The Diocese of Southwark including Nine Elms Arts Ministry

GENERAL PRIVACY NOTICE

Your personal data – what is it?

“Personal Data” is any information relating to an identified or identifiable natural living person, commonly referred to as the ‘data subject’. Identification can be by the information alone or in conjunction with any other information that the data controller may possess or be likely to obtain. The processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR) brought into force by the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

Who are we?

This Privacy Notice is provided to you by The Diocese of Southwark including Nine Elms Arts Ministry, as the data controller for your data. This means that it decides how your personal data is processed and for what purposes. In the rest of this Privacy Notice we use the word “we” to refer to the joint data controllers.

The Diocese of Southwark including Nine Elms Arts Ministry works together with:

 The Southwark Diocesan Board of Finance (DBF);

 The South London Church Fund;

 Bishops and archdeacons of the Diocese of Southwark

As the Church of England 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 of England 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. 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, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;

 The data we process may constitute sensitive personal data because, as a church-based organisation, 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 obligation 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; 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 may 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 Nine Elms Arts Ministry 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 Nine Elms Arts Ministry

 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 may also include 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 Southwark 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 Southwark including, where relevant, the Southwark Diocesan Board of Education, Southwark Cathedral and Subsidiary Bodies;

 There may be other legal entities we share data with within the Church of England who are also data controllers;

 On occasion, other churches or organisations 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 requestrequest, 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

The UK is a third country outside the European Economic Area (EEA). Any electronic personal data transferred either to countries or territories inside the European Economic Area (EEA) or to other third countries, will be subject to safeguards. The two safeguards employed by the Diocese including Nine Elms Arts Ministry are (a) sending data to countries deemed under UK law as offering an adequate level of data protection or (b) ensuring that recipients of your data are contractually obliged to protect your data using contracts approved under UK law. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas. We take all reasonable steps to ensure that your personal data is processed securely and will only transfer your personal data outside the United Kingdom where it is compliant with applicable data protection legislation or is part of a contract with specific individuals or organisations and the means of transfer provides adequate safeguards in relation to your personal data.

Changes to this notice

We keep this Privacy Notice under regular review and we will place any updates on www.nineelmsartsministry.org

This notice was last updated in June 2022

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.

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: Nine Elms Arts Ministry , c/o Revd Betsy Blatchley, Pioneer Minister in the Arts, Diocese of Southwark, Trinity House, 4 Chapel Court, Borough High Street, London SE1 1HW

Email:  betsy.blatchley@southwark.anglican.org

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.