Contacts
Data Privacy Notice
First edition — adopted by each PCC and Incumbent May/June 2018
The Parochial Church Councils (PCCs) of St Mary Mablethorpe, St Peter Trusthorpe, St Clement Sutton on Sea, St Margaret Huttoft and St Andrew Anderby, and the Incumbent and Ministry Team of the Mablethorpe and Sutton Group of Parishes.
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”). That data can be held in any way, including on paper or electronically.
2. Who Are We?
Each PCC of the above-named parishes is the data controller for their parish records, and each subscribes to this same policy, which explains how the personal data held by the PCC is processed and for what purposes.
The Incumbent (Rector) is the data controller for records held by all members of the Ministry Team who minister in these parishes (including him/herself). The Incumbent also subscribes to this policy, which explains how the personal data held by the Ministry Team members is processed and for what purposes.
3. How Do We Process Your Personal Data?
The PCCs of the above-named parishes and the Incumbent and Ministry Team Members comply with their obligations under the GDPR by keeping personal data up to date; storing and destroying it securely; not collecting or retaining excessive amounts of data; protecting personal data from loss, misuse, unauthorised access and disclosure; and ensuring that appropriate technical measures are in place to protect personal data.
Each PCC uses your personal data to: provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution (the parishes); maintain registers of Baptisms, Banns of Marriage and Marriage; administer membership records; fundraise and promote the interests of the parish/charity; manage employees and volunteers; maintain PCC accounts and records (including Gift Aid applications); inform people of news, events, activities and services running in the parishes; and publicise “points of contact”.
The Incumbent and Ministry Team use your personal data to: conduct Baptisms, Marriages and Funerals and other Occasional Offices and provide Pastoral Care to those involved; provide general Pastoral Care to those who request it; inform people of news, events, activities and services running in the parishes; and facilitate the administration of the parishes and their activities (including the management of employees and volunteers and the electronic payment of expenses and disbursements).
4. What Is the Legal Basis for Processing Your Personal Data?
PCCs are legally required to maintain an Electoral Roll for membership and electoral purposes, and to maintain registers of Baptisms, Banns of Marriage and Marriages. PCCs will seek the explicit consent of Electoral Roll members so they can be kept informed about news, events, activities and services running in the parishes — this consent is requested on Electoral Roll Application forms and retained on paper. PCCs have a legitimate interest in carrying out processing in respect of the Gift Aid system, and explicit consent will be sought for publicising contact details on public media.
PCCs and the Incumbent and Ministry Team carry out processing in respect of employees and volunteers (including publication of rotas) as required by law, contract and legitimate interest. The Incumbent and Ministry Team process data in respect of the conduct of baptisms, marriages (including calling banns) and funerals and associated occasional offices on the basis that we have a legitimate interest in doing so, and in providing pastoral care in connection with such events.
5. Sharing Your Personal Data
In general, personal data will be treated as strictly confidential. PCCs will share data with the Incumbent and Ministry Team only to facilitate pastoral care or for other purposes connected with the church. The Incumbent and Ministry Team Members will share data between themselves only as required to carry out the requested occasional offices and facilitate pastoral care, and will share data with the PCCs only as required to conduct the occasional offices, provide pastoral care as requested, or for other purposes connected with the church.
Neither the PCCs nor the Incumbent and Ministry Team Members will ever share personal data with third parties outside of the parish, except: PCCs may share data with HMRC for the purpose of claiming Gift Aid; with explicit consent, PCCs may display contact details in/on public media; the Incumbent and Ministry Team may share personal data of volunteers and employees with our banks for the purpose of paying expenses and with the Diocese; and where required by law, including data shared with the Registrar of Births, Deaths and Marriages, HMRC, the DBS in connection with employees and volunteers, the Diocese in respect of permissions and billing, and the police or other statutory agencies.
6. How Long Do We Keep Your Personal Data?
We keep data in accordance with the guidance in “Keep or Bin: Care of Your Parish Records”, available from the Church of England website. Specifically, the PCCs retain electoral roll data (including records of consent) 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, banns and marriages) permanently.
The Incumbent and Ministry Team Members retain personal records relating to baptisms, marriages and funerals until the conclusion of the relevant occasional office and the pastoral follow-up period; other pastoral records are retained until the end of the process to which they relate; and bank details for payments will be deleted when the payee leaves the relevant role. Data on public media will be retained until no longer current or removal is requested.
7. Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, you have the right to: request a copy of your personal data which the PCCs or the Incumbent and Ministry Team holds about you; request that inaccurate or out-of-date data is corrected; request your data is erased where it's no longer necessary or legally required to retain it; withdraw your consent to relevant processing at any time; request that the data controller provide your data to you, and where possible transmit it directly to another data controller (data portability); request a restriction on further processing where there's a dispute about accuracy; object to processing, where applicable; and lodge a complaint with the Information Commissioner's Office.
8. Further Processing
If we wish to use your personal data for a new purpose not covered by this notice, 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 necessary, we will seek your prior consent to the new processing.
9. Contact Details
To exercise any of the rights above, or with queries or complaints, please contact the Incumbent in the first instance, who acts as Data Controller in his own right (for the whole Ministry Team) and as Data Controller for each of the above-named PCCs — see our Contacts page.
You can also contact the Information Commissioner's Office on 0303 123 1113, via ico.org.uk, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.