Cogges Church Data Protection Policy

St Mary’s Cogges (“Cogges” or “the church”) uses personal data about living individuals for the purpose of general church administration and communication.

Cogges 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 Data Protection Act 1998.

Cogges fully endorses and adheres to the eight principles of the Data Protection Act. 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 Cogges must adhere to these principles.

  • Data Controller: St Mary’s Cogges Parochial Church Council
  • Data Protection Officer: James Webster

The Principles

Schedule 1 to the Data Protection Act lists the data protection principles in the following terms:

  1. Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless – (a) at least one of the conditions in Schedule 21 is met, and (b) in the case of sensitive personal data, at least one of the conditions in Schedule 32 is also met.

  2. Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.

  3. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.

  4. Personal data shall be accurate and, where necessary, kept up to date.

  5. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

  6. Personal data shall be processed in accordance with the rights of data subjects under this Act3.

  7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

  8. Personal data shall 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.

Source: ICO

Lawful Purpose

Cogges will use your data for three main purposes:

  1. The day-to-day administration of Cogges; 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 activities and events.
  3. Statistical analysis; gaining a better understanding of church demographics.

Applying the principles

  • All staff and volunteers who process Personal Data on behalf of Cogges will be required to agree to sign our Data Processor agreement.
  • The PCC will appoint the Church’s Data Protection Officer. All questions and concerns in relation to this policy should be addressed to them.
  • When personal information is collected we will ensure that
    • this information is necessary for church purposes
    • the information is not kept for longer than it is needed
    • those people supplying the information are aware of this policy and how they can obtain a copy
  • Personal information (including photographs) of individuals will not be published on our website without obtaining explicit and informed consent from the individuals concerned or their parents (unless that infomation is already in the public domain). We will never publish the names of children and young people alongside their photographs.
  • We will ensure that all church members and attendees are aware of who to contact to update the information held about them by Cogges.
  • A copy of this policy will be on our church website.
  • All personal information held by staff and volunteers on behalf of Cogges will be held and processed in a sufficiently secure manner (whether in paper or electronic form) to prevent unauthorised access (whether by unauthorised church staff or third parties). This means we will:
    • Store paper based information in secure, lockable cupboards
    • Use password protections and encryption of particularly sensitive electronic documents (all computers used to store sensitive information must be encrypted, any mobile devices capable of accessing sensitive information must use a keyboard lock)
    • Restrict access to both paper and electronic personal data to those who need to process it for one of the above uses
    • Ensure that personal information is transmitted securely in a way that cannot be intercepted by unintended recipients

Maintaining Confidentiality

Cogges will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the staff and leadership of the church in order to facilitate the administration and day-to-day ministry of the church.

Exceptions

The contact details of adult church members may be shared with other church members through the church database. Individuals may request that their information is not shared with other members.

There are four further exceptional circumstances to the above permitted by law:

  1. Where we are legally compelled to do so.
  2. Where there is a duty to the public to disclose.
  3. Where disclosure is required to protect your interest.
  4. Where disclosure is made at your request or with your consent.

The Database

Information contained on the database will not be used for any other purposes than set out in this section. The database is accessed through a remote server and therefore, can be accessed through any computer with internet access. The server for the database is located within the UK and managed by ChurchApp Ltd.

  • Access to the database is strictly controlled through the use of name specific passwords.
  • Access is authorised by the Church office and overseen by the Operations Director.
  • Those authorised to use the database only have access to their specific area of use within the database.
  • People who may have secure and authorised access to the database include Cogges Staff, data in-putters, Ministry Team Leaders, Small Group Leaders and PCC.

Rights to Access Information

Employees and other subjects of personal data held by Cogges have the right to access any personal data that is being held in certain manual filing systems (subject to certain exemptions).

  • Subject Access - all individuals who are the subject of personal data held by Cogges are entitled to:
    • Ask what information the church holds about them and why.
    • Ask how to gain access to it.
    • Be informed how to keep it up to date.
    • Be informed what Cogges is doing to comply with its obligations under the 1988 Data Protection Act.
  • Personal information will not be passed onto any third parties outside of the church environment.
  • Personal Information may be withheld if the information relates to another individual.
  • Subject Consent - The need to process data for normal purposes has been communicated to all data subjects. In some cases. If the data is sensitive, for example, information about health, race or gender, express consent to process the data must be obtained.

Any person who wishes to exercise this right should make the request in writing to the Cogges Data Controller, using the standard letter which is available on line from www.ico.gov.uk

Cogges reserves the right to charge the maximum fee payable for each subject request. If personal details are inaccurate, they can be amended upon request. Cogges aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 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.

Revisions

  • May 9th 2016 initial check-in - draft [James Webster]
  • May 10th 2016 format changes & clarifying the re-publishing of infomation already in the public domain [James Webster]
  • June 13th 2016 feedback from PCC Lay Chair (Harvey Leach) clarifications and detail around access control to database
  • Sept 19th 2017 typos and change of database provider

  1. http://www.legislation.gov.uk/ukpga/1998/29/schedule/2 ↩

  2. http://www.legislation.gov.uk/ukpga/1998/29/schedule/3 ↩

  3. http://www.legislation.gov.uk/ukpga/1998/29 ↩