PRIVACY SUMMARY – 18 JULY 2022
The Parochial Church Council (PCC) of Holy Trinity Warrington is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures.
The data privacy notice below explains what information we gather about you, what we use it for and who we share it with. It also sets out your rights and who you can contact for more information or queries.
Data Privacy notice
- Purpose of this notice
This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.
In this notice:
- “Data Protection Legislation” means all applicable privacy and data protection legislation and regulations including the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (“PECR”), the Data Protection Act 2018 as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (“UK GDPR”) and any other applicable national laws, regulations and secondary legislation in the UK relating to the processing of personal data and the privacy of electronic communications, as amended, replaced or updated from time to time;
- “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; and
- “data controller”, “data subject”, and “process” have the meanings given to them in the Data Protection Legislation.
- Who we are
For the purpose of the Data Protection Legislation and this notice, we are the “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
The PCC of Holy Trinity Warrington is not required to appoint a data protection officer and has not done so. Our Church Wardens act as our Data Protection Point of Contact. They are responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 11 (Contact Us), below.
- How we may collect your personal data
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with Data Protection Legislation. Circumstances in which we may process your data include:
- you ask to become a member of our congregation (for example, join the electoral roll);
- you ask us to provide services (for example, to perform a baptism);
- you offer to gift funds through your bank account or by gift aid;
- you are employed by us;
- you contact us by email, telephone, post or social media (for example, when you have a query about our services);
- other people give it to us (for example, your current or former employer, another church, or third-party service providers that we use); or
- it is publicly available (for example, from social media platforms including LinkedIn and Instagram).
- The kind of information we might hold about you
The information we hold about you may include the following:
- your name, gender, age and date of birth
- contact information such as your address, email and mobile number;
- lifestyle and social circumstances (for example, your hobbies);
- family circumstances (for example, your marital status and dependents);
- employment and education details (for example, the school or college you attend, the organisation you work for and your job title);
- financial and tax-related information (for example your income, bank account details and PAYE deductions);
- details of contact we have had with you relating to the provision of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- details of how you like to interact with us, and other similar information relevant to our relationship;
- information we receive from other sources, such as other charities or publicly available information.
The personal data we collect may also include explicitly or implicitly so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:
- dietary requirements (for example, when we are preparing food for an event);
- health (for example, so that we can consider access when arranging events or meetings); and
- sexual orientation (for example, if you provide us with details of your spouse or partner).
We may also process personal data relating to ethnic or racial origin (for example, any multicultural networks you belong to and your first language), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).
We may seek separate permission from you in writing to process these special categories of personal data.
If you choose not to provide, or object to us processing, the information we collect, we may not be able to provide some or all of our services to you.
- How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our services and to comply with our legal obligations. This may include processing your personal data where you are a member of our congregation, a visitor to our building (for example, a coffee bar customer or visiting our building for an event), a member of another organisation noted at Annex A or one of our employees, independent contractors or suppliers.
We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for inviting you to events or sharing information about us.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
- administer membership records;
- fundraise and promote the interests of the charity;
- manage our employees and volunteers;
maintain our own accounts and records (including the processing of gift aid applications);
- inform you of news, events, activities and services running at Holy Trinity
- notify you about any changes to our services
- seek your thoughts and opinions on the services we provide; and
- 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.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Our lawful basis for processing
We rely on several lawful basis of processing when we collect and use personal data to operate our business and provide products and services to our clients. These include:
- you have explicitly agreed to us processing your information for a specific reason (for example, to keep you informed about news, events, activities and services and keep you informed about diocesan events);
- the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you (for example, recruitment processes);
- the processing is necessary for compliance with a legal obligation we have (for example, for under Ecclesiastical law, in relation to Gift Aid or under employment, social security or social protection law);
- the processing is in accordance with the legitimate interest of the PCC of Holy Trinity Warrington or a party named at Annex A or a third party, which may include:
- supporting and promoting the work of the Church of England;
- protecting our charitable interests;
- preventing fraud;
- ensuring that complaints are investigated;
- evaluating, developing or improving our services; or
- keeping you informed about relevant services and events and provide you with information, unless you have indicated at any time that you do not wish us to do so;
- the processing is necessary to protect the individual’s “vital interests”; and/or
- the 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 the consent of the data subjects.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet legal obligations imposed on us;
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. We retain personal data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available from the Record Management Guides located on the Church of England website at https://www.churchofengland.org/more/libraries-and-archives/records-management-guides.
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.
Change of purpose
Where we need to use your personal data for a reason other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.
- Data sharing
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required to do so by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. This may include sharing your personal data:
- with other members of Holy Trinity (“Church”) in order to carry out a service to other Church members or for purposes connected with the Church;
- within the Church of England, in order to carry out a service to other Church members or for purposes connected with the Diocese, and certain third parties as set out in Annex A;
- where it is necessary to administer the relationship between us; and
- where we have another legitimate interest in doing so – this may include sharing your personal data with a regulator or to otherwise comply with the law
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers, which includes some of the organisations noted at Annex A. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services (for example, insurance brokers, safeguarding advisers), administration services, and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
- Transferring personal data outside the United Kingdom (UK)
Whilst we store personal data on cloud servers within the UK, we may transfer personal data outside the UK to third parties that help us run our organisation. Contractual obligations are imposed on the recipients of any data transferred in order to to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.
- Data security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting our Data Protection Point of Contact using the contact details noted at paragraph 11 (Contact Us), below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes (for example, to invite you to an event).
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights please email our Data Protection Point of Contact using the contact details noted at paragraph 11 (Contact Us), below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In addition, you have the right to lodge a complaint with the Information Commissioners Office.
- Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to receiving the weekly notice sheet that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Point of Contact using the contact details noted at paragraph 11 (Contact Us), below.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- Contact us
The PCC of Holy Trinity Warrington is not required to appoint a data protection officer and has not done so. If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact the Churchwardens PCC of Holy Trinity Warrington using the contact details on our website at https://htwarrington.org.uk/contact/.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate)
Website – https://ico.org.uk/concerns
Church of England parties with whom data may be shared
The Bishops of Liverpool and Warrington
The Archdeacon of Warrington and St Helen’s
The other Archdeacons of Liverpool Diocese
Liverpool Diocesan Board of Finance
Liverpool Diocesan Board of Education
The Chancellor for the Diocese of Liverpool
The Diocesan Registrar
Holy Trinity Church of England School
The Parochial Church Council of Holy Trinity Warrington
Transform Northwest Network (known as Church Collective)
Other Diocesan bodies under Diocesan Synod that may be established from time to time and will be added to this list
The National Church of England Institutions
Other official Church of England organisations
Employees, office holders, volunteers, other recognised roles and contractors of the above offices and organisations.