Data Protection and Privacy Policy
This is the privacy and data protection policy for the 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.
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, photograph, video, email
address or postal 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).
How is your data used and processed
The church processes data including:
• Names, titles and aliases.
• Contact information including telephone/mobile 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 and dependants.
• Where you give financially in support of the church.
• 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: mental and physical health, details of injuries,
medication/treatment received, data concerning criminal records, fines and other similar
judicial records.
As a Data Controller, our minister and volunteers 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. If you have any concerns about how your data is being use, please
speak with our Data Controller.
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 with the
aim of ensuring that all children and adults at risk are provided with safe environments.
• Deliver our Church's mission 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 church.
• Administer our membership records.
• Enable us to follow up membership, course and event enquiries.
• Maintain our own accounts and records.
• Process and record financial donations that you have made.
• Communicate with you about our services, events, meetings, mission and other matters
which are relevant to you as part of our church community.
What is the legal basis for processing your personal data?
Our legal basis is as follows:
• Most of our data is processed because it is necessary for our legitimate interests to enable
our charitable and missional aims. For example, maintaining membership records,
safeguarding children and adults at risk of abuse, recording our financial donations, and
operating team rotas for the effective function of Sunday services or other groups.
• Some of our processing is necessary for compliance with a legal obligation. Retaining
safeguarding records is an example 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 should buy tickets for a church
event.
• As a religious organisation, we are permitted to process information about your religious
beliefs to administer our membership.
Where your information is used other than in accordance with one of these legal bases, we will
first obtain your consent to that use. For example, if you are a regular attender and request to
receive our ‘all church' emails or join a church WhatsApp Group.
Will we share your data?
You can be reassured that we will treat your personal data as strictly confidential.
The main church database in the form of a church directory is only made available to the minister
and trustees.
Data 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. We may need to share your data with some or all of
the following (but only where necessary):
• Our agents, servants and contractors. For example, if we should utilise a commercial
provider to send out, say, newsletters.
• On occasion, other churches with which we could be carrying out joint events or activities.
Our primary database is held by our Administrator in Microsoft Word and our financial records are
stored by our Treasurer in Microsoft Excel. In addition, some data is held by our Minister, our
Secretary and a Sunday School Leader.
How long will we keep your personal data?
Our general rule is to keep data no longer than necessary. Where you continue to actively engage
with our church services, activities and events, we will retain the appropriate data for you so that
we can best serve your involvement. We operate an annual process of review, by which we
assess who is actively engaging in church life, and where this is not the case, we will remove your
data.
Additionally:
• We will keep some records permanently if we are legally required to do so. For example,
this covers some safeguarding records.
• We may keep some other records for an extended period. For example, it is current best
practice to keep financial records for a minimum period of seven years to support HMRC
audits.
What are your rights regarding 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 about 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 cannot be deleted
(for example because we need it for our legitimate interests or regulatory purposes).
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 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, mobile, email or by post.
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: https://ico.org.uk/global/contact-us/email/ or at the Information
Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Further processing
If we wish to use your personal data for a new purpose not covered by this policy, then we will
provide you with a new policy prior to commencing the processing to explain this new use and set
out the relevant purposes and processing conditions. Where and whenever necessary, we will
seek your prior consent to the new processing.
Data Controller details
Data Controller: Marlow Baptist Church
Data Protection Lead: Keith Baxter
Email: marlowbc@yahoo.com
Senior Information Risk Owner: Heather Baxter
Definitions and appointed persons
| Role | Definition | Appointed person / organisation |
| Data Controller | An individual or organisation who collects, stores and processes (uses) data | Marlow Baptist Church |
| Data Protection Lead | The DPL is responsible for the day-to day organisational management of protection and is the go-to person for responding to any issues around data, dealing with subject access requests and completing an annual data review. | Keith Baxter |
| Senior Information Risk Owner | The SIRO is a trustee who works with the DPL to provide the trustees with assurance that information risk is being managed appropriately and effectively across the organisation. | Heather Baxter |