GRACE BIBLE CHURCH RUGBY

Data Protection & Privacy Policy

Data Controller Details

Data Controller: Grace Bible Church Rugby

Charity number: 1164758

Church address:

61 Somers Road
RUGBY
CV22 7DG

Data Protection Lead: Mr. David McArdle

Church Email: gracebiblechurchrugby@gmail.com

Church Office Phone: 01788 560674

This policy first adopted: 18 September 2024

This policy due for review: 30 September 2025

This is the privacy statement and data protection policy for Grace Bible Church Rugby. It covers how we will process (use and store) your data, what data we hold, your individual rights and how you can interact with us about your data.

This policy covers our use of personal data, which is any information about a living individual which allows them to be identified from that data (for example a name, photograph, video, email address, or postal address). Identification can be by the information alone or in conjunction with any other information.

Our processing of personal data is governed by the Data Protection Bill/Act 2017-2019 and 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).

How is your data used and processed?

Grace Bible Church Rugby processes data including:

Names