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Data Privacy Policy

The Chaplaincy Church Council (CCC) of St Mark Florence with St Peter Siena and Holy Cross Bologna

From 31 December, 2020

We are part of the Diocese in Europe, a diocese of the Church of England. We may share personal data with the diocesan offices and diocesan registry (legal office), which are located in London, United Kingdom. This will involve a transfer of personal data outside the European Economic Area (EEA). [We may also transfer data to other countries outside of the EEA if our service providers from time to time are located in those countries.]

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We may transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • If we transfer data to a country which has not received an adequacy decision at the date of transfer, we may use specific contracts approved by the European Commission which give personal data the same protection as it has in the European Union.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

1. Your personal data – what is it?

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”).

2. Who are we?

The CCC is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.

3. How do we process your personal data?

The CCC complies with its obligations under the “GDPR” 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.

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 administer Electoral Roll membership records;
  • To fundraise and promote the interests of the chaplaincy;
  • To manage our employees and volunteers;
  • To maintain our own accounts and records (including the processing of Gift Aid applications);
  • To inform you of news, events, activities and services throughout our Chaplaincy.
  • Where we have your permission, 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.

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

  • Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and keep you informed about diocesan events.
  • 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: –
    • the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
    • there is no disclosure to a third party without consent.

5. Sharing your personal data

Your personal data will be treated as strictly confidential and will only be shared with other members of the church or with third parties outside of the chaplaincy with your 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 [see footnote for link].

Specifically, we retain Electoral Roll data while it is still current; Gift Aid declarations and associated paperwork 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 CCC holds about you;
  • The right to request that the CCC 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 CCC 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, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
  • 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.

9. Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the Chaplaincy Administrator on email, administrator@stmarksitaly.com or phone, 0039 055 294 764.

You can contact the Information Commissioners Office 0044 (0) 303 123 1113 or via email https://ico.org.uk/global/contact-us/email/

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St Mark's English Church, Florence, Italy