Privacy Policy

Website privacy notice

 

INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data 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, text, 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 legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • User Data that includes data about how you use our website and any online services (e.g. Social Media) together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and social media presence.
  • 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 analyse your use of our website and other online services, to administer and protect our organisation and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our outreach. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our organisation.
  • 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; 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 Customer Data, User Data, and Technical Data to deliver relevant website content and information to you (including Facebook adverts, emails that you opt into, or other display materials) and to measure or understand the effectiveness of the content we serve you. Our lawful ground for this processing is legitimate interests which is to reach out to the wider community. We may also use such data to send other communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely our mission and outreach programme).

 

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 requirement, 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.
  • 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 contacting us 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 our legitimate interests which in this case are to reply to communications sent to us and to support you 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.

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 process your personal data without your knowledge or consent where this is required or permitted by law.

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 analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google 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 made a purchase or asked for information from us about our goods or 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 St Eustachius’, St Paul’s and St Michael’s; the Deanery of Tavistock and the Diocese of Exeter
  • 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, and Google Suite who provide webmail services to our volunteers).
  • Professional advisers including our bankers (TSB), independent financial examiners and insurers (Ecclesiastical)
  • 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 European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the 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 European Commission have approved as providing an adequate level of protection for personal data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

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.

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:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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.