Data Privacy

Parish of Cray Valley
St Andrew’s & St Mary’s


GENERAL PRIVACY NOTICE
Your personal data – what is it?
“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].


Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of the Parish of Cray Valley
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 (that is, our vicar);
• the bishops of the Diocese of Rochester; and
• the Diocesan Office, which is responsible for the financial and administrative arrangements for the Diocese of Rochester.

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.


What data do the data controllers listed above process? 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 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, 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.


How do we process your personal data?
The data controllers 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 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.
What is the legal basis for processing your personal data?
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.
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;
• 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 Diocese of Rochester to
support the mission of the Church in our parish. For example, our clergy are supported by our area
dean and archdeacon, who may provide confidential mentoring and pa storal 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 Diocese of Rochester including, where relevant,
the Rochester Diocesan Board of Education;
• On occasion, other churches with which we are carrying out joint events or activities.
How long do we keep your personal data?
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. 


Your rights and 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.
1. 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.
2. 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.
3. 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)).
4. 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.
5. 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.
6. 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).
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioner’s Office. 


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. 


Further processing
If we wish to use your personal data for a new purpose, not covered by this N otice, 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.


Contact Details
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, Parish of Cray Valley
Email: crayparish@outlook.com
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.
Parish of Cray Valley St Andrew’s & St Mary’s


PRIVACY NOTICE ROLE HOLDERS
(e.g. Churchwardens, PCC Secretaries, PCC Treasurers, Deanery Synod reps, Safeguarding officers etc.
See explanatory note on Privacy Notices on p.8)


Your personal data – what is it?
“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].


Who are we?
This Privacy Notice is provided to you by the Parochial Church Council (PCC) of Cray Valley 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 (that is, our [vicar or rector]);
• the bishops of the Diocese of Rochester; and
• the Diocesan Office, which is responsible for the financial and administrative arrangements for
the Diocese of Rochester.
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 has 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.


How do we process your personal data?
The data controllers 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 (for example some of the roleholders are volunteers and no financial information will be processed for these role holders): -
• To enable those who undertake pastoral care duties as appropriate (e.g. visiting the bereaved);
• 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 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 manage our employees and volunteers;
• To maintain our own accounts and records;
• 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 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;
• To share your contact details with the Diocesan office so they can keep you informed about news
in the diocese and events, activities and services that will be occurring in the diocese and in which
you may be interested.
• 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 confer benefits in connection with your engagement as a Role Holder.
“Role Holders” includes volunteers, employees, contractors, agents, staff, retirees, temporary
employees, beneficiaries, workers, treasurers and other role holders.
• We may process sensitive personal data relating to Role Holders including, as appropriate:
▪ information about an Role Holder's physical or mental health or condition in order to monitor
sick leave and take decisions as to the Role Holder's fitness for work;
▪ the Role Holder's racial or ethnic origin or religious or similar information in order to monitor
compliance with equal opportunities legislation;
▪ in order to comply with legal requirements and obligations to third parties.
• Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.


What data do the data controllers listed above 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, employment details, hobbies,
family composition, and dependants.
• 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 identifiers such as bank account numbers, payment card numbers, payment/transaction
identifiers, policy numbers, and claim numbers.
• Financial information such as salary, bonus, record of earnings, tax code, tax and benefits
contributions, expenses claimed, creditworthiness, car allowance (if applicable), amounts insured,
and amounts claimed.
• Other operational personal data created, obtained, or otherwise processed in the course of
carrying out our activities, 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 to Role Holders including emergency contact
information; gender, birth date, referral source (e.g. agency, employee referral); level,
performance management information, languages and proficiency; licences/certificates,
citizenship, immigration status; employment status, retirement date; billing rates, office location,
practice and speciality; publication and awards for articles, books etc.; prior job history,
employment references and personal biographies.
• 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.


What is the legal basis for processing your personal data?
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 rol l, 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.
We will also process your data in order to assist you in fulfilling your role in the church including pastoral
and administrative support or if processing is necessary for compliance with a legal obligation.
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.


Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties
including other data controllers where it is necessary for the performance of the data controllers’ tasks
or where you first give us your prior consent. It is likely that we will need to share your data with
• 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 Diocese of Rochester to
support the mission of the Church in our parish. 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 Diocese of Rochester including, where relevant,
the Rochester Diocesan Board of Education;


How long do we keep your personal data?
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.


Your rights and 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.
1. 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.
2. 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.
3. 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)).
4. 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.
5. 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.
6. 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).
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioners Office.


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.


Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection 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 notice
We keep this Privacy Notice under regular review and we will place any updates on this web page
standrewsatcray.org.uk. This Notice was last updated in November 2017.


Contact Details
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, The Parish of Cray Valley
Email: crayparish@outlook.com
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.
Cray Valley Parish
01689 823 775
St Andrew’s Church St Mary’s Church
Lower Road High Street, St Mary’s Cray
Orpington Orpington
Kent, BR5 4AL Kent, BR5 3NL
standrewsatcray.org.uk stmarysatcray.org.uk