Data Protection Policy
Thornbury Parish Church (including the Church Hall) uses personal data about living individuals for the purpose of pastoral care.
Thornbury Parish Church recognises the importance of the correct and lawful treatment of personal data. All personal data , whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.
Thornbury Parish Church fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for Thornbury Parish Church must adhere to these principals.
The data is registered under the provisions of the Data Protection Act under the Bishop of Gloucester who is the Data Controller for the Diocese of Gloucester. The registration number is Z6964678 and full details of the registration can be viewed on the Information Commissioners website www.ico.gov.uk .
The principles require that personal data shall:
1. Be processed fairly and lawfully and shall not be processed unless certain conditions are met
2. Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose
3. Be adequate, relevant and not excessive for those purposes
4. Be accurate and, where necessary, kept up to date
5. Not to be kept for longer than is necessary for that purpose
6. Be processed in accordance with the data subject’s rights
7. Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures
8. And not transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
All personal data is to be treated as private and confidential information and is not to be disclosed to anyone other than those who need access to the personal data in order to facilitate Pastoral Care and Staff Administration in the administration of and day-
There are four exceptional circumstances to the above permitted by law:
Where we are legally compelled to do so
Where there is a duty to the public to disclose
Where disclosure is required to protect our interest
Where disclosure is made at your request or with your consent
USE OF PERSONAL INFORMATION
Use of personal data is for the purpose of Pastoral Care and Staff Administration which includes:-
Contacting you to keep you informed of Church Activities
Data held by and on behalf of Thornbury Parish Church will not be used for any other purposes than set out in this section.
Data is distributed among a number of computers (both Church and privately owned) and in paper format by those who have a need to either maintain, process or use the data.
A record of where data is located, what the data is, what it is to be used for and who maintains, process or uses the data is to be maintained by the Church office under the authority of the Data Controller. Due to the distributed nature of the data there is no obvious master data set, therefore, data which is master data is to be declared in the data record help by the Church office, and is to be used to maintain subsidiary data sets. When the circumstances surrounding the holding of data change then the Church office is to be notified of the changes.
The Vicar will act on behalf of the Bishop of Gloucester as the Data Controller for Thornbury. The Vicar may further delegate data controller status to others for pastoral care.
Where data is stored electronically it is to be stored on a machine which is adequately protected physically and electronically with the latest updates to the operating system, antivirus, firewall and any other technical measures which are necessary.
Electronic data is to be password protected. On computers which are dedicated to Church use, logon passwords with appropriate inactivity time shall be the minimum protection. For other machines, file and/or programme passwords must be used to protect the data.
When data is no longer required, electronically held data is to be erased, ensuring that temporary files and backups are also erased, and paper records are to be shredded.
Personal information will not be passed onto any third parties outside of the church
Subject Consent: The need to process data for normal purposes has been communicated to all data subjects. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained.
Retention of Data: The need to process data for normal purposes has been communicated to all data subjects. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained.
Rights to Access Information
Employees and other subjects of personal data held by Thornbury Parish Church have the right to access any personal data that is being kept about them on computer and also have access to paper-
Subject Access: All individuals who are the subject of personal data held by Thornbury Parish Church are entitled to:
Ask what information that Thornbury Parish Church holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed what Thornbury Church is doing to comply with its obligations under the 1998 Data Protection Act.
Any person who wishes to exercise this right should make the request in writing to the Data Controller, using the standard letter which is available on line from www.ico.gov.uk
Thornbury Parish Church reserves the right to charge the maximum fee payable for each subject access request. If personal details are inaccurate, they can be amended upon request.
Thornbury Parish Church aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a completed form unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request within the original 40 days.