Controller via firstname.lastname@example.org or by calling 020 8579 9444
You have the right to make a complaint at any time to the Information Commissioner on 0303 123 1113 (local rate), or online at: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/