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Privacy statement

Parish of Port Talbot St. Theodore P.C.C. Data Protection Policies.

These policies are written in accordance with the E.U. General Data Protection Regulations were adopted by the Parochial Church Council(PCC) on the 23rd May 2018, and replace earlier Data Protection Policy.

In accordance with those regulations the P.C.C. also adopts the attached Privacy Notice to be given whenever personal data is collected.

The Parochial Church Council is registered with the Information Commissioner’s Office (I.C.O.) under Registration Reference ZA288232. Under that Registration the nature of the work carried out is stated as Pastoral Care and the description of the processing is set out on the register. These  Policies are therefore to be read in conjunction with those Registration details.

All personal data is held in accordance with and for the purposes set out in the Registration. The P.C.C. will comply with its obligations under the new law by keeping personal 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.

Personal data is held in the following ways:

1. The Parish Electoral Roll. The legal basis in holding and processing this information is for the legitimate interests of the Parish. It is stored securely and is not available outside the parish. It is treated as strictly confidential and is used internally solely for the administrative purposes of the parish and will only be shared with other members of the church for purposes connected with the church.

2. Gift Aid Records. The legal basis here is the same as in 1. above. The information is processed on the personal computer/ memory stick of the gift aid secretary and is password protected. This information is used solely in connection with record keeping and claiming gift aid refunds from H.M.R.C. Only the gift aid secretary has access to and knowledge of this data.

3. Parish Registers/Records. These are processed in accordance with and solely for the purpose of compliance with the legal obligation to maintain records.

4. Parish Website. Photographs taken at parish events, will only appear on the website, Facebook page and used in future publicity in the case of a child under 16 with the consent of a person with parental responsibility for the child and in all other cases either with an individual’s written consent or where it has been made clear that photographs to record the event are being taken. The website will be regularly reviewed as to how long it would be reasonable for the photographs to remain on it.

5. Hire of Halls. The processing of only such personal data e.g. the names and addresses and other contact details of hirers as is necessary to enter into a written contract of hire. The information is not shared and is kept secure. It will be retained for 12 months in order to administer the contract, the halls and the hall accounts.

6. CCTV. This was installed for the purpose of crime prevention. It is used in the interests of the parish and members of the public, for maintaining the safety of users, the security of personal property the halls and car park, and for preventing and investigating crime. Full details of the permitted processing is set out in the I.C.O. Registration. Before installing CCTV the P.C.C carried out an impact assessment and considered that given the extensive use of both halls by the community, measures were needed to help achieve the above, and that given the lay out of the halls it was possible for people to enter certain parts unobserved and impossible to ensure that only members of the public associated with a given event were legitimately present. It was therefore considered necessary to install CCTV subject to strict conditions as to its use. There are 7 cameras covering the halls and car park. The screen and recording equipment are in a locked area, the parish office, where only certain authorised members of the parish have access. The retrieval of images function is also password protected and images will be retained for a maximum of 28 days, but only viewed if necessary for the purpose of maintaining the security of the halls and car park and preventing and investigating crime. Should it be necessary to preserve the images for a longer period as a result, the images will be kept for as long as is reasonably necessary and shared with such persons and bodies as may have a legitimate reason to see them.

7. Data Barring Service Certificates(DBS). The Parish has adopted the Church in Wales Safeguarding Policy and has an appointed safeguarding officer. Any DBS certificates are processed in accordance with that Policy.

8. The processing of personal data that reveals, inter alia, a religious belief is classified as sensitive data and as such there must be an additional legal basis for processing it. In respect of the information held by the parish, e.g. possibly the electoral role and baptismal register, that could come within this, the additional legal basis is that processing is carried out by a not -for- profit body with a religious aim and the processing relates only to members or former members (or those who have regular contact with it in connection with that purpose) and there is no disclosure to a third party without consent.

Personal data will always be treated as strictly confidential and will only be shared with other members of the church in order to carry out a service to other church members or for purposes connected with the church. Data will only be shared with third parties outside of the Parish with the individual’s consent.

If the PCC wishes personal data to be used for a new purpose this will only be done with the individual’s written consent and upon the giving of a copy of the PCC’s Privacy Notice setting out the new purpose.

All personal data is kept in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available on the Church in Wales website. Specifically, the Parish retains electoral roll data while it is still current; gift aid and associated paperwork for up to 6 years after the calendar year to which they relate, and parish register (baptisms, marriages, funerals) permanently.

In the event of a breach of the data protection principles the PCC will interrogate its procedures and take such remedial steps as it considers necessary to prevent any similar breach in the future. The individual or individuals concerned will be informed and if necessary the ICO contacted.