Data Protection Policy
Created: April 2019
Approved: April 2019
Bristol CCRC Trust (“the church”) is committed to protecting and respecting privacy. This statement explains when and why the church collects personal information about people who visit, connect with us on social media or through our website, how we use it, the conditions under which it may be disclosed to others and how it is kept securely.
The church will review and update this statement as necessary. By using our website, or connecting with the church through any other available touchpoint the church takes this as an implicit agreement to be bound by this statement and data protection policy.
1. The collection of personal information
Personal information is obtained when someone engages with the website, signs-up for an event or group, registers a child for a kids group, completes a ‘Connect Card’, gives financially, or applies for a paid or volunteer position with the church.
2. What type of information is collected?
The personal information gathered by the church will usually include:
first and last names
phone / mobile numbers
attendance information at events, groups and meetings
information regarding which pages on the website are accessed, and when
3. How is the information used?
As a church, we hold records of the people in our congregation, volunteers, guest and service users and use this information to coordinate church activities and to keep you informed of things happening in the life of the church.
We also collect and use information about our suppliers, contractors, the Church of England’s national and diocesan staff, and personnel working for relevant public bodies. This information is used to manage and administer the church and to carry out our charitable purposes. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Generally we do not rely on consent as a legal basis for processing your personal data other than when we collect Special categories of Data or in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on an unsubscribe link in one of our emails to you or by emailing firstname.lastname@example.org.
We have set out below a description of the ways we plan to use your personal data. St Nicholas collects and processes information so that we can:
Manage, administer and promote the life of the church
Manage, maintain and publish the electoral role in accordance with Church Representation Rules
Administer financial transactions and donations
Administer our courses or events
Manage our websites and social media accounts
Manage our volunteers and HR function
Prevent and detect crime
Where we need to comply with a legal or regulatory obligation
4. Who has access to the information?
All employed staff at the church have access to the personal information held in the church’s contact management systems. They have all been made aware of the legal requirements of GDPR and will abide by them when dealing with the personal information collected by the church.
The church will not sell any information to third parties.
5. Managing debit and credit card information
Third party service provides
We may pass your information to a third party associated organisation for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. The church will not release information to third parties, unless it has been requested, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Purchases, one-off and regular donations and event ticketing
If a purchase is made through the church (through giving via debt / credit cards by completing a gift envelope or when using the online payment system, or for the purpose of purchasing event tickets) card information is not held by the church. It is collected by third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions.
6. Gift Aid declarations, attendance and children’s registration
The church is legally required to hold some types of information to fulfil our statutory obligations.
In order for the church to be able to claim Gift Aid on donations, the church is required to keep a record of the information and permission granted by the giver. This information is held on ChurchSuite and is only accessible by a limited number of employees of the church.
The church also takes a weekly count of the number of people in attendance and this information is uploaded onto ChurchSuite. This is anonymous and names are not recorded.
16 or Under
The church registers all children whose parents have opted-in to involve them in the children’s ministry. This process forms part of the church’s safeguarding policy and we will hold this information on the system as long as is necessary according to Diocese of Bristol. Parents can ask for their child’s details to be removed from the database at any point.
We are concerned to protect the privacy of children aged 16 or under. Parent/guardian's must grant permission whenever personal information is provided.
7. ChurchSuite - data management system
ChurchSuite is the data management system used by the church to host and process all personal information of guests and members of the church, upon receipt of a completed Connect Card or welcome pack.
ChurchSuite is a cloud hosted, web based management system which complies with the principles of the General Data Protection Regulation (“GDPR”).
“Maintaining the security of your data is one of our highest priorities, and to this end, all access to ChurchSuite is over an SSL (https://) connection, which provides 256-bit military grade encryption to ensure that all data in transit between your web browser and ChurchSuite is fully encrypted.
Where we are required to store any usernames or passwords for third-party integrations, such as social media or communication channels, we will always encrypt these details before they are stored on our servers.
Once we have received any data and stored it on our servers, we make commercially reasonable efforts to ensure its security on our system. To this end, we have chosen to host our ChurchSuite servers in a data centre that meets some of the strictest of industry security requirements, and is classified as a Tier 2 data centre.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure, so whilst we strive to protect your personal information, unfortunately we cannot warrant the security of any information you transmit to us.”
This final paragraph applies to the transmission of data over the internet from any St Nicholas email account too.
8. Demographic information
Using management information tools on ChurchSuite, we may analyse personal information to understand demographics of those within the church, including address information. We do this to ensure that the charitable objectives of the church are being met and that what we provide is relevant for all types of people.
9. Use of 'cookies' on the website
It is possible to switch off cookies in the settings preferences. For more information on our full cookies policy click here. Turning cookies off may result in a loss of functionality when using the website.
For the purpose of keeping webstats and analysing how people interact with the website – for the purpose of improving it and making it fit for purpose, the church may use software that allows us to track IP addresses and ‘click’ interaction with the website.
10. Your legal rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.