You may have already heard about a new European regulation* which affects all organisations which hold personal data. The main aim of GDPR is to give greater control to individuals as to which organisations hold their personal data. Although Stevenage Vineyard holds relatively little personal data, it will be subject to the new regulations.
We are sending you this Announcement because Stevenage Vineyard holds some of your personal data. You are currently on the Church’s contact list which contains information such as your email address and mobile telephone number – and also, if we have it, your home address and landline telephone number. The contact list is used mainly to provide you with information and details of any important Church news (for example, about special events or meetings). The data is protected and kept safe – the contact list is not distributed and access is only available to members of the Church leadership team.
If you no longer wish to receive information and details about special events or meetings at Stevenage Vineyard, you can unsubscribe from our contact list by emailing firstname.lastname@example.org
* The European General Data Protection Regulation (GDPR)
Stevenage Vineyard (‘the organisation’) maintains a contact list which details the name, address, telephone number and email address of people who regularly or periodically attend the church. Stevenage Vineyard is committed to being transparent about how it collects and uses this personal data and to meeting its data protection obligations. This document sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.
“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data protection principles
The organisation processes the personal data it holds on its contact list in accordance with the following data protection principles:
- The organisation processes personal data lawfully, fairly and in a transparent manner.
- The organisation collects personal data only for specified, explicit and legitimate purposes.
- The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- The organisation keeps personal data only for the period necessary for processing.
- The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
- The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.
- The organisation does not hold any special categories of personal data or criminal records data.
- The organisation will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered from people who regularly or periodically attend the church is currently held in electronic format only.
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:
- whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights;
- whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making
The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
To make a subject access request, the individual should send the request to: email@example.com. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.
The organisation will normally respond to a request within a period of one month from the date it is received. If it cannot respond within this period, the organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case.
Individuals have a number of other rights in relation to their personal data. They can require the organisation to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override the organisation’s legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.
To ask the organisation to take any of these steps, the individual should send the request to: firstname.lastname@example.org.
The organisation takes the security of personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by the Pastors or Trustees of the church in the proper performance of their duties.
If the organisation engages third parties to process personal data on its behalf, such parties will do so on the basis of written instructions, under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
International data transfers
The organisation will not transfer personal data to countries outside the EEA.
Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual moves house or changes his/her email address.
Individuals may have access to the personal data of other individuals in the course of any duties or responsibilities they are carrying out on behalf of the organisation – for example, leaders of Small Groups will be provided with contact details for anyone who enrols in their group. Where this is the case, the organisation relies on individuals to help meet its data protection obligations.
Individuals who have access to personal data are required:
- to access only data that they have authority to access and only for authorised purposes;
- not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
- to keep data secure;
- not to remove personal data, or devices containing or that can be used to access personal data, from the organisation’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
- not to store personal data on local drives or on personal devices.
The organisation will provide clear instructions to all individuals who have access to personal data about their data protection responsibilities.