Privacy Notice

The Parochial Church Council (PCC) of ST JAMES’S CHURCH, PICCADILLY

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 (the “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 to you by the Parochial Church Council (PCC) of St James’s, Piccadilly 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 (that is, our rector);
• the bishops of the Diocese of London; and
• the London Diocesan Fund, which is responsible for the financial and administrative arrangements for the Diocese.

As the Church is made up of all of 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 this Privacy Notice. This Privacy Notice is sent to you by the PCC on our own behalf and on behalf of each 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?

They will process some or all of the following where necessary to perform their tasks:

• Names, titles, and aliases, photographs;
• 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, hobbies, family composition, and dependants;
• Where you make donations or pay for activities such as use of a church hall, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
• 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. Where you provide this information, we may also process other categories of sensitive personal data: racial or ethnic origin, sex life, mental and physical health, details of injuries, medication/treatment received, political beliefs, labour union affiliation, genetic data, biometric data, data concerning sexual orientation and criminal records, fines and other similar judicial.

How 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:

• 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 minister to you and provide you with pastoral and spiritual care (such as visiting you when you are gravely ill or bereaved) and to organise and perform ecclesiastical services for you, such as baptisms, confirmations, weddings and funerals;
• 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 administer the parish, deanery, archdeaconry and diocesan membership records;
• To fundraise and promote the interests of the Church and charity;
• To maintain our own accounts and records;
• To process a donation that you have made (including Gift Aid information);
• 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 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;
• Our processing also includes the use of CCTV systems for the prevention and prosecution of crime

Donations and Fundraising

What data do we collect about you?

• Your name
• Contact address(es)
• Telephone number(s)
• Email address(s)
• Records of your communications with us
• Donation and Gift Aid information
• Bank details when you set up a Direct Debit
• Information you may provide onto our website such as reason for donating

How do we use the data we collect about you?

We use your personal data for a number of purposes including the following:

• To keep a record of donations you make, actions you take, and our communications with you
• To process credit and debit card donations you make
• To process your direct debit payments, you make
• To claim gift aid on your donations via HMRC
• To send you marketing information about our work and fundraising activities
• To support community-based fundraising you may be taking part in
• To comply with applicable law and regulations

Congregation Giving and Donations

Church Suite is used to process your donation or becoming a regular giver.  We use Stripe ( https://stripe.com/gb/legal/privacy-center ).  For donations to the Work of St James’s and the Wren Project, we use Donorfy ( https://donorfy.com/privacy-notice ) and GoCardless ( https://gocardless.com/privacy/ ) to process your donation.

Our lawful basis for processing your information is consent and legitimate interests. We will keep your donation details for 7 years.

Signing up for further information about Fundraising

We collect your name and email address to send you updates. We will communicate with you using MailChimp ( https://www.intuit.com/privacy/statement/ ). Our lawful basis for processing your information is consent, you can unsubscribe at any time using the link in the email or by contacting US.

Ethical screening and minimising risk

To comply with our obligations as a charity, we must also take reasonable and appropriate steps to know who our donors are, particularly where significant sums are donated. Using charity law as a legal basis for processing, we may conduct due diligence to provide assurances that donations and support are from appropriate sources. This is to safeguard our reputation and to help us mitigate any associated risk. We have clearly defined principles that guide how we engage in mutually beneficial relationships with companies, foundations and individuals. These principles ensure that we raise money legally, safely and transparently. The nature and extent of due diligence research is proportionate to the fundraising opportunity. This doesn’t mean that we’ll research lots of personal details about every donor or question every donation. Any information we collect for these purposes will only consist of what is necessary for us to meet these requirements and will be processed in line with your rights. Please see Our Due Diligence Policy (Link Here)

American Friends

Gifts in the US can be made via the American Friends of St James’s Piccadilly. This is an independent non-profit corporation with tax-exempt status under section 501(c) (3) of the Internal Revenue Code. Donations are tax-deductible to the extent permitted under applicable law. We may carry out due diligence in line with our Donor Due Diligence Policy. We process your information using Donorfy (https://donorfy.com/privacy-notice) For further information, please contact Brian Willetts, Director of Development at development@sjp.org.uk

Notices to California Residents

In addition to your rights under GDPR, CalOPPA gives California residents the right to opt-out of having their personal information sold. St James Piccadilly does not sell personal information. As described in this privacy notice, we may share personal information with our Affiliates and service providers. We may also disclose personal information to third parties for business purposes as permitted by CalOPPA, such as to our auditors, for compliance or security, or in connection with mergers and acquisitions.

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

To receive the information described above or to request that we stop sharing your information, please contact datamanager@sjp.org.uk .

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. 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 where it is necessary for the performance of our 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 send out newsletters on our behalf, or to maintain our database software;
• Other clergy or lay persons nominated or licensed by the bishops of the Diocese of London to support the mission of the Church in our parish. For example, our clergy are supported by our area dean and archdeacon, who may provide confidential mentoring and pastoral support. Assistant or temporary ministers, including curates, deacons, licensed lay ministers, commissioned lay ministers or persons with Bishop’s Permissions may participate in our mission in support of our regular clergy;
• Other persons or organisations operating within the Diocese of London including, where relevant, the London Diocesan Board for Schools and Subsidiary Bodies;
• On occasion, other churches with which we are carrying out joint events.

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.

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. 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.
• 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. 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 it.
• The right to withdraw your consent to the processing at any time for any processing of data to which consent was given. 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 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 James’s Church 197 Piccadilly London W1J 9LL
Email: datamanager@sjp.org.uk

You can contact the Information Commissioners Office on 0303 123 1113 or via their website https://ico.org.uk/global/contact-us/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.