Struthers Memorial Church
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 General Data Protection Regulation (GDPR), the Data Protection Act 2018 and other legislation relating to personal data and rights such as the Human Rights Act .
Who are we?
Struthers Memorial Church (SMC) is a company limited by guarantee incorporated in Scotland. It is also a registered Scottish Charity. Charity No. SC006960. Struthers Memorial Church’s headquarters is in Greenock, Scotland where the work started and we now have 11 churches throughout Britain. SMC employs a number of paid staff and relies greatly on the help and availability of a large number of
volunteers. A wide range of manual, administrative and professional skills are required to assist with the running of the organisation and many members of the various churches enthusiastically provide such help.
In addition, SMC runs three Bookshops/Coffeeshops and Cedars School of Excellence (CSE), which are all based in Scotland. CSE is an independent Christian School in Greenock catering for children from 5 to 18 years.
Struthers Memorial Church is the data controller for your data. For the purpose of this privacy notice, each church, Bookshops/Coffeeshops and CSE will be referred to as a ‘branch’. Each branch is made up of a number of different role-holders who work together to deliver the Church’s mission. They work together with:
- the Minister of each branch, where relevant;
- the Treasurer of each branch where relevant;
- the employees and volunteers of each branch; and
- the Directors of Struthers Memorial Church, who is responsible for the financial and administrative arrangements of the organisation’s activities.
As the Church is made up of all of these persons and branches working together, SMC may need to share personal data we held with them so that they can carry out their responsibilities to SMC and the community. This means we are all responsible to you for how we process your data.
Struthers Memorial Church is the data controller however; role-holders from each branch are required to follow SMC‘s data protection policies and procedures. This means we are all responsible to you for how we process your data.
Each of the branches has their own tasks within the organisation 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 on behalf of SMC and on behalf of each of its branches. In the rest of this Privacy Notice, we use the word “we” to refer to each branch, as appropriate.
What data does the data controller listed above process?
- Names, titles, and aliases.
- 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 licence 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, 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 (Bookshops/Coffeeshops only), IP addresses and website visit histories, logs of visitors, and logs of accidents, injuries and insurance claims.
- 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 possibly including racial or ethnic origin, 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.
SMC will process some or all of the following where necessary to perform its tasks:
- Names, titles, and aliases.
- 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, 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?
SMC will comply with it 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 those who undertake pastoral care duties as appropriate (e.g. visiting the bereaved);
- To enable us to meet all legal and statutory obligations;
- 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 our constitution and statutory framework;
- To minister to you and provide you with pastoral and spiritual care (such as visiting you when you are ill or bereaved) and to organise and perform church services for you, such as water baptisms, weddings and funerals;
- To administer the church membership database;
- To process a donation that you have made (including Gift Aid information);
- To fundraise and promote the interests of the church and charity;
- To seek your views or comments;
- To manage our employees and volunteers;
- To maintain our own accounts and records;
- 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. To keep you informed about events, activities and services at Struthers Memorial Church;
- To process an application for a role;
- To enable us to provide a voluntary service for the benefit of the public;
- Our processing also includes the use of CCTV (Bookshops/Coffeeshops only) 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. 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 to provide payroll details to third parties such as HMRC.
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 halls or equipment, travel and transport arrangements, etc.
We may also process data with your explicit consent so that we can keep you informed about news, events, activities and services and process your gift aid donations and keep you informed about church events.
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 privacy is important to us, and 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 SMC’s tasks or where you give us your prior consent. It is likely that we will need to share your data with
- The appropriate bodies including the other branches;
- Our agents, role holders and contractors;
- Other laypersons nominated by SMC to support the mission of the organisation in the community. For example, assistants who may provide confidential mentoring and pastoral support or support our ministers. Assistant or temporary ministers may participate in our mission in support of our ministers;
- Other persons or organisations, where relevant, to enable us to meet our legal obligations.
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 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
Unless subject to an exemption under the General Data Protection Regulation (GDPR), you have the following rights with respect to your personal data:
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 (e.g. HMRC) 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 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.
When exercising any of the rights listed above, 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.
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 may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Privacy 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 our notice board.
This Privacy Notice was last updated in January 2018.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant data protection rights or queries at:
Data Protection Officer
Struthers Memorial Church
33 West Stewart Street
Phone: 01475 729668
You can contact the Information Commissioner’s Office on 0303 123 1113 or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF or visit www.ico.org.uk.
Struthers Memorial Church is a company limited by guarantee incorporated in Scotland. Company No. SC335480. Registered Office: 33 West Stewart Street, Greenock, PA15 1SH. Struthers Memorial Church is a registered Scottish Charity. Charity No. SC006960.