INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data, including through your use of our site www.brentorchurch.org.uk.
By providing us with your data, you warrant to us that you are over 13 years of age.
Brent Tor PCC is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
Our full details are: Brent Tor PCC, the body responsible for the churches of St Michael de Rupe and Christ Church in the Anglican Parish of Brent Tor.
Full name of legal entity: Brent Tor Parochial Church Council
Email address: churchwardens@brentorchurch.org.uk
Postal address: C/O The Parish Office, 5a Plymouth Road, Tavistock PL19 8AU
Telephone number: 01822 810845
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at data@brentorchurch.org.uk.
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, SMS, WhatsApp, post, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our that by communicating directly with us you have given us Consent to process that data for the purpose of replying to you. Furthermore, this data may be retained for archiving purposes in the public interest or, if you are a contractor or service provider, in order to administer the Contract.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to detect and prevent criminal attacks on our systems, using the new Recognised Legitimate Interest basis.
- Photographic event data that includes pictures of persons at events. We process this data to maintain a photographic record of events, and to produce images for our website and other offerings. Our lawful ground for this processing is our Legitimate Interests, to maintain a photographic archive of public events. This information may be archived, meeting the requirements of an archiving purpose in the public interest. If we wish to use these images publicly our lawful ground is Consent which we will obtain from all persons who are identifiable in photographs, or their parents/guardians if under 13 years of age.
- We may use Technical Data to deliver relevant website content and information to you, and other datasets (e.g. those administered by Meta as a co-controller) to deliver social media posts to your feed.
- In some situations, you may opt into emails from us in, in which case we will use your Communications Data to send you emails. You must have opted in to contact us, but thereafter, we may use the lawful ground of Legitimate Interests to reach out to the wider community. We may also use such data to send other communications to you, while providing you with the opportunity to opt out of any such communications with every message or email.
Sensitive Data
We need to collect the following sensitive data about you in order to assist you in seeking pastoral support and to meet our legal duties:
- Congregation data that includes data about who is on our Electoral Roll, and who is present at meetings and some events. The numbers of worshippers at services are also recorded, but not by name (and therefore do not comprise Personal Data), however, regular worshippers in the Parish are recorded. We process this data to report attendance to the Diocese, and to ensure that persons on the Electoral Roll, and the PCC are accurately recorded. Our lawful ground of processing is that of a Legal Obligation, as set out in Canon Law and the Church Representation Rules. Our specific exemption for processing this potentially sensitive data falls under Article 9(2)(d), in that it is governed by the Church of England and this data does not leave the Church of England without consent.
- DBS data includes information that is gathered as part of DBS checks on volunteers and officials, and which may include criminal records data. Our legal basis for processing this information is Explicit Consent (Article 9(2)(a)) as the data subject must agree to this processing; in addition, we have a Legal Obligation to enforce this. While the data subject can opt out of the process, they cannot hold a formal office in the PCC or work with vulnerable adults or children in the absence of this information, as per our legal obligations under current Canon Law and the Church Representation Rules, as well as the binding directions from the Archbishops’ Council on Safeguarding.
- Safeguarding data – we may from time to time process personal and sensitive information received regarding the safeguarding of children and vulnerable adults. This may take the form of a Safeguarding Disclosure or allegations being made. At this time there is no Legal Obligation on us to process this data. However, we would take action and process this data so as to safeguard the Vital Interests (including the condition as laid down in Article 9(2)(c)) of the vulnerable data subject or other vulnerable person.
- Photographic service data that includes pictures of persons at services. We process this data to maintain a photographic record of services, and to produce images for our website and other offerings. Our lawful ground for this processing is our Legitimate Interests, to maintain a photographic archive; if we wish to use these images publicly our lawful ground is explicit consent which we will obtain from all persons who are identifiable in photographs, or their parents/guardians if under 13 years of age. This may reasonably be perceived as Sensitive as it relates to religious observance, and our specific exemption for processing this potentially sensitive data comes under Article 9(2)(e) in that processing relates to personal data which are manifestly made public by the data subject.
