Privacy notice

1. Important information and who we are

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 Data Protection Bill 2017 and the General Data Protection Regulation 2016/679 (GDPR]. 

Who are we?  

This Privacy Notice is provided to you by the Parochial Church Council (PCC) of Christ Church Spitalfields which is the data controller for your data.  

The Church of England is made up of a number of different organisations and office-holders who work together to deliver the Church’s mission in each community.  The PCC works together with: 

  • the incumbent of the parish (that is, our rector); 

  • the Bishops of the Diocese of London; and 

  • the London Diocesan Fund, which is responsible for the financial and administrative arrangements for the Diocese of London. 

As the Church 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 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.   

Each of the data controllers have their own tasks within the Church 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 by the PCC on our own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.  

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL at GDPR@ccspits.org or by calling 020 7377 2440.

 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes 

It is important that the personal data we hold on you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

2.  The Data we collect about you

Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data - includes first name, maiden name, last name, username (or similar identifier), marital status, title, date of birth, gender, photograph, video footage and any other biographical information you may provide us.

  • Contact Data - includes billing address, delivery address, email address and telephone numbers.

  • Financial Data - includes bank account and payment card details.

  • Transaction Data - includes details about payments to and from you and other details of events, products or services you have purchased from us or gifts you have donated to us.

  • Technical Data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 

  • Profile Data - includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  

  • Usage Data - includes information about how you use our website, events, products and services. 

  • Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

As a church, we collect data about services and events you attend.  Some of this information may be considered to come within the definition of Special Categories of Personal Data. Special Categories or Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We will always make it clear to you when we collect this information and why.  For some of our events and services we may also collect information about criminal convictions and offences.  

If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your tickets to an event or service you have with us but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions - you may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • are involved in the life of the church through one of our services, groups or activities;

  • are involved in photography or videography via our services or events;

  • donate online, by text message or completing a giving envelope;

  • register for an event or course;

  • subscribe to our services or publications; 

  • request marketing to be sent to you;

  • respond to a survey; or

  • give us some feedback. 

Automated technologies or interactions - as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources - we may receive personal data about you from various third parties and public sources as set out below: 

  • Technical Data from analytics providers such as Google based outside the EU.

  • Identity and Contact Data from publicly available sources such as Companies House based inside the EU.

The data controllers will comply with their 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. 

4. How do we process your 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 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 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 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 the Church and charity;  

  • 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 also includes the use of CCTV systems for the prevention and prosecution of crime.  

5. 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. 

6. 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, staff or lay persons nominated or licensed by the bishops of the Diocese of London 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 London including, where relevant, the London Diocesan Board for Schools and Subsidiary Bodies; 

  • On occasion, other churches with which we are carrying out joint events or activities. 

  • Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. 

  • Third Party Product Providers we work in association with:  When you are using our secure online donation pages your donation is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.

7. 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. 

 8. Your rights and your personal data   

You have the following rights with respect to your personal data: 

  • 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.  

  • 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 telephone, email, or by post (see Contact Details below). 

  • The right to object to the processing of personal data where applicable. 

  • 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. 

9. 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.   

10. 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. 

 11. 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, Christ Church Spitalfields  

Email: admin@ccspits.org   

You can contact the Information Commissioner’s 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.  

The policy was last updated on 1 November 2019.