Privacy Policy

Data Controller: Liberty Church, Registered Charity SC002865
Data Protection Lead: Fiona Farrimond, Adminstrator
Date of Policy: 24th May 2018

This is the privacy statement and data protection policy for Liberty Church.  It covers how we will process (use and store) your data, what data we hold, your individual rights and how you can interact with us about your data. If you have any questions about this policy you are welcome to get in touch with us. We are happy to help.

This policy covers our use of Personal data, which 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. 

Our processing of personal data is governed by the Data Protection Bill/Act 2017-2019 and 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 Liberty Church, Registered Charity Number SC002865, which is the Data Controller for your data.  For clarity, the term Data Controller covers all employed staff members, office holders and trustees for Liberty Church.

So, how is your data used and processed?

Liberty Church processes data containing:

• Names, titles, and aliases, photographs; 
• Contact information including telephone numbers, postal /residential addresses, and email addresses; 
• Where there is a legitimate interest to facilitate our charitable aims and activities, or where you have provided 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 give financially in support of Liberty Church or pay for church activities (event bookings etc.), financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers; 
• As a church (religious organisation), the data we process is likely to constitute sensitive personal data because the very 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, political beliefs, data concerning sexual orientation and criminal records, fines and other similar judicial records. 

As a Data Controller, all our appointed representatives will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; not to 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. If you have any concerns about how your data is being used, please speak with our Data Protection Lead.

What are we doing with your data?

We only hold data that either we are legally obliged to or that helps us fulfil our missional and charitable aims as a church. We are a membership organisation and good communication with our membership is an essential part of being church.

Therefore, we will hold and process data to: 

• Enable us to meet all legal and statutory obligations 
• Comply with and facilitate our 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 (please see our safeguarding procedure)
• Help you grow as a disciple and to minister to you and provide you with pastoral and spiritual care and to organise and perform ecclesiastical services for you, such as baptisms, weddings and funerals
• Deliver our Church's mission to our community, to the wider locality and to the ends of the earth 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 our charitable organisation
• Administer our membership records of adult and child members
• Enable us to follow up membership, course and event enquiries 
• Fundraise and promote the interests of the Church and charity 
• Maintain our own accounts and records
• Process and record financial donations that you have made (including Gift Aid information) 
• Communicate with you about your views or comments 
• Update you about changes to our services, events, role holders and any matters of interest related to the church community
• 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 
• Make grant applications and process applications for positions
• Enable us to provide a voluntary service for the benefit of the public  

 

What is our legal basis for processing your personal data? 

• Most of our data is processed because it is necessary for our legitimate interests to facilitate our charitable and missional aims. For example, maintaining membership records, safeguarding our children, recording our financial donations and operating team rotas for the effective function of Sunday services. 
• Some of our processing is necessary for compliance with a legal obligation. Retaining safeguarding records and gift aid declarations are examples of this. 
• We may also process data if it is necessary for the performance of a contract with you, or to provide a direct service to you. For example, if you buy tickets for a church event.
• As a religious organisation, we are 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. 

 

Will we share your data? 

We may use certain carefully selected agents, servants and contractors.  For example, we use a church website management company to host our website and database.  You can be reassured that we will treat your personal data as strictly confidential.  It will be shared with third parties only where there is a legal obligation (for example in the case of HMRC as regards Gift Aid claims); where it is necessary for the performance of our tasks (as in the case of agents, servants or contractors); or where you have given us your prior consent.

How long will we keep your personal data? 

Our general rule is to keep data no longer than necessary. Where you continue to engage actively with our church services, activities and events, we will retain the appropriate membership data for you so that we can best serve your involvement.  We operate to an annual process of review, by which we assess who is actively engaging in church membership.    If you have not been actively engaging for more than 24 months we will remove your data, unless you advise us that you wish to remain on our mailing list.  Additionally:

• We may keep some records permanently.  For example records of wedding and baptism services, and some safeguarding records. 
• We may keep some other records for an extended period of time.  For example, it is necessary to keep financial records for a minimum period of 7 years.  

 

What are your rights in regards to 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. 

• 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. You also have access as a church member to be able to update aspects of your personal data directly via our members’ portal. 
• 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 email, or by post (see Contact Details below). 
• The right to lodge a complaint with the Information Commissioner's Office. You can contact the Information Commissioner's Office on 0303 123 1113 or via email ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF. 

 

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, however it is our general practice not to publish any personal data on our website or in our printed newsletters. 

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. 

What else should you know about privacy, our website and other websites?

Remember to close your browser when you have finished your user session. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or internet cafe. You as an individual are responsible for the security of, and access to, your own computer.

Please be aware that whenever you voluntarily disclose personal information over the internet that this information can be collected and used by others. In short, if you post personal information in publicly accessible online forums, you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your usernames and passwords and any account information. Please be careful and responsible whenever you are using the internet.

Our pages may contain links to other websites, and you should be aware that we are not responsible for the privacy practices on other websites.

You are very welcome to get in contact with us…

If you have any queries or concerns about how we use your data, please do get in contact with us.    Our Data Protection lead can be contacted at:   

Liberty Church
Liberty Centre
Pitreavie Way
Dunfermline
Fife   KY11 8QS
Email:  office@libertychurch.co.uk       Tel:  01383 733970

Policy updated: 24th May 2018