Privacy Notice STATEMENT
[Ruach City Church, Charity Number: 1046218]
Data Controller: Ruach City Church, Charity Number: 1046218 known as Ruach
Data Protection Lead: Jacqui Heslop, Head of HR & Administration
Date of Notice: 21stMay 2018
Ruach City Church’s Partners (Members), Visitors, Volunteers and Employees are extremely important to us, and this Privacy Notice explains:
- how we will process (use, store and protect) your personal data;
- what data we hold and how we use them to provide services to you;
- your individual rights; and
- how you can interact with us about your data.
The privacy notice helps us offer you a better experience and demonstrate Ruach’s values in the service we provide to you:
- AIMFOR EXCELLENCE
- WORK TOGETHER
- ACT WITH INTEGRITY
- RESPECT YOU
- EMPOWER YOU
It also outlines what steps you can take if you would like us to change how we use your personal data, or if you would like us to stop using it altogether. We aim to be clear how we use your personal information, and not do anything you would not reasonably expect.
This Privacy Notice covers our use of Personal data, which is any information about a living individual, which allows them to be identified from that data. For example, a name, photographs, videos, email address, address, or identification number. Identification can be by the information alone or in conjunction with any other information.
Who are we?
This Privacy Notice is provided to you by Ruach City Church, Charity Number 1046218, which is the Data Controller for your data.
Ruach has appointed a number of responsible people for the control and processing of personal data that we hold. These post-holders will have ongoing training in GDPR requirements, and Ruach can provide a list of the individuals, upon request. For clarity, the term Data Controller covers all employed staff members, office holders and trustees for Ruach.
How do we protect your data?
Ruach is committed to protecting your personal data. All information you provide to us will be used in accordance with Ruach’s data protection policy.
Your personal data will be stored securely in our database hosted on a secure server within Ruach’s IT network. Access is restricted to staff and volunteers who need to see the data to carry out their duties at Ruach. User access rights to the database are restricted according to individual job roles in order to ensure that users only see information relevant to them. Data held on paper are secured in locked cabinets.
[Our processing of personal datais governed by the Data Protection Bill/Act 2017-2019 and the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998].
So, how is your data used and processed?
Ruach City Church processes data containing:
- names, titles, and aliases, photographs;
- Contact information including telephone numbers, postal /residential addresses, and email addresses;
- Where there is a legitimate interest to facilitate our charitable aims and activities, or where you have provided 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, dependants, next of kin and emergency details;
- Where you give financially in support of Ruach City Church or pay for church activities (e.g. event bookings etc.), financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, gift aid status (as required by HMRC);
- As a church (religious organisation), the data we process is likely to constitute sensitive personal data because the very 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 sensitive personal data: racial or ethnic origin, sex life, mental and physical health, details of injuries, medication/treatment received, political beliefs, data concerning sexual orientation and criminal records, fines and other similar judicial records.
For role holders and other requirements, we also process the following data:
- Non-financial identifiers such as passport numbers, driving license numbers, vehicle registration numbers, taxpayer identification numbers, employee identification numbers, tax reference codes, and national insurance numbers.
- Financial information such as salary, record of earnings, tax code, tax and benefits contributions, expenses claimed, car allowance (if applicable).
- Other operational personal data created, obtained, or otherwise processed in the course of carrying out our activities/duties, including but not limited to, CCTV footage, recordings of telephone conversations, IP addresses and website visit histories, logs of visitors, and logs of accidents, injuries and insurance claims.
- Other employee data (not covered above) relating toRole Holdersincluding emergency contact information; gender, birth date, referral source; performance management information, languages and proficiency; licences/certificates, citizenship, immigration status; employment status, retirement date, office location; publication and awards for articles, books etc.; prior job history, employment references and personal biographies.
As a Data Controller, all our appointed persons will comply with their 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.
If you have any concerns about how your data is being used, please contact our Data Protection Lead: Jacqui Heslop, Head of HR & Administration on firstname.lastname@example.org.
What are we doing with your data?
We only hold data that either we are legally obliged to or that helps us fulfil our missional and charitable aims as a church. We are a partner/membership organisation and good communication with our partners (members), visitors, volunteers and church community is an essential part of being a church.
Therefore, we will hold and process data to:
- Enable us to meet all legal and statutory;
- Comply with and facilitate our 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 (please see our safeguarding procedure);
- Help you grow as a disciple and to minister to you and provide you with pastoral and spiritual care, (such as visiting you when you are sick or bereaved), and to organise and perform church services for you, such as baptisms, baby dedications, weddings and funerals;
- Deliver our Church’s mission to our community, and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in the constitution and statutory framework of our charitable organisation;
- Administer and update our partnership (membership) and visitor records of adult and child partners (members) / visitors;
- Enable us to follow up partnership (membership), congregation, course and event enquiries;
- Fundraise and promote the interests of the Church and charity;
- Maintain our own accounts and records;
- Process and record financial donations that you have made, (including Gift Aid information);
- Communicate with you about our work and your views or comments;
- Update you about changes to our services, events, role holders and any matters of interest related to you our church community;
- Send you communications, which you have requested and that may be of interest to you. These may include information about events, courses, church updates campaigns, appeals, other fundraising activities;
- Process an application for a role; and
- Enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution.
Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
Additional data processing:
- We will process data about role holders for legal, personnel, administrative and management purposes, and to enable us to meet our legal obligations. For example to pay role-holders, monitor their performance and to discuss benefits in connection with your engagement as a role holder. “Role Holders” includes volunteers, employees, contractors, agents, staff, retirees, temporary employees, beneficiaries, workers and other role holders.
