DATA PRIVACY NOTICE 

The Chaplaincy Council (CC) of Holy Trinity Brussels

Holy Trinity Brussels is committed to the protection of the privacy of all our members. We encourage individuals to build meaningful relationship with each other and to feel safe and secure within the church family. To support this, Holy Trinity aims to provide high standards of protection for personal information. 

1. Your personal data – what is it?

Your privacy is important to us and we understand how important it is to you. Our aim is to be transparent about what we do with your personal data. Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

CHURCHSUITE DATA COLLECTION

2. What is ChurchSuite?

The CC of Holy Trinity Brussels relies on the ChurchSuite platform to store and organize all of our church contacts. We collect, with your permission, any or all of the following categories of data that you choose to disclose: full name, date of birth, sex, marital status, spouse name, childrens' names, email address, mobile/telephone/work phone numbers, job, employer, residential address, services attended, mother/preferred language, nationality, and church activities. Your voluntary subscription to Holy Trinity’s ChurchSuite platform can be changed at any time; you can unsubscribe using the unsubscribe link in the footer of Holy Trinity emails. For more information on how your personal data may be handled in the context of the ChurchSuite platform, please refer to the ChurchSuite Privacy Policy.

3. How do we process your personal data?

The CC of Holy Trinity Brussels complies with its obligations under the “GDPR” by keeping data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. You are responsible for keeping your contact details up to date and for removing your details when you no longer wish to Holy Trinity to have them.  

We use your personal data for the following purposes:

·      To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;

·      To communicate with members using the ChurchSuite platform, through email or other contact information provided by members;

·      To administer membership records;

·      To fundraise and promote the interests of the church;

·      To manage our employees and volunteers;

·      To maintain our own accounts and records;

·      To maintain accurate records of our Electoral Role;

·      To maintain accurate safeguarding records for children and youth ministries;

·      To inform you of news, events, activities and services running at Holy Trinity Brussels;

4. What is the legal basis for processing your personal data?

·      We obtain your explicit consent to hold your data.

·      Processing is necessary for carrying out legal obligations in relation to Gift Aid or under employment, social security or social protection law, or a collective agreement;

·      Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided:

o   the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes[PV1] [AB2] ).

5. Sharing your personal data
Your personal data will be treated as strictly confidential. Members are in control of their own data and can choose to show or hide data to other members of the church in order for purposes connected with the church. Holy Trinity clergy, administrators, and ministry leaders may use your data to manage activities of the church (such as volunteering and rotas). There is no disclosure to third parties outside of the chaplaincy without consent.

6. How long do we keep your personal data?
We keep data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available from the Church of England website.

Specifically, we retain electoral roll data while it is still current; paperwork associated with donations for up to 6 years after the calendar year to which they relate; and chaplaincy registers (baptisms, marriages, funerals) permanently.

7. Your rights and your personal data 

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

·      The right to request a copy of your personal data which the CC of Holy Trinity Brussels holds about you;

·      The right to request that the CC of Holy Trinity Brussels corrects any personal data if it is found to be inaccurate or out of date; 

·      The right to request your personal data is erased where it is no longer necessary for the CC of Holy Trinity Brussels to retain such data;

·      The right to withdraw your consent to the processing at any time;

·      The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].

·      The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

·      The right to object to the processing of personal data, understanding that this may limit access to some activities within the chaplaincy;

·      The right to lodge a complaint with the Information Commissioners Office.

8. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection 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.

WEBSITE DATA COLLECTION

9. Website Cookie Policy

By using the website holytrinity.be, you agree to our use of cookies. We use cookies to provide you with a great experience and to help our website run effectively. Analytics cookies determine unique visitors, which we need to provide accurate site data.

ELECTORAL ROLL

10. Why do we process your personal data?

We use the personal data you provide on the electoral roll application form to enable us to manage, maintain and publish the electoral roll in accordance with Church Representation Rules (CRR) to:

·      determine eligibility for attendance and participation at the Annual Parochial Church Meeting and for election to the Parochial Church Council, deanery, diocesan and general synods where applicable;

·      calculate the number of representatives who may be elected to each of these synods in the following year;

·      undertake a review and revision of the electoral roll as necessary; and

·      publish your name and address, by exhibiting the roll in the parish church or the church website.

11. What is the lawful basis for processing your personal data?

1.     Processing for the purpose of determining eligibility, creating the electoral roll and use of the roll to calculate numbers for election to synod is necessary for compliance with a legal obligation. The processing is a legal requirement imposed by the Church Representation Rules, which means that you must give us this information if you want to be included on the electoral roll.

2.     Processing for the purpose of determining eligibility and creating or revising the electoral roll is carried out in the course of our legitimate activities, as this relates solely to members the Church of England in connection with its purposes. 

3.     Processing for the purpose of publishing the electoral roll relates to personal data which are manifestly made public by the data subject.  When you apply to have your name added to the church electoral roll, the automatic legal consequence as stated in the CRR, (Part I Formation of the Roll 1(8) and Revision of Roll and Preparation of New Roll 2(1), 2(3) and 2(7)) is that your name and address will be published, and by submitting your application form you are making that data public.

12. Sharing your personal data

The personal data of members of the Electoral Role will be shared within the institutional Church of England and with the general public.

13. How long do we keep your personal data?

We keep your personal data for 6 years after a complete review of the electoral roll.

14. Your rights and your personal data 

Unless subject to an exemption you have the following rights with respect to your personal data:

·      The right to request a copy of your personal data which we hold about you;

·      The right to request that we correct any personal data if it is found to be inaccurate or out of date; 

·      The right to request your personal data be erased where it is no longer necessary for us to retain such data;

·      The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing;

·      The right to lodge a complaint with the Information Commissioners Office.

15. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the Chaplaincy Administrator at admin@holytrinity.be or by phone +32 (0) 2511 7183. Or contact us by mail:

Holy Trinity Brussels

Attention: The Reverend Canon John Wilkinson

Acting Senior Chaplain and Canon Pastor

Rue Capitaine Crespel 29

1050 Ixelles

john.wilkinson@holytrinity.be

You can also contact the Data Officer for the Diocese in Europe:

Diocese in Europe

Attention: Andrew Caspari

14 Tufton Street

London, SW1P 3QZ

UNITED KINGDOM

 andrew.caspari@churchofengland.org