POLICIES

“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by [the Data Protection Bill/Act 2017 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].

SAINT is one church with multiple Church of England parishes, across East London, which work together in collaboration.

This Privacy Notice is provided to you by the Parochial Church Council (PCC) of the Parish of Hackney which is the data controller for your data.

The Church of England is made up of a number of different organisations and office-holders who work together to deliver the Church’s mission in each community. The PCC works together with:

• the incumbent of the parish;
• the PCC of the Parish of St Mary with St Edward and St Luke Leyton;
• The PCC of the Parish of St Leonard Shoreditch;
• The PCC of the Parish of West Ham;
• the bishops of the Diocese of London and the Diocese of Chelmsford; and
• the London Diocesan Fund and the Chelmsford Diocesan Board of Finance, which is responsible for the financial and administrative arrangements for the Dioceses of London and Chelmsford, respectively.

As the Church is made up of all of these persons and organisations working together, we may need to share personal data we hold with them so that they can carry out their responsibilities to the Church and our community. The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

Each of the data controllers have their own tasks within the Church and a description of what data is processed and for what purpose is set out in this Privacy Notice. This Privacy Notice is sent to you by the PCC on our own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.

They will process some or all of the following where necessary to perform their tasks:

• Names, titles, and aliases, photographs;
• Contact details such as telephone numbers, addresses, and email addresses;
• Where they are relevant to our mission, or where you provide 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 make donations or pay for activities such as use of a church hall, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim number
• The data we process is likely to constitute sensitive personal data because, as a church, the 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, labour union affiliation, genetic data, biometric data, data concerning sexual orientation and criminal records, fines and other similar judicial records.

The data controller 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.

We use your personal data for some or all of the following purposes:

• To enable us to meet all legal and statutory obligations (which include maintaining and publishing our electoral roll in accordance with the Church Representation Rules);
• To carry out 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;
• To minister to you and provide you with pastoral and spiritual care (such as visiting you when you are gravely ill or bereaved) and to organise and perform ecclesiastical services for you, such as baptisms, confirmations, weddings and funerals;
• To deliver the 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 each data controller;
• To administer the parish, deanery, archdeaconry and diocesan membership records;
• To fundraise and promote the interests of the Church and charity;
• To maintain our own accounts and records;
• To process a donation that you have made (including Gift Aid information);
• To seek your views or comments;
• To notify you of changes to our services, events and role holders;
• To send you communications which you have requested and that may be of interest to you. These may include information about church events, church ministries, campaigns, appeals, other fundraising activities;
• To process a grant or application for a role;
• To 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.

Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as another organisation in the Church of England). An example of this would be our safeguarding work to protect children and adults at risk. We will always take into account your interests, rights and freedoms.

Some of our processing is necessary for compliance with a legal obligation. For example, we are required by the Church Representation Rules to administer and publish the electoral roll, and under Canon Law to announce forthcoming weddings by means of the publication of banns.

We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the hire of church facilities.

Religious organisations are also 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.

Your personal data will be treated 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):

• The appropriate bodies of the Church of England including the other data controllers;
• Our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software;
• Other clergy or lay persons nominated or licensed by the bishops of the Dioceses of London and Chelmsford to support the mission of the Church in our parishes. For example, our clergy are supported by our area dean and archdeacon, who may provide confidential mentoring and pastoral support. Assistant or temporary ministers, including curates, deacons, licensed lay ministers, commissioned lay ministers or persons with Bishop’s Permissions may participate in our mission in support of our regular clergy;
• Other persons or organisations operating within the Dioceses of London and Chelmsford including, where relevant, the London Diocesan Board for Schools, the Chelmsford Diocese Board of Education and Subsidiary Bodies;
• On occasion, other churches with which we are carrying out joint events or activities.

We will keep some records permanently if we are legally required to do so. 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. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.

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.

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;

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.

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.

In compliance with UK Government guidelines we will be keeping temporary data records of those attending in-person services at any of our SAINT locations. We are doing this in order to assist NHS Test and Trace with requests for data if it is needed. This statement was last updated in April 2021.

We keep this Privacy Notice under regular review and we will place any updates on saint.church. This Notice was last updated on April 2021.

Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:

The Data Controller, Hackney Church House, 1 Prodigal Square, London E8 1FX

Email: hello@saint.church

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

HCEL intends to cooperate fully with the NHS Test and Trace service and will ask each attendee to provide certain details when booking tickets to HCEL events for this purpose. HCEL will keep a temporary record of attendees and those booking tickets to Hackney Church for 21 days and provide the data to the NHS Track and Trace service.

We will collect the minimum amount of personal data required in order to sensibly comply with government guidance, with reference to the point we collect such data (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace). we will collect the following:

• Name
• Phone number
• Date of attendance 
• Performance start time)

HCEL will not verify any individual’s identity for NHS Test and Trace purposes. HCEL will not ask individuals to provide us with any health information at any time. HCEL will remind individuals of our entry conditions to the church (which may involve a self-assessment by the individual of their health, along with other factors). HCEL will highlight that if the individual is feeling unwell, displaying any symptoms of Covid-19 or believe they could be refused entry to the theatre on the basis of their own self-assessment of their individual circumstances then they should not enter the theatre.

The data collected above for the NHS Test and Trace service will only be used for contract tracing and not for any other purpose.

HCEL will pass the data collected to the NHS Test and Trace service, which is operated by the DHSC, where requested. We will not supply such data to any other third party.

We will keep the data collected for a period of 21 days, in line with the government’s guidance on this issue. (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace#how-records-should-be-maintained). Once this retention period has ended we will securely delete the data.

Notwithstanding the above, the data collected for the NHS Test and Trace service may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you. Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.

We will keep all data safe as set out below in our privacy policy and you will have the same rights in respect of this data as you would in respect of any data we hold about you.

We are required to demonstrate that we have a GDPR-specified lawful basis for processing personal data collected for NHS Test and Trace. We have identified that this personal data is processed under the ‘legitimate interests’ basis, where the legitimate interest is facilitating contact tracing in respect of Covid-19 and the processing is necessary to achieve such interest given that the government has recommended these measures and we have procedures in place to protect the individual data providers’ interests, rights and freedoms.

If you require any further information regarding our collection of personal data in connection with the NHS Test and Trace service then please email us at GDPR@hcel.church.

This Privacy Notice is provided by Hackney Church Experiences Limited, the in-house venue programmers for Hackney Church. HCEL is your data controller. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by [the Data Protection Bill/Act 2017 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].

HCEL may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.  We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

HCEL will comply with our  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.

The personal data we collect from you includes:

• Your email address if you subscribe to our mailing list through our website, via email or via our ticketing agent.
• Additional data such as your phone number or your address if you include them when you contact us.
• How you interact with our emails from the mailing lists including; which links you click on and whether you open them.
• Google Analytics demographic information such as gender, location, age, which browsers you use or desktop vs mobile use.
• Any questions or feedback you contact us with.

Hackney Church Experiences will use your data in the following ways:

• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

• To notify you about changes to our service.

• If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.

• If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services. 

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

We will keep some records permanently if we are legally required to do so. 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. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed. We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. 

When assessing what retention period is appropriate for your personal data, we take into consideration: 

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

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.

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.

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.

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

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.

Any changes we may make to our privacy notice in the future will be provided to you by e-mail.

This privacy notice was last updated on 4 June 2018.

Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:

The Data Controller, Hackney Church Experiences Ltd, St John at Hackney Church, 1 Prodigal Square, London E8 1FX

Email: GDPR@hcel.church

You can contact the Information Commissioner’s 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