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Privacy

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 data protection legislation (including the Data Protection Act 2018) as well as 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 Diocese of Southwark which is the data controller.  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 office-holders who work together to deliver the Church’s mission in each community.  The Diocese of Southwark works together with:

  • The Southwark Diocesan Board of Finance
  • PCCs of the parishes within the Diocese and the Incumbents of these parishes;
  • the bishops and archdeacons of the Diocese of Southwark; and
  • the National Church Institutions whose responsibilities include processing data to manage the stipends, salaries and pensions for clergy and some staff.

As the Church of England 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 of England 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 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 the Diocese of Southwark on our own behalf and on behalf of each of these other data controllers.  In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.

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 use of diocesan premises, 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 (sensitive) personal 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 personal data such as: racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, criminal records, fines and other similar judicial records.

How do we process your personal data?

The Diocese of Southwark complies with its 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 use your personal data for some or all of the following purposes:

  • To enable us to provide a voluntary service for the benefit of the public within the Diocese of Southwark
  • To enable us to meet all legal and statutory obligations (which, for example, include maintaining and publishing records in accordance with the Church Representation Rules 2017);
  • 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 administer records of

i)      Clergy

ii)     Readers

iii)    Southwark Pastoral Assistants

iv)    Youth Workers

v)     PCC & DCC Officers

vi)    Authorised Lay Ministers

vii)   General, Diocesan and Deanery Synod members

viii)  Cathedral, DBF and DBE Committee members;

  • To manage our employees and volunteers;
  • To fundraise and promote the interests of the Diocese;
  • To maintain our own accounts and records (including the processing of donations and Gift Aid applications);
  • To seek your views or comments;
  • 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).  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, carrying out our obligations under employment, social security law or under Canon Law.

We may also process data if it is necessary for the performance of a contract with you.

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 within the Diocese of Southwark in order to carry out a service to other church members or for purposes connected with the Diocese.

Clergy contact details will be provided:

  • periodically to Crockford’s Clerical Directory
  • When necessary, by the Diocesan Property Department to its representatives for the purpose of undertaking works of repair to Diocesan clergy housing and the letting of Diocesan properties
  • To the relevant local authority (in respect of Council Tax) and utility companies (in respect of supplies of energy to the property
  • In compliance with our legal responsibilities

There may be other legal entities we share data with within the Church of England who are also data controllers, including our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software.

How long do we keep your personal data?

We keep data in accordance with the guidance set out in the guide “Save or Delete: the Care of Diocesan Records” which is available from the Church of England website at https://www.churchofengland.org/more/libraries-and-archives/records-management-guides. We will keep some records permanently if we are legally required to do so. 

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 be informed

Individuals have the right to be informed about the collection and use of their personal data.

2.  The right of access

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.

3. The right to correct and update the information we hold on you (rectification)

If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated

4. The right to erasure

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)

 5.  The right to restrict processing

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.

 6.  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.

7.   The right to object to processing of data where applicable

8.   Rights in relation to automated decision making and profiling.

 

Transfer of Data Abroad 

Any electronic personal data transferred to countries or territories outside the European Economic Area (EEA) 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 Privacy 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 Protection Officer
Email: data@southwark.anglican.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.