Holmer Parish Church

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Data Privacy Policy

The Parochial Church Council (PCC) of The Ecclesiastical Parish of Holmer with Huntington, Hereford

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 Act (1988) and the newer General Data Regulation (2018)(the “GDPR”).

2. Who are we?

The PCC of Holmer with Huntington, Hereford is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes. Formally “the Church” in this Notice is the Vicar and Parochial Church Council (PCC), but also includes Office Holders (any Curates) and any members of staff, both paid and unpaid, who process data on its behalf (including our Parish Administrator).

3. How do we process your personal data?

Holmer with Huntington, Hereford 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:

4. What is the legal basis for processing your personal data?
  1. Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations and keep you informed about diocesan events.
  2. Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.
  3. Processing carried out by a not-for-profit body with a religious aim provided:
    • the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
    • there is no disclosure to a third party without consent.
  4. For the Legitimate Interests of the church.
5. Legitimate Interest Assessment

Legitimate Interests are the appropriate legal basis upon which we store and process data, as we will only do so in ways that people would reasonably expect and that have a minimal impact upon the privacy of any individual (‘data subject’).

The Legitimate Interests enable us:

We believe that ‘Legitimate Interest’ is the most appropriate legal basis for the data processing. We understand the requirement to protect individual’s interests, by not divulging personal data beyond the Legitimate Interests identified above.

All the processing is necessary to facilitate an efficient and effective working relationship and communication stream between the Data Controller and its Data Subjects.

We are confident that individuals’ interests do not override these legitimate interests, and that we only use personal data in ways that could be reasonably expected.

We recognise the importance of keeping secure data relating to children and vulnerable adults to protect their interests.

As appropriate, we have adequate safeguards in place to prevent accidental disclosure of personal data. Our Data Privacy Notice includes the list of legitimate interests and an opt-out for those who wish to exercise their right to have their details erased.

6. Sharing your personal data

Your personal data will be treated as strictly confidential and will only be shared with other members of the church to carry out a service to other church members or for purposes connected with the church – for example Church rotas.

We will only share your data with third parties outside of the parish with your consent or where required to do so by law. This includes public display of the Electoral Roll, which includes names and addresses, for a period before the Annual Parochial Church Council Meeting, as required by law.

7. How long do we keep your personal data?[1]

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.

Specifically, we retain electoral roll data 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, marriages, funerals) permanently.

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:

9. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection 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. Contact Details

To see a copy of your data, to opt out from communications, to exercise your other rights, or if you have any queries or complaints, please contact the Parish Administrator at info@holmerchurch.org.uk or 01432 273200.

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.

References:
  1. Details about retention periods can currently be found in the Record Management Guides located on the Church of England website at: https://www.churchofengland.org/more/libraries-and-archives/records-management-guides
  2. 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.
  3. 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.