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Stanborough Park Church Data Protection Policy

Posted on 24 May, 2018

Stanborough Park Church Data Protection Policy

Introduction

The Stanborough Park Church needs to gather and use certain information about individuals. These individuals can include interests, volunteers, church members, suppliers, employees, or other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the Stanborough Park Church’s data protection standards and to comply with the law.

Purpose

This data protection policy ensures that the Stanborough Park Church:

  • complies with data protection law and follows good practice
  • protects the rights of those whose information is held and processed
  • is open about how it stores and processes individuals’ data
  • protects itself from the risks of a data breach

General Data Protection Regulation (GDPR)

GDPR describes how organisations, including the Stanborough Park Church, must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

GDPR is underpinned by six important principles. These say that personal data must be:

  • processed lawfully, fairly and in a transparent manner in relation to the data subject;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; inaccurate or outdated personal data should be deleted or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Scope

This policy applies to:

  • All staff and volunteers of the Stanborough Park Church.
  • All people working on behalf of the Stanborough Park Church.
  • All data that is held by the Stanborough Park Church, relating to identifiable individuals

Data Protection Risks

This policy helps to protect the Stanborough Park Church from some data security risks, including:

  • Breaches of confidentiality. For example, information being given out inappropriately.
  • Failing to offer choice. For examples, all individuals should be free to choose how the organisation uses data relating to them.
  • Reputational damage. For example, the Stanborough Park Church could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with the Stanborough Park Church has some responsibility for ensuring that data is collected, stored and handled appropriately. Each department or ministry that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

The Stanborough Park Church Board is ultimately responsible for ensuring that the Stanborough Park Church meets its legal obligations. However, there are specific responsibilities, as follows:

The Elders are responsible for:

  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff, members, and anyone else covered by this policy.

The Church Clerk is responsible for:

  • Dealing with requests from individuals to see the data the organisation holds about them (also called 'subject access requests').

The Stanborough Facilities Manager is responsible for:

  • Checking and approving any contracts or agreements with third parties that may handle the organisation's sensitive data.
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Evaluating any third-party services the organisation is considering using to store or process data. For instance, cloud computing services, social media, or other communication platforms.

The Communication director is responsible for:

  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

Department or Ministry Staff & Volunteer Guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from the Pastoral Team, the Church Clerk or the Elders.
  • The Stanborough Park Church will provide training to all employees and volunteers to help them understand their responsibilities when handling data.
  • Employees and Volunteers should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used, frequently changed, and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the organisation or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees and Volunteers should request help from the Elders or Church Clerk if they are unsure about any aspect of data protection.

Data Storage

The following rules describe how and where data should be safely stored. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees and Volunteers should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.
  • When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts.
  • Data should be protected by strong passwords that are changed regularly and never shared with anyone.
  • If data is stored on removable media (like a memory stick), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. These backups should be tested regularly.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data Use

Personal data is of no value to the Stanborough Park Church unless the Stanborough Park Church can use it to achieve the organisation's charitable objectives. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft. Therefore:

  • When working with personal data, employees and volunteers should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. It should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. 
  • Personal data should never be transferred outside of the European Economic Area unless the country has been approved by the Information Commissioner's' Office.
  • Employees should not save copies of personal data to their own computers. They should always access and update the central copy of any data.

Data Accuracy

The law requires the Stanborough Park Church to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees and volunteers who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a member's details when they call.
  • The Stanborough Park Church will make it easy for data subjects to update the information the Stanborough Park Church holds about them. For instance, via the Stanborough Park Church website.
  • Data should be updated as and when inaccuracies are discovered. For instance, if a member can no longer be reached on their stored telephone number, it should be removed from the database at that time.

Subject Access Requests

All individuals who are the subject of personal data held by the Stanborough Park Church are entitled to:

  • Ask what information the organisation holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the Stanborough Park Church is meeting its data protection obligations.

