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Data Privacy Statement for The Benefice of Hanborough and Freeland


1. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. This includes things such as your name, address, telephone number, and email address. Identification can be by the information alone or in conjunction with any other information in the data controllers’ possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”) and the Data Protection Act 2018, (the “DPA 2018”).   


2. Who are we?

This Privacy Statement is provided to you by the Parochial Church Councils (PCCs) of Hanborough and Freeland.  The PCCs work together with the incumbent of the parishes (that is, our Rector). The Benefice of Hanborough and Freeland consists of the Parishes of Hanborough and Freeland. Some data for both parishes is jointly held within the Benefice.

As the church is made up of PCCs, clergy, ministers, together with associated lay volunteers and administrators all 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 communities.  The PCCs and incumbent referred to above are joint data controllers (this means they decide how your personal data is processed and for what purposes), which means we are all responsible for how we process your data.

In the rest of this Privacy Statement, we use the word “we”, “us” and “our[s]” to refer to any or all of the above data controllers, as appropriate.

3. How we process your personal data?

We comply with our obligations under data protection laws by:

  • keeping personal data up to date

  • by storing and destroying it securely

  • by not collecting or retaining excessive amounts of personal 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 meet our legal and statutory obligations (which include maintaining and publishing our electoral roll in accordance with the Church Representation Rules)

  • To maintain a list of those that regularly attend our churches

  • To deliver the wide number of church ministries and activities as agreed by the PCC’s

  • To provide news and information related to events, activities and services run by our churches

  • To provide pastoral support to regular attendees and others connected to the church

  • To administer records of our employees, ministers, office-holders and volunteers

  • To fundraise and promote the interests of our Churches and communities

  • To maintain our financial accounts and records (including the processing of any donations and of Gift Aid)

  • To manage the use of our building and its maintenance and security 

  • To seek your views or comments

  • To send you communications which you have requested and that may be of interest to you.

  • To process a grant or application for a role

  • To carry out safeguarding procedures 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 share your contact details, when necessary, with the Oxford Diocesan Board of Finance which is responsible for the financial and administrative arrangements for the Diocese of Oxford, including the granting of faculty permission for building repairs and maintenance.

4. What is the legal basis for processing your personal data?
The legal basis for processing varies depending on the purpose:

  • Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as the Oxford Diocesan Board of Finance).  An example of this would be holding office-holder’s personal data to support the day-to-day communications needed to run our churches (this applies to roles such as churchwarden and PCC secretary). 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. Other examples include obligations in relation to Gift Aid or under employment, social security or social protection law.

  • The processing is necessary in order to protect someone’s vital interests.

  • 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 a contract for maintenance of our buildings or equipment, or hire of the church hall.

  • For other purposes we will process your data with your explicit consent.  An example of this would be regular emails providing information about our services and activities in the parish/benefice.

We are permitted to process personal data which may reveal religious or philosophical beliefs because it is a not-for-profit body with a religious aim and because the processing relates only to members or former members (or those who have regular contact with us in connection with those purposes); and there is no disclosure of sensitive personal data 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 in order to carry out a service to other church members or for purposes connected with the church.  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):

  • ChurchSuite: We collect and process personal data that you provide to us when you sign up to join our ChurchSuite management system or when you participate in any of our church’s activities. This data can include your name, address, email and phone contact details, relationships with your family members, marital status, date of birth, employment details, and records of participation in church activities. 

 My ChurchSuite allows you to manage your own personal data which is held in the system and to choose which data you add. It also allows you to decide how you want the Benefice to communicate with you and what personal data you want to share with others in the church address book. Only other people who have signed up to the Benefice My ChurchSuite account have access to information about you in My ChurchSuite.

If you are providing us with personal data for anyone other than yourself (for example, if you are a carer), please ensure that you have permission to do so.

My ChurchSuite uses up-to-date technical and organisational security measures to protect your personal data. 

  • Other clergy or lay persons nominated or licensed by the bishops of the Diocese of Oxford to support the mission of the Church in our parishes. 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.

  • The Oxford Diocesan Board of Finance.

  • Other persons or organisations operating within the Diocese of Oxford including, where relevant, the Oxford Diocesan Board of Education.

  • Our agents and contractors (such as maintenance contractors, printers and architects).

  • On occasion, other churches or community organisations with whom we are carrying out joint events or activities.

We will also share your personal data if we think it necessary in order to protect the rights or safety of our church, our staff, any of our church members or volunteers, or any vulnerable person. We will share your personal data with the police or other authorities if required or appropriate to do so.

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.  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 parish registers (baptisms, marriages, funerals) permanently.

We will keep some records permanently if we are legally required to do so.  In general, we will endeavour to keep data only for as long as we need it.  This means that we may delete or destroy it when it is no longer needed.

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 we hold about you;

  • The right to request that we correct 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 PCCs to retain such data;

  • The right to withdraw your consent to the processing at any time;

  • The right to request that the data controllers provide you with your 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 is 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.

When exercising any of the rights listed above, 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.

8. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection Statement, then we will provide you with a new statement 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 contact the Benefice Administrator using the Contact form on this website or by telephoning 01993 881270.

You can contact the Information Commissioner’s Office on 0303 123 1113 or via email or at the Information Commissioner's Office, Wycliffe House,  Water Lane, Wilmslow, Cheshire. SK9 5AF.

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