1. Your personal data – what is it?
Personal data is any information about a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by 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.
2. Who are we?
Blackburn Cathedral is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes. A description of what data is processed and for what purposes is set out in this Privacy Notice.
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 Cathedral works together with:
- the Bishops of the Diocese of Blackburn; and
- the Diocese of Blackburn, which is responsible for the financial and administrative arrangements for the Diocese of Blackburn including safeguarding.
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.
3. What data do we process?
- 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 our facilities, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
- 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, mental and physical health, details of injuries, medication/treatment received, labour union affiliation, data concerning sexual orientation and criminal records, fines and other similar judicial records.
4. How do we process your personal data?
Blackburn Cathedral complies with its obligations under the “GDPR” by:
- Keeping personal data up to date;
- By storing and destroying it securely;
- By not collecting or retaining excessive amounts of data;
- By protecting personal data from loss, misuse, unauthorised access and disclosure; and
- By ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for 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 in the parish, Diocese and beyond;
- To administer membership records for Cathedral activities and groups;
- To fundraise and promote the interests of the Church and charity;
- To maintain our own accounts and records;
- To manage our employees and volunteers;
- 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 inform you of news, events, activities and services at Blackburn Cathedral;
- To send you communications which you have requested and that may be of interest to you. These may include information about 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; and
- Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
5. What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests. 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 Cathedral facilities or employment contracts and volunteer agreements.
Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details. This will include former members.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use for instance to keep you informed about news, events, activities and services and to process your gift aid donations.
6. Sharing your personal data
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;
- Blackburn Cathedral Developments, Blackburn Cathedral Trust and the Friends of Blackburn Cathedral;
- Other clergy or lay persons nominated or licensed by the bishops of the Diocese of Blackburn to support the mission of the Church in our parish. 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 Diocese of Blackburn including, where relevant, the Blackburn Diocesan Board of Education;
- There may be other legal entities we share data with within the Church of England who are also data controllers; and
- On occasion, other churches with which we are carrying out joint events or activities.
7. How long do we keep your personal data?
We keep data in accordance with the guidance set out in the guide “Chapter and Verse – The Care of Cathedral Records” produced by the Church of England Record Centre which is available from the Church of England website at: https://www.churchofengland.org/more/libraries-and-archives/records-management-guides
Specifically, we retain electoral roll data while it is still current; gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate; it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits; and parish registers (baptisms, marriages, funerals) are kept permanently. 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.
8. Your rights and 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
- 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 object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
9. Transfer of Data Abroad
We take steps to ensure that where your information is transferred outside of the EEA, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations.
10. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data 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.
11. Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on the Cathedral website. This Notice was last updated in May 2018.
12. Contact Details
To exercise all relevant rights, queries of complaints please in the first instance contact the Cathedral’s Executive Director by email at firstname.lastname@example.org
Alternatively, 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.