If an individual contacts the Stanborough Park Church requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the Stanborough Park Church. The information must be provided free of charge, though a reasonable fee may be charged when a request is manifestly unfounded or excessive, particularly if it is repetitive. The Stanborough Park Church must provide the relevant data information without delay and at the latest within one month of receipt. The Stanborough Park Church will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing Data for Other Reasons

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. In these circumstances, the Stanborough Park Church will ensure the request is legitimate, seeking assistance from the Church Board and from the South England Conference of SDA’s where necessary.

Providing Information

The Stanborough Park Church aims to ensure that individuals are aware that their data is being processed, and that they understand how the data is being used and how to exercise their rights. To these ends, the Stanborough Park Church has privacy statements, setting out how data relating to individuals is used by the Stanborough Park Church.

DATA PRIVACY NOTICE

Privacy Notice (employees)

We process personal data relating to those we employ to work as, or are otherwise engaged to work as, part of our workforce. We do this for employment purposes, to assist in the running of the charity and/or to enable individuals to be paid.

The personal data we process may include, but may not be limited to, the following:

  • data relating to your identity (including name, data of birth, gender, photographs, passport, National Insurance Number, immigration status, marital status, dependants),
  • contact details (business and home address, telephone numbers, email addresses, emergency contact details),
  • employment details (position, office location, terms of employment, performance and disciplinary records, sickness and holidays),
  • background information (CV, previous experience, qualifications and certifications, criminal records check (for vetting purposes, where permissible and in accordance with applicable law),
  • financial information (bank details, tax information, salary, benefits, expenses),
  • IT information – information related to your access to our systems (login details, IP addresses, log files, access/times/duration of use, location).

The collection of this information will benefit us by:

  • improving the management of workforce data across the business,
  • enabling development of a comprehensive picture of the workforce and how it is deployed,
  • informing the development of recruitment and retention policies,
  • allowing better financial modelling and planning,
  • ensuring compliance with our policies and procedures and our legal obligations,
  • enabling monitoring of selected protected characteristics.

We will not share information about you with third parties without your consent unless the law allows or requires us to do so.

Under the data protection legislation you have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress,
  • prevent processing for the purpose of direct marketing,
  • object to decisions being taken by automated means,
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed,
  • claim compensation for damages caused by a breach of the data protection legislation.

If you would like to find out more about our data retention policy and how we use your personal data, or if you want to see a copy of the information about you that we hold, please contact the Church Clerk, Stanborough Park Church, St Albans Road, WATFORD, WD25 9JL. 

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with the Church Clerk in the first instance, or directly with the Information Commissioner’s Office at: https://ico.org.uk/concerns

Privacy Notice (non-employees) 

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”).

2. Who are we? 

The Church Board of Stanborough Park Church, Watford is the data controller (contact details below).  This means it decides how your personal data is processed and for what purposes.

3. How do we process your personal data?

The Church Board of Stanborough Park Church, Watford 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 provide pastoral care to our members;
  • To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution; 
  • To administer membership records; 
  • To fundraise and promote the interests of the charity; 
  • To manage our employees and volunteers; 
  • To maintain our own accounts and records (including the processing of gift aid applications);
  • To inform you of news, events, activities and services running at Stanborough Park Church;
  • To share your contact details with the South England Conference office so they can keep you informed about news and events, activities and services that will be occurring in which you may be interested. 
  • To operate the Stanborough Park web site and deliver the services that individuals have requested.
  • To process gift aid applications.
  • To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.
  • Our processing also includes the use of CCTV systems for the prevention of crime.

4. 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, arrange for Pastoral visits, organise the operating of various church committees, process your gift aid donations and keep you informed about events.
  • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
  • 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. 

5. 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 Conference with your consent.

6. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the purposes in Section 3 above (How do we process your personal data?).

Specifically, we retain membership 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 church registers (baptisms, marriages, funerals) permanently.

7. 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: -

  • The right to request a copy of your personal data which the Church Board of Stanborough Park Church, Watford holds about you; 
  • The right to request that the Church Board of Stanborough Park Church, Watford corrects 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 the Church Board of Stanborough Park Church, Watford to retain such data;
  • The right to withdraw your consent to the processing 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.

8. 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.

9. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the Clerk to the Church Board of Stanborough Park Church, Watford at swan.patricia4@gmail.com. 

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.