Data Privacy Notice
The Parochial Church Council (PCC) of St Peter’s, Brighton
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 id governed by the General Data Protection Regulation (GDPR).
Who are we?
The PCC of St Peter’s, Brighton is the data controller. This means it decides how your personal data is processed and for what purposes.
St Peter’s Church Brighton is also affiliated to the following charities:
- Church Renewal Trust, a charity registered in England and Wales with number 1129661
- Church Revitalisation Trust, a charity registered in England and Wales with number 1174882
How do we process your personal data?
The PCC of St Peter’s, Brighton 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:
- To enable us to provide a voluntary service for the benefit of the public
- To provide church services, events and activities
- To administer membership records
- To fundraise and promote the interests of St Peter’s Brighton
- To manage our employees, interns and volunteers
- To maintain our own accounts and records (including the processing of gift aid applications)
What is the lawful basis for processing your personal data?
We rely on one or more of the following reasons in law which give us the right or the duty to process personal data:
- Consent: On occasion we seek explicit consent for us to process data, particularly data which is classified as sensitive. This may include processing of data regarding children and vulnerable adults.
- Legal obligations: Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.
- Legitimate interests: Our purposes are the provision of church services, events and activities. In accordance with these, we carry out processing in our capacity as a not-for-profit body with a political, philosophical, religious or trade union aim. This has the provision that: the processing relates only members or former members (or those who have regular contact with it in connection with those purposes), and your interests and fundamental rights do not override our legitimate interests.
A Legitimate Interest Assessment (balance test) has been conducted and documented.
Sharing your personal data
Your personal data will be treated as strictly confidential.
Personal data may be shared with our affiliated charities in line with our stated purposes and for internal administrative purposes.
We use trusted organisations as third-party data processors to carry out some of administrative and financial purposes and ensure through legally binding contracts that these organisations maintain complete confidentiality of your data and themselves comply fully with GDPR. We will only share your data with other third parties with your consent, or as required to comply with statutory obligations.
We generally use eternal third parties based within the European Economic Area (EEA) so their processing of your personal data will not involve a transfer of data outside of the EEA. This includes our main database provider, ChurchSuite.
Where we contract with external third parties with an international base, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. This includes Campaign Monitor (Australia).
Where we contract with providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. This includes MailChimp.
How long do we keep your personal data?
In general, we will only retain your personal data for a long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Church members: We keep data on people involved in St Peter’s and up to 2 years after a person has ceased to be involved with all aspects of our church life.
- Financial matters: Gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate.
- Parish registers: Information on baptisms, marriages and funerals permanently, as required by the church of England.
Your rights and your personal data
Unless subject to an exemption under GDPR, you have the following rights concerning your personal data:
- The right to request a copy of your personal data which the PCC of St Peter’s, Brighton holds about you.
- The right to ask us to correct any personal data if it is found to be inaccurate or out of date.
- The right to ask for your personal data to be erased where it is no longer necessary for us to retain such data.
- The right to withdraw your consent to the processing, where consent is used as a basis for such processing.
- The right to ask us to stop processing your data during any dispute about the accuracy or processing of your personal data.
- The right to lodge a complaint with the Information Commissioners Office.
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. When necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries or complaints, please contact the Data Manager at firstname.lastname@example.org or on 01273 698182.
You can contact the Information Commissioners Office on 0303 123 1113 or via email at https://ico.org.uk/global/contact-us/email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
This policy applies from 25th May 2018 and was updated on 23rd May 2018.
NHS Track and Trace
St Peter’s will temporarily use your information during the COVID-19 pandemic. Although we may already have your data, there are now additional reasons to collect the name and phone number of all visitors to our buildings in order to support the NHS Track and Trace service.
NHS Track and Trace helps the NHS to quickly identify people who may have been exposed to COVID-19 in order to reduce the spread of the virus. They do this by testing anyone with symptoms, tracing those who may have been in contact with that person and then alerting those contacts that they need to self-isolate.
We need your name, a contact number, the date of your visit and your arrival/departure time. If these is more than one person in the group, then one person can be the ‘lead member’ and only their information needs to be recorded plus the number in the group.
We will only pass on your details if the NHS contact us to say they need this data.
We will only keep this information for 21 days and will dispose of it after that time.
Website Specific Privacy Notice
The information you provide is intended to be used in the context of the website and the activities St Peter’s undertakes, and it’s not intended to be used outside that context.
When a registration and login facility is available, your details will be recorded and used to identify you in order to provide appropriate access to resources.
Other data may also be recorded (comments, contact information), which will be used in the context of the associated application.
The Internet works by sending information between serves and clients (e.g. browsers) identified with ‘IP Addresses’. The IP addresses are logged together with time, page requested and browser type as part of the site’s normal operation and are used to record general activity on the site. No direct personal information is stored.
Cookies are small pieces of data that are used internally by the web application software to maintain sessions and in some cases to associate users with preferences on the site. Most browsers can report, block, or remove cookies, if you wish, though this can affect your experience of the site.
People provide information when signing up for different activities at St Peter’s (e.g. the Alpha course). We keep this information on the site for a limited period and send it to the people managing the activity.
All data is stored in the UK (except for a Twitter guest cookie, as mentioned in Google Analytics, and email list subscription and management information – which is stored in the US).
The website uses Google Analytics to determine how the site is used. Here is Google’s description of the privacy aspect of that:
The websites may contain links to other websites. St Peter’s Church is not responsible for the privacy policies of those sites, and we encourage you to read their privacy notices.