DATA PRIVACY NOTICE
The Parochial Church Council (PCC) of the Parish of Marton-in-Cleveland with Easterside
1. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. (for example name, photographs, email address). 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”) and other legislation relating to personal data and rights such as the Human Rights Act 1998 and the Data Protection Act 2018.
2. Who are we?
The Parochial Church Council of the Parish of Marton-in-Cleveland with Easterside (henceforth “the PCC” and “we”) is the data controller. This means it decides how your personal data is processed and for what purposes.
The incumbent (vicar), currently Revd Caroline Taylor, is also a separate data controller within the PCC.
3. What data do the data controllers listed above process?
We will process some or all of the following necessary to perform our tasks:
· Names, titles, and aliases, photographs;
· 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 (but not limited to); gender, age, date of birth, marital status, nationality, education/work histories, 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 and payment card numbers;
· If you attend a live-streamed service or church event, we may capture your image whilst filming or taking photographs;
Some data we process is considered a “special category” of information because it may indicate religious belief. For instance, if you appear on a live-stream showing you receive communion.
· We may also process other categories of sensitive personal data, where you provide it: such as (but not limited to): racial or ethnic origin; mental and physical health; medication/treatment received; criminal records, fines and other similar judicial records.
4. How do we process your personal data?
The PCC will comply 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 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 with the aim of ensuring that all are provided with safe environments;
· To minister to you and provide you with pastoral and spiritual care (such as visiting you if you are bereaved), and to perform ecclesiastical services for you, such as baptisms and weddings;
· 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 send you communications: which you have requested and that may be of interest to you; to seek your views or comments; or to notify you of important changes;
· To process a grant or application for a role;
· To record and upload, or live-stream services from our church, online, in order to reach out to those who wish to participate in our services remotely;
· The use of CCTV systems for the prevention and prosecution of crime.
5. What is the legal basis for processing your personal data?
We collect and use personal data using consent and explicit (i.e. written) consent. By signing the Consent Form and the Media Release form, you are consenting to us using your data for the purposes set out above.
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of an associated 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 to administer and publish the electoral roll, and 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. For example, 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.
In regards to filming: 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 indicated 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 media consent will be renewed every 3 years, but you can withdraw your consent at any time to being filmed in future services by contacting the PCC Secretary as set out in section 11 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.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with third parties where it is 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. For example, when processing DBS applications;
· 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 York to support the mission of the Church in our parish. For example: the area dean, archdeacon, curates, deacons, licensed lay ministers;
· On occasion, other churches with which we are carrying out joint events or activities.
· We will be sharing photographs and recorded or live-streamed services with the public, by uploading it to social media and other internet sites, such as our website and Facebook etc. This means your data may be stored outside the UK. Each platform has its own privacy policy which describes how your data is used and protected.
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 7 years; parish registers (baptisms, marriages, funerals) permanently; and data relating to live-streamed/recorded services for up to 3 years, except for certain special services, which may be retained permanently for archival purposes.
In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
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 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 it.
The right to withdraw your consent at any time *
· You can withdraw your consent to the processing of data for which consent was previously sought easily by telephone, email, or by post (see Contact Details below).
· You have the right to request that we stop processing your data in general. Upon receiving the request, we will let you know if we are able to comply or if we have legitimate grounds to continue to process your data.
The right to rectify 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 data portability
· You have the right to request that we transfer some of your data to another controller.
The right to object to the processing of personal data where applicable.
The right to lodge a complaint with the Information Commissioner’s Office.
*The rights to withdraw consent, or request erasure or restrict processing are limited in the case of live-streaming/recording, 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 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 details below.
9. Further processing
If we wish to use your personal data for a new purpose, not covered by this 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 Notice
We keep this Notice under regular review and we will place any updates on this web page www.stcuthbertmarton.org.uk/data.
This Notice was last updated in January 2022.
11. Contact Details
Please contact us if you have any questions about this Privacy Notice, the information we hold about you or to exercise all relevant rights, queries or complaints at: PCC Secretary at St Cuthbert’s Parish Centre, Stokesley Road, Marton-in-Cleveland, TS7 8JU.
Email: secretary@stcuthbertmarton.org.uk
Phone: 01642 316 201
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.