- We may process sensitive personal data relating to Role Holders including, as appropriate:
What is our legal basis for processing your personal data?
- Most of our data is processed because it is necessary for our legitimate interests to enable our charitable and missional aims. For example, maintaining partnership (membership) and visitor communication/records, safeguarding our children, recording our financial donations and operating team rotas for the effective function of Sunday services.
- Some of our processing is necessary for compliance with a legal obligation. Retaining safeguarding records and gift aid declarations are examples of this.
- We may also process data if it is necessary for the performance of a contract with you, or to provide a direct service to you. For example, if you buy tickets for a church event.
- As a religious organisation, we are permitted to process information about your religious beliefs to administer partnership (membership), visitor or contact details.
- Where your information is used, other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Will we share your data?
You can be reassured that we will treat your personal data as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- Appropriate bodies within our denominational structure. All of these bodies will be part of our church setup and have their own privacy policies.
- Our agents, servants and contractors. For example, we utilise commercial providers to send out information (e.g. event information) on our behalf, and to maintain our database software.
How long will we keep your personal data?
Ruach considers its relationship with Partners and Visitors etc. to be lifelong, and we will hold your details until you tell us you no longer wish to hear from us. Our general rule is to keep personal data no longer than necessary for the purposes for which it was collected, unless otherwise advised, and in accordance to Ruach’s records retention schedule. Where you continue to actively engage with our church services, activities and events, we will retain the appropriate partnership (membership) / visitor data for you so that we can best serve you.
We operate to an annual process of review, by which we assess who is actively engaging in church attendance or partnership (membership), and where this is not the case, we will contact you to confirm that your data will be removed. Any data that is deemed no longer required will be deleted or archived.
- We will keep some records permanently if we are legally required to do so. For example this covers wedding, baptism registers and some safeguarding records.
- We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits.
Your Communication Preferences
We may contact you by the following:
- Post; or
- Social Media
You can manage the ways we contact you by registering on Ruach’s Consent Portal and updating your preferences or completing a consent form. Details of this will be provided to you or can be requested by sending an email to: email@example.com.
Ruach will request your consent as the legal basis for processing, where this is not overridden by the interests and rights or freedoms of the data subjects concerned. We recognise that this is not the only lawful ground for processing data.
Your personal information will be used to provide any services you have requested and to keep in touch with you. We may communicate with you about the following:
- Ruach updates and news;
- Invitations to events/activities;
- Ways to get involved;
- Services you have requested or that may be of interest;
- Administrative purposes;
We will ask for your consent to contact you for specific purposes and will only contact you through the communication channels you have consented to. Unless you have requested otherwise, your data is used and processed for the full range of supporter activities and programmes, and all relevant communications, marketing and fundraising activity. Note that we may have to contact you for a reason where your consent is not required, for example to comply with the law, or to fulfil a contractual obligation.
Where do we collect the data from?
The majority of the data we hold is obtained directly from you, for example when you:
- Make a donation to Ruach (Ruach does not store any credit/debit card details);
- Register for an event;
- Complete an application/registration form or other forms;
- Contact us with an enquiry;
- Complete a survey;
- Volunteer at Ruach;
- Attendance registers;
- Apply for a job with Ruach;
- Are a church leader and/or have a key role at Ruach working in partnership with us;
- Purchase goods or services from us;
- Otherwise provide us with personal information.
We may also collect information from other sources, for example:
- We may use the Royal Mail’s postcode finder or PCA Predict to check the accuracy of the address we hold;
- Information made available publicly by Charity Commission, Linked In, social media etc.
What are your rights in regards to 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.
- The right to be informed
Via this Privacy Notice
- The right to access information we hold on you.
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.
- The right to correct and update the information we hold on you.
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated. You will also have access, going forward, as a church partner to be able to update aspects of your personal data directly via our partners (members) portal (ThankQ).The right to have your information erased.
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)).
- The right to object to processing of your data.
You can change your communication preferences at any time or restrict how we process your data. 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. We will also advise how this may affect our service to you. 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.
- 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.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
You can withdraw your consent easily by the consent portal on ThankQ, email (firstname.lastname@example.org), telephone (020 8678 6888 – option 1), or by post (Ruach City Church 122 Brixton Hill, London SW2 1RS).
- The right to lodge a complaint with the Information Commissioner’s Office. 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.
Third Party Partners
Your data will not be disclosed to external organisations other than those acting as agents for Ruach City Church. We always make sure there are appropriate controls in place so that your data will remain secure. We will never sell, trade or give away your data.
Unless we have a legal obligation to do so, we will not disclose your data to individuals, organisations or other entities outside Ruach other than those which are acting as agents for Ruach (for example, if we use a company to print and send out documents). All external partners with whom data are being shared and to whom we are not legally bound must sign a contract and/or confidentiality and non-disclosure agreement before any data transfer takes place.
We may need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies) or if we have your permission to do so.
Tools may be used to help us improve the effectiveness of Ruach’s communications with you, including monitoring website visits and using tools such as Google Analytics to improve our website and services.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU 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, however it is our general practice not to publish any personal data on our website or in our printed newssheets.
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.
Changes to this Privacy Notice
We keep this Privacy Notice under regular review and we will place any updates on our website: https://www.ruachcitychurch.org/policies/.
This Privacy Notice statement was last updated in May 2018.
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You are very welcome to get in contact with us
If you have any queries or concerns about how we use your data, please do get in contact with us.
Our Data Protection lead is Jacqui Heslop, Head of HR & Administration and can be contacted at:
Tel: 020 8678 6888 – option 1
Address: Ruach City Church 122 Brixton Hill, London SW2 1RS