The Stronghold uses personal data about living individuals for the purpose of general church administration and communication.
The Stronghold recognises the importance of the correct and lawful treatment of personal data. All personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the General Data Protection Regulation 2017
The Stronghold fully endorses and adheres to the eight principles of the GDPR. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for The Stronghold must adhere to these principles.
The principles require that personal data shall:
- Be processed fairly and lawfully and shall not be processed unless certain conditions are met.
- Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose.
- Be adequate, relevant and not excessive for those purposes.
- Be accurate and where necessary, kept up to date.
- Not be kept for longer than is necessary for that purpose.
- Be processed in accordance with the data subject’s rights.
- Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures.
- Not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
1. How we collect your information
Personal information is any information about someone which allows them to be identified. This includes names, address, phone number, email address, photographs, internet address, bank details, age, sex, interests, and sensitive information (see below).
We may collect personal information each time you are in contact with us. For example, if you:
- Provide your contact details, in writing or orally, to Church Staff
- Register your details and your family details, at https://TheStronghold.churchsuite.co.uk or similar software, or via an embedded form on our website or any social media we may operate
- When you attend church services or participate in other Church activities;
- Register for a conference or other Church event;
- Inform us of your interest in serving in particular areas
- Make a donation, through offering envelopes, text, website.
- Purchase goods/services, including when you provide bank card details;
- Communicate with the Church by means such as email, letter, telephone;
- Have face to face meetings with staff and volunteers;
- Visit our website;
- Access social media platforms such as Facebook, YouTube, WhatsApp, Twitter, Instagram (when applicable)
2. Maintaining Confidentiality
The Stronghold will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the leadership and ministry overseers/co-coordinators of the church in order to facilitate the administration and day-to-day ministry of the church.
All The Stronghold staff and volunteers who have access to Personal Data will be required to agree to this Data Protection Policy.
Appropriate handling of information you may have shared with church members, friends and aquaintences on a friendship basis is a private matter and it is not the responsibility of The Stronghold.
There are four exceptional circumstances to the above permitted by law:
- Where we are legally compelled to do so.
- Where there is a duty to the public to disclose.
- Where disclosure is required to protect your interest.
- Where disclosure is made at your request or with your consent.
3. How we use your Personal Information
The Stronghold will use your data for three main purposes:
1.The day-to-day administration of the church; e.g. pastoral care and oversight including calls and visits, preparation of ministry rotas, maintaining financial records of giving for audit and tax purposes.
2.Contacting you to keep you informed of church services, activities, resources and events, including those involving children and youth. Information communication methods include the website.
3.Statistical analysis; gaining a better understanding of church demographics. N.B. although collated church data may be passed to a third party, such as number of small groups or small group’s attendance, no personal data will be disclosed.
The lawful basisfor ‘processing’ your data is by your consent, though we may process under legitimate interest where a balancing test has been applied. Some types of information data (e.g. gift aid records or supplier information for the accounts) will be held as required by legal obligation or contract.
4. How we store and share information
Any IT systems and devices used will be password protected and access will be only to necessary data for the specific use. Access set up is controlled by the Data Administrator.
Personal information will not be passed onto any third parties outside of the church environment. Some third party service providers from time to time will be brought into the church environment to support efficient administration (such as mailing or survey providers or employment administration). They will all operate with security and privacy policies to protect your data. By providing us with your details you are giving the Church your express permission to transfer your data to any such service providers.
Information of a personal nature on a website or in a newsletter will not be produced without the consent of those involved.
We may keep some records for an extended period of time if we are legally required to do so. (e.g. financial records for 8 years). In general we will endeavour to keep data only for as long as we need it.
The Church may collect and store sensitive personal information(this is called Special Category Personal Information). This includes health information, religious information (church attendance), when you and/or your family attend or register for church events and conferences.
Your personal information will be kept strictly confidential. It is never sold, given away, or otherwise shared with anyone, unless required, by law.
Personal information of childrenwill be only held when consent is granted by those who hold parental responsibility for the child. We take the rights and risks of children into account when designing our prcedure for holding their information.
5. Your rights to access information
Subject Access - all individuals, including children, who are the subject of personal data held by The Stronghold are entitled to:
- Ask what information the church holds about them and why.
- Ask how to gain access to it.
- Be informed how to correct and keep it up to date.
- Be informed what The Strongholdis doing to comply with its obligations under the General Data Protection Regulation 2017
- Ask for use of your data to be restricted to certain purposes only
- Withdraw your consent for further processing
- Ask to have your information erased
Employees and other subjects of personal data held by The Stronghold have the right to access any personal data that is being held. This right is subject to certain exemptions: Personal Information may be withheld if the information relates to another individual.
Any person who wishes to exercise this right should make the request in writing to the The Stronghold Data Officer, using the standard letter which is available online from ico.org.uk (‘Your right of access’).
Please address all correspondance to:
The Data Protection Officer, The Stronghold,
Forster Avenue, Weaverham Northwich CW8 3BH
or emailing firstname.lastname@example.org
The Stronghold aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 30 days of receipt of a completed form unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.
version 1 July 2018