DATA PRIVACY NOTICE

 The Parochial Church Council (PCC) of Henfield with Shermanbury and Woodmancote.

      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”).

      1. Who are we?

The PCC of Henfield with Shermanbury and Woodmancote is the data controller (contact details below).  This means it decides how your personal data is processed and for what purposes.

The Church of England is made up of a number of different organisations and officeholders who work together to deliver the Church’s mission in each community. The PCC works together with:

      • the incumbent of the parish (that is, our vicar)
      • the bishops of the Diocese of Chichester; and
      • the Diocesan Office of the Chichester Diocesan Fund and Board of Finance, which is responsible for the financial and administrative arrangements for the Diocese of Chichester.

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. The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data. Each of the data controllers have their own tasks within the Church 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 the PCC on our own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.

      1. 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 dependents;
      • Image – We may capture your image whilst filming a church service. A separate privacy notice for photography and filming in churches is attached in appendix 1 and is displayed in St. Peter’s Henfield.
      • Where you make donations or pay for activities such as use of a church hall, 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 sensitive personal data because, as a church, the fact that we process your data at all may be suggestive of your religious beliefs.
      1. How do we process your personal data?

The data controllers (e.g. The PCC of Henfield with Shermanbury and Woodmancote)  comply with their 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: –

      • 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, confirmations, weddings and funerals;
      • To enable us to provide a voluntary service for the benefit of the public in a particular geographical area (the parish) as specified in our constitution.
      • To fundraise and promote the interests of the charity;
      • To live-stream services from our church, online, in order to reach out to those who are unable to attend in person, or who wish to participate in our services remotely.
      • To seek your views or comments;
      • To manage our employees and volunteers;
      • To maintain our own accounts and records;
      • To process a donation that you have made; (including Gift aid information);
      • To inform you of news, events, activities and services running at St Peter’s, Henfield, St Giles’ Shermanbury and/or St Peter’, Woodmancote.
      • To share your contact details with the Diocesan office so they can keep you informed about news in the diocese and events, activities and services that will be occurring in the diocese and in which you may be interested.
      • Our processing also includes the use of CCTV systems outside Church House, Church Lane, Henfield, for the prevention and prosecution of crime.
      1. Where we collect data from.

We only collect data from you, where we have consent. Where we conduct ecclesiastical services for you or on your behalf, we may receive data from a funeral director.

      1. What is the legal basis for processing your personal data?
      • 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.
      • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
      • Processing is necessary for the performance of a contract; e.g in connection with the hire of Church facilities or advertising in the Parish Magazine.
      • Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union 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.
      1. 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 outside of the parish with your consent. This includes MailChimp for sending subscription e-newsletters.
      1. 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 [see footnote for link].

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.

      1. 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: – 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 request a copy of the personal data which we hold about you;
      • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
      • The right to request your personal data is erased where it is no longer necessary for us to retain such data;
      • The right to withdraw your consent to the processing of data at any time;
      • The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable)
      • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
      • The right to object to the processing of personal data, (where applicable)
      • The right to lodge a complaint with the Information Commissioners Office.
      1. 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.

11. Contact Details

To exercise all relevant rights, queries or complaints please in the first instance contact the Parish Administrator on 01273 495532.

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.

[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

APPENDIX

Photography and filming in churches – Privacy Notice

This privacy notice is provided to explain what to expect when we collect and process your personal information in relation to photography and/ or filming and streaming of church services in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

  1. The data controller is: The Parochial Church Council of Henfield with Shermanbury and Woodmancote,  St Peter’s Church, Church Lane, Henfield, BN5 9NY
  2. In addition to that already specified in our Data Privacy notice – which can be obtained on our website at https://henfield.org/policies-and-privacy-notice/ or is available from the Church office, personal information is collected for purposes of:
  • Recording and uploading, or live-streaming services from our church, online, in order to reach out to those who are unable to attend in person, or who wish to participate in our services remotely; and
  • Managing the consent forms in relation to the filming and streaming of church services on-line.
  1. The categories of personal data we collect are:
  • Image – We may capture your image whilst filming the church service.
  • Name and contact details – we will record your name and contact details provided on the consent form.

We also process “special categories” of information that may include:

  • Religious belief – By taking part in the service this may indicate religious belief.
  • Archiving – certain services may be retained permanently for historic purposes.
  1. We collect and use personal data using consent and explicit (written) consent.

By signing the Consent Form, you are consenting to us using your data for the purposes set out above.

You may withhold your consent by sitting in a “film free area” of the church before filming or photography starts.  These areas are the North and South Aisles of St. Peter’s, Henfield.  If you do not wish to be filmed receiving Holy Communion please tell one of the welcome team who will inform the clergy. Holy Communion will then be brought to you in your seat.

In the filming areas, once live-streaming or filming has started, or group photographs have been taken consent cannot be withdrawn because your data can’t be permanently removed from the internet, nor can a group video or photograph be edited to remove your image.

If you are a regular attendee, your consent will be renewed every 3 years, but you can withdraw your consent at any time to being filmed in future services by contacting the Parish Administrator as set out in section 9. below and sitting in the “film-free” area when attending church services if you do not want to be filmed. 

You may be asked to consent on behalf of children aged 16 years or under attending with you.  Please consider whether they would want their images to be uploaded to the internet.

5. We will be sharing photographs and recorded or live-streamed services with the public, by uploading it to social media and other internet sites, such as Facebook, Instagram etc.

  1. This means your data may be stored outside the UK. Each platform has its own privacy policy which describes how your data is used and protected.
  1. We will keep your data for up to 3 years, except for certain special services, which may be retained permanently for archival purposes.
  1. You have the following rights regarding your personal data:
  • Your right of access – You have the right to ask us for copies of your personal information.
  • Your right to withdraw consent – You have the right to withdraw your consent as described in section 4 above*.
  • Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete*.
  • Your right to request erasure – You have the right to ask us to erase your personal information in certain circumstances*.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances*.

*The rights to withdraw consent, or request erasure or restrict processing are limited, i.e. once the data is uploaded online, we are no longer able to erase or restrict the processing of individual images.  In addition, the right to rectification only applies to the processing of your name and contact details, it cannot apply to your image captured on film.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.  You can exercise your rights by contacting us at the contact details below.

  1. If you have any complaints or queries regarding this processing activity or wish to exercise your rights, please contact The Parish Administrator on 01273 495532 or admin@henfield.org or write to The Parish Administrator, St. Peter’s Church, church Lane, Henfield BN5 9NY

You have the right to make a complaint at any time to the Information Commissioner on 0303 123 1113 (local rate), or online at: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/