Nov 2024 Ad Clerum post Makin Review

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 Bill/Act 2017 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 is provided to you by the Bishop of Ebbsfleet who is the data controller for your data.

What data do the data 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 events or publications, financial identifiers such as bank account details;
• Information about use of our website, this includes data provided using Google Analytics which uses cookies to track statistical information about users – this is generally anonymised but could possibly contain personally identifiers in some cases;
• Information supplied by those signing up to use the clergy portal on our website;
• The data we process is likely to constitute sensitive personal data because, as a bishop in the Church of England and his staff, 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 sensitive personal data such as that relating to health, family circumstances, contained in CVs and relating to ministerial development reviews and clergy disciplinary measure cases.

How do we process your personal data?

The data controller will comply with legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data. We may use the online ChurchSuite system to store data. You may wish to read their privacy policy to find out more information on how they meet the GDPR. We have carried out a data audit and website audit concerning personal data processing. The results of both of these can be obtained from the Bishop of Ebbsfleet’s office.

We use your personal data for some or all of the following purposes:

• To enable us to meet all legal and statutory obligations;
• To carry out comprehensive safeguarding procedures in collaboration with the relevant Diocese (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 and to organise and perform ecclesiastical services for you;
• To deliver the Church’s mission, and to carry out any other voluntary or charitable activities as provided for in the statutory framework of the data controller;
• To promote the interests of the Bishop of Ebbsfleet and the Church of England;
• To maintain our own accounts and records;
• To process a donation that you have made;
• 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 and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities;
• To process a grant or application for a role;

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). We will always take into account your interests, rights and freedoms.

Some of our processing is necessary for compliance with a legal obligation including Canon Law and Church of England rules.

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. An example of this would be processing your data in connection with the providing a service to you.

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.

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 or where you first give us your prior consent. We use the ChurchSuite database system to store information and to perform functions on our behalf. 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, and persons or organisations operating within, the Church of England;
• Our agents, servants and contractors. For example, we have a commercial provider who maintains our website. Our website is fully GDPR compliant: we have implemented an SSL Certificate provided by Cloudflare – a service which provides security and performance features to a wide network of websites. The website runs from UKFAST fully complaint servers. Further details are available on request.

How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so. 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 to support HMRC audits. In general, we will endeavour to keep 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.

1. 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 the information from. Once we have received your request we will respond within one month.
   • There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
2. The right to correct and update 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.
3. 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)).
4. The right to object to processing of your data
   • You have the right to request that we stop processing your 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 data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
5. The right to data portability
   • You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
   • You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioner’s Office.

Transfer of Data Abroad

Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.

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.

Contact Details

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, Bishop of Ebbsfleet’s Office, The Old Vicarage, 29 St John’s Meadow, Blindley Heath, Lingfield, Surrey RH7 6JU
Email: 
Telephone: 01342 834140

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