Introduction
This is the privacy notice for Freedom Church Hereford (charity
number 1161926). It covers how we will process (collect, use and
store) your data, what data we hold, your individual rights and how
you can interact with us about your data.
This policy 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, photograph, video, email address, or
postal address). Identification can be by the information alone or in
conjunction with any other information.
Our processing of personal data is 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).
Who are we?
This privacy notice is provided to you by Freedom Church Hereford
(charity number 1161926), which is the data controller for your data.
This means it decides how your personal data is processed and for
what purposes.
Our policy for processing your personal data
Your privacy is really important to us, and we understand how
important it is to you. Freedom Church is committed to the privacy of
all its members, former members and those who have regular
contact with us in conjunction with those purposes, including those
who attend the church's events and use our ministries.
The church complies with its obligations under the General Data
Protection Regulations (GDPR) by keeping personal information up
to date; by storing and destroying it securely; by not collecting or
retaining excessive amounts of information; by protecting personal
information from loss, misuse, unauthorised access and disclosure
and by ensuring that appropriate technical measures are in place to
protect personal information.
How is your data used and processed?
Freedom Church processes data containing:
Names, aliases and photographs;
Contact information, including telephone numbers, postal 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,
and dependants;
Where you give financially in support of Freedom Church or pay for
church activities (event bookings, etc.), financial identifiers such as
bank account numbers, payment card numbers,
payment/transaction identifiers, policy numbers, and claim numbers;
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.
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 officer. For clarity, the term data
processor covers all employed staff members, office holders and
trustees for Freedom Church.
How do we use / process your personal data?
We only hold data that either we are legally obliged to or that helps
us fulfill our missional and charitable aims as a church. We will hold
and process data to:
Enable us to meet all legal and statutory obligations;
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
gravely ill or bereaved);
Deliver our church's mission to our communities, 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 our records of adult and child members;
To manage our employees and volunteers;
Enable us to follow up 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 your views or comments;
Update you about changes to our events, role holders and any
matters of interest related to the church community;
Send you communications which you have requested and that may
be of interest to you. These may include information about
campaigns, appeals or other fundraising activities;
Process a grant or application for a role;
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 membership records, safeguarding our
children, recording our financial donations and operating team rotas
for the effective function of Sunday events.
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 membership 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.
Sharing your personal information
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):
Our agents, servants and contractors. For example, we utilise
commercial providers to send out newsletters on our behalf, to
maintain our database software and for event booking;
On occasion, other churches with which we are carrying out joint
events or activities.
How long do we keep your personal data?
Our general rule is to keep data no longer than necessary. Where
you continue to actively engage with our church events and
activities, we will retain the appropriate data for you so that we can
best serve your involvement. We operate an annual review process,
by which we assess who is actively engaging in church membership,
and where this is not the case we will remove your data.
Additionally;
We will keep some records permanently if we are legally required to
do so. For example this covers 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 seven years to support HMRC audits.
Your rights and personal information
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 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 also have access
as a church member to be able to update aspects of your personal
data directly via our member's portal, My ChurchSuite (coming soon).
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 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. 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 telephone, email, or by post (see
contact details below).
The right to lodge a complaint with the Information
Commissioner's Office. You can contact the Information
Commissioner's Office on 0303 123 1113, via email at
https://ico.org.uk/global/contact-us/email/ or at the Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF.
Further processing
If we wish to use your personal data for a new purpose, not covered
by this 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.
Data Deletion
To delete your personal data please send an email to app@freedomchurch.cc We will delete your personal data and related content. After deletion, it will take 90 days for your personal data to be fully removed from our backups. For the avoidance of doubt: After such deletion and removal from backup no copies of data and its content shall survive, and you accept that such information cannot be subsequently restored.
Contact Details
We can provide you access to your personal data at any time. We
ask that requests are made in writing to the Data Protection Officer,
Freedom Church, The Forge, 161 Holme Lacy Road, Hereford, HR2
6DG, or via email to dpo@freedomchurch.cc.