THE OCTAGON DATA PRIVACY NOTICE
This notice sets out the policy of the Octagon Parochial Church Council (PCC) for compliance with the General Data Protection Regulations (GDPR) when processing personal data. The PCC will handle personal data in accordance with this Notice. This Notice will apply from the date when GDPR became effective.
What is Personal Data?
Personal data is data by which a living individual can be identified. 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.
To whom does this Notice apply
This notice applies to all who hold data in connection with the parish, and to all whose data is held and processed by the PCC and by office holders of the parish. The Octagon PCC is the data controller (contact details in paragraph 10 below). The data controller decides how personal data is processed and for what purposes.
How is personal data protected?
The Octagon PCC, as Data Controller for the parish, protects personal data as required by GDPR. Under GDPR, the Octagon PCC is classed as a “not-for-profit body with a religious aim”. As such, the PCC must comply with Section 9 of GDPR, which allows the PCC to collect personal data without the subject’s express consent, providing that:
- the processing relates only to members or former members of the church (or those who have regular contact with it in connection with the aim) and
- that there is no disclosure to a third party without consent.
This matter is discussed further below.
How do we process your personal data?
The Octagon PCC complies with its obligations under GDPR as follows:
- 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;
- 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 provide a voluntary service for the benefit of the public in the parish;
- To administer membership records;
- To fundraise and promote the interests of the parish;
- To manage our employees, volunteers and contractors;
- To maintain our own accounts and records (including the processing of gift aid applications);
- To inform you of news, events, activities and services in the parish;
- To administer distribution of and payment for the Octagon Magazine
What is the legal basis for processing your personal data?
The legal basis for processing personal data is Section 9 of GDPR, which is applicable to the PCC as a not-for-profit body with a religious aim. This regulation permits the PCC to process personal data, without the express consent of parishioners, where:
- Processing of data relating to employees and contractors is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement, or;
- Processing of data relating to parishioners and members of the public is carried out by the PCC, 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.
Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the church in order to carry out a service to other church members or for purposes connected with the church.We will only share your data with third parties not listed in this notice with your consent.
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. 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.
Your rights and your personal data
Unless subject to an exemption under GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data which the PCC holds about you;
- The right to request that the PCC corrects any personal data if it is found to be inaccurate or out of date;
- The right to request that your personal data be erased where it is no longer necessary for the PCC to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable) [This only applies where processing is based on legitimate interests (or the performance of a task in the public interest); and processing for the purposes of scientific/historical research and statistics]
- The right to lodge a complaint with the Information Commissioners Office (for contact details see paragraph 10 below.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then before we do so, we will either provide you with a new notice explaining this new use, or invite you to sign a data consent permitting the new use. The consent form will set out the relevant new purposes and processing conditions. A blank example of a consent form is at appendix to this Notice.
To exercise all relevant rights, queries or complaints please in the first instance contact the Parish Administrator. Tel 02392 631 367, email: firstname.lastname@example.org
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.
Explaining the terms used in the Notice:
Data is information of any kind, stored on any media including on paper and electronically.
Personal data is information about a living individual which is capable of identifying that individual.
Processing is anything done with/to data, including collecting and storing it.
The data subject is the person about whom personal data are processed.
The data controller is the person or organisation who determines the how and what of data processing, in the Octagon this is the PCC.