Privacy: Role Holders

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/Act 2017, the General Data Protection Regulation 2016/679 (GDPR) and other legislation relating to personal data and rights such as the Human Rights Act 1998. 

Who are we?
This Privacy Notice is provided by the PCC of St Stephen’s Tonbridge 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 (our vicar);
  • the bishops of the Diocese of Rochester; and
  • the Diocesan Office which is responsible for the financial and administrative arrangements of the Diocese of Rochester.

As the church is made up of all 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 the Privacy Notice. This Privacy Notice is sent to you by the PCC on our own and on behalf of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate. 

What data do the data controllers listed above process?
We will process some or all of the following where necessary to perform our tasks:

  • Names, titles, photographs and video;
  • Contact details such as telephone numbers, addresses and email addresses;
  • Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education, work histories, academic/professional qualifications, employment details, hobbies, family composition and dependants;
  • Non financial identifiers such as passport numbers, driving license numbers, vehicle registration numbers, taxpayer identification numbers, employee identification numbers, tax reference codes and national insurance numbers;
  • Financial identifiers such as bank account numbers, payment card numbers, payment/ transaction identifiers, policy numbers and claim numbers;
  • Financial information such as salary, bonus, record of earnings, tax code, tax and benefits contributions, expenses claimed, creditworthiness, car allowance (if applicable), amounts insured and amounts claimed;
  • Other operational personal data created, obtained, or otherwise processed in the course of carrying out our objectives, including but not limited to, CCTV footage, recordings of telephone conversations, IP addresses and website visit histories, log of visitors, and logs of incidents, injuries and insurance claims;
  • Other employee data (not covered above) relating to role holders including emergency contact information, gender, date of birth, referral source (eg agency, employee referral), level, performance management information, languages, proficiency, licences/certificates, citizenship, immigration status, employment status, retirement date, billing rates, office location, practice, speciality, publication and awards for articles and books, prior job history, employment references and personal biographies.
  • The data we process is likely to constitute sensitive personal data because, as a church, the fact that we process your data at all may be suggestive of your religious beliefs.

Why do we process your personal data?
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. We use your personal data for some or all of the following purposes (some of the role holders are volunteers and no financial information will be processed for these role holders):

  • 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 enable those who undertake pastoral care duties as appropriate (such as visiting the bereaved);
  • 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 administer the parish, deanery, archdeaconry and diocesan membership records;
  • To fundraise and promote the interests of the church and charity;
  • To manage our employees and volunteers;
  • To maintain our own accounts and records;
  • 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;
  • To share your contact details with the Diocesan office so they can keep you informed about news in the Diocese and events, activities and services that will be occurring in the Diocese and in which you may be interested;
  • We will process data about role holders for legal, personnel, administrative and management purposes and to enable us to meet our legal obligations, for example, to pay role-holders, monitor their performance and to confer benefits in connection with your engagement as a role holder. “Role Holders” include volunteers, employees, contactors, agents, staff, retirees, temporary employees, beneficiaries, workers, treasurers and other role holders;
  • We may process sensitive personal data relating to role holders including, as appropriate:
    • Information about a role holder’s physical or mental health or condition in order to monitor sick leave and take decisions as to the role holders fitness for work;
    • The role holder’s racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
    • In order to comply with legal requirements and obligations to third parties;
  • The use of CCTV systems for the prevention and prosecution of crime.

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.

We will also process your data in order to assist you in fulfilling your role in the church including pastoral and administrative support or if processing is necessary for compliance with legal obligation.

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.

Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ 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 maintain our database software, or to send electronic mailings on our behalf;
  • Other clergy or lay persons nominated or authorized by the data controllers may participate in our mission in support of our regular clergy;
  • Other persons or organisations operating within the Diocese of Rochester including, where relevant, the Rochester Diocesan Board of Education;
  • On occasions, other churches with which we are carrying out joint events or activities.

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 (for detailed list of our legal requirements regarding data retention please see our Data Retention Policy).

Your rights and 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 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.

  • See Information Commissioners Office’s details below.

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. 

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. 

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
St Stephen’s Church Office
35 Waterloo Road
Kent TN9 2SW 

You can contact the Information Commissioners Office on 0303 123 1113 or via email or at:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Cheshire SK9 5AF