- Financial data that includes details of any Gift-Aided donations, standing orders etc. We process this data to receive your donation and, where relevant, to reclaim gift aid for the church from it. Our lawful ground for processing is consent, which you have given by filling out the gift aid declaration or making a standing order or other donation. Our specific exemption for processing this sensitive data comes under Article 9(2)(a) in that by providing the information for us to claim gift aid or other financial information, you have provided explicit consent for us to do so.
- Pastoral data that includes data about persons who seek pastoral or spiritual guidance or assistance. We process this data in order to put you in touch with a suitable member of the Ministry Team under the guidance of the Incumbent. Our lawful ground for this processing is Consent which in this case are to reply to communications sent to us and to support you as – and only as – you request it. Our specific exemption for processing this sensitive data comes under Article 9(2)(a) in that by contacting us you have provided explicit consent for us to do so. In some cases, it may become known that someone might be in need of pastoral care through a third party. In this case, our offer of care will utilise the legal basis of Legitimate Interests, under the condition of Article 9(2)(d), as the information will not be shared outside of the Church of England and dependent bodies (including BMCN, where appropriate)
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to provide website content to you on request).
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at data@brentorchurch.org.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may only process your personal data without your knowledge or consent where this is required or permitted by law; furthermore, in most situations we will only do so if it is held to be in your own interest.
We do not carry out automated decision making or any type of automated profiling.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails, or being physically present at a service or event).
We may receive limited (usually anonymised) personal data from third parties such as advertising networks such as Facebook based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
COMMUNICATIONS
Our lawful ground of processing your personal data to send you communications is either your consent or our legitimate interests (see above).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you asked for information from us about our services or (ii) you agreed to receive our communications and in each case you have not opted out of receiving such communications since.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at data@brentorchurch.org.uk.
If you opt out of receiving communications this opt-out does not apply to personal data provided as a result of other grounds as specified above.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- The Church of England more widely, specifically the Benefice (of Bere Ferrers with Bere Alston, Brent Tor, Gulworthy, Mary Tavy, Peter Tavy, Tavistock and Whitchurch); the Deanery of Tavistock and the Diocese of Exeter, for purposes set down in law, for safeguarding, and for pastoral care.
- Service providers who provide IT and system administration services (our Data Processors – JustHostMe Ltd who supply our website and emails servers, Sync.com who provide document storage and archiving services, WordFence who provide security services, Google LLM who provide webmail services to our volunteers and officers, Clearly Simpler who process our Safeguarding Dashboard info, and 31:8 who handle DBS checks on our behalf).
- Professional advisers including our bankers (TSB), independent financial examiners and insurers (Ecclesiastical), for compliance with our responsibilities as an Excepted Charity.
- Government bodies that require us to report processing activities (the ICO, in the case of any Data Breaches).
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Countries outside of the UK do not always offer the same levels of protection to your personal data, so UK law has prohibited transfers of personal data outside of the UK unless the transfer meets certain criteria. Countries within the European Economic Area (EEA) meet these strict criteria, and so most data processing occurs within the jurisdictions of the UK and/or EEA.
Some of our third parties service providers are based outside the UK/EEA so their processing of your personal data will involve a transfer of data outside the UK/EEA.
Whenever we transfer your personal data out of the UK/EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the Information Commissioner has approved as providing an adequate level of protection for personal data, including the UK: US Safe Harbor Framework); or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the Information Commissioner which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we will request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those personnel who have a need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
Communication Data, User Data and Pastoral Data will be retained for 7 years and then deleted or anonymised, unless relating to a Contract still in force.
Technical Data is retained indefinitely for the prevention of fraud.
Congregation and Photographic Data is retained indefinitely as part of our archiving commitment.
Financial Data is retained for 20 years so as to help us to protect you against future HMRC investigation.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at data@brentorchurch.org.uk.
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 if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
COOKIES
Currently we do not utilise cookies. If in future we choose to do so, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, we will provide a cookie policy if we ever decide to use them.