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 (EU) 2016/679 (the “GDPR”), as passed into UK law in the Data Protection Act 2018 (the “DPA”).

2. Who are we?

The Parochial Church Council (PCC) of St Thomas à Becket Church, Lewes, is the data controller (contact details below, para 9).  This means that the PCC decides how your personal data is processed and for what purposes.

3. How do we process your personal data?

The PCC of St Thomas à Becket, Lewes, complies with its obligations under the GDPR and DPA:

• 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;
• 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 membership records;
• To fundraise and promote the interests of the charity;
• 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 run at or by St Thomas à Becket;
• 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;
• To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.

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 as a Legal Obligation 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 as a Legitimate Interest by a not-for-profit body with a political, philosophical, religious or trade union aim provided:
  • other 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. This includes processing that is carried out as a Legitimate Interest under the Church Representation Rules.
• Processing is necessary under Contract with respect to suppliers (to the PCC) and their staff, sub-contractors or agents.

5. Sharing your personal data

Your personal data will be treated as strictly confidential. It 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. We will only share your data with third parties outside of the parish with your consent, or as legally required.

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”. This is available from the Church of England website [see footnote 1 for link].​

Specifically, we retain electoral roll data while it is still current. Gift aid declarations and associated paperwork are retained for up to 6 years after the calendar year to which they relate. Parish registers (baptisms, marriages, funerals) are retained permanently.

7. Your rights and your personal data

Unless subject to an exemption under the GDPR and the DPA, you have the following rights with respect to your personal data:

• The right to request a copy of your personal data which the PCC of St Thomas à Becket, Lewes, holds about you;
• The right to request that the PCC of St Thomas à Becket, Lewes, 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 PCC of St Thomas à Becket, Lewes, 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);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;
• The right to object to the processing of personal data, (where applicable);
• The right to lodge a complaint with the Information Commissioner’s Office.

8. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy 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 or complaints please in the first instance email Herbert Bennett, Associate Vicar

You can also contact the Information Commissioner’s Office:
Tel 0303 123 1113
Go to their website: https://ico.org.uk
Write to or visit:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF.

[1] Details about retention periods can currently be found in the Record Management Guides located on the Church of England website at: https://www.churchofengland.org/about/libraries-and-archives/records-management-guides