Christ Church Mayfair 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, 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 describes the way that we, Christ Church Mayfair (“CCM”), as a controller use 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 Church Council of CCM works together with:
the incumbent of the parish (that is, our Senior Minister); 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 such as the names and addresses on our electoral roll.
The legal entity governing our church is The Bible Talks Trust (charity number 1092036) but we are transitioning to Christ Church Mayfair Charitable Company (charity number 1152061) shortly. The legal entity is accountable for the finances of the church, our Safeguarding and other legal matters.
Each of the controllers has their own tasks within the Church of England 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 CCM on our own behalf and on behalf of each of the controllers listed above. In the rest of this Privacy Notice, we use the word “we” to refer to each controller, as appropriate.
What data do the controllers listed above process?
They will process some or all of the following where necessary to perform their 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 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 weekends away, 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 special category 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 special category data: racial or ethnic origin, sex life, mental and physical health, details of injuries, medication/treatment received, political beliefs, labour 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 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 personal data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical and organisational 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, 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 controller;
- To administer the parish, deanery, archdeaconry and diocesan membership records;
- To fundraise and promote the interests of the Church and CCM;
- 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 (such as Timeout) and that may be of interest to you. These may include information about campaigns, events, appeals, other fundraising activities;
- To process a grant or application for a role; and
- To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution.
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.
We may also process personal 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 personal 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 usually obtain your consent to that use unless there Is another substantial public interest that we can rely on to use your personal data.
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 where we are legally required to share your personal data, where we share your personal data to protect CCM or another individual, or where you first give us your prior consent. It is likely that we will need to share your personal 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 maintain our database software e.g. ChurchSuite; 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 retain some records according to certain regulatory and statutory responsibilities. 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 after the date of the transaction to support HMRC audits. In general, we will endeavour to keep personal 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 personal data we hold on you
- At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the information and where we obtained the personal data from. Once we have received your request we will endeavour to respond within one month.
- There are no fees or charges for the first request but additional requests for the same personal data may be subject to an administrative fee.
- The right to correct and update the personal data we hold on you
- If the personal data we hold on you is out of date, incomplete or incorrect, you can inform us and your personal data will be updated.
- The right to have your personal data erased
- If you feel that we should no longer be using your personal data or that we are illegally using your personal data, you can request that we erase the personal 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 personal data
- You have the right to request that we stop processing your personal 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 personal data. Even after you exercise your right to object, we may continue to hold your personal 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 personal data to another controller in certain circumstances. 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 personal 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 personal data transferred to countries or territories outside the UK or the EU will only be transferred where we have put in place appropriate safeguards to protect your personal data usually through contracts approved by the European Commission. 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 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.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on our website http://christchurchmayfair.org/privacy-notice/. If we make a significant change, we will notify you. This Notice was last updated in April 2018.
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, Christ Church Mayfair, Down Street, London, W1J 7AN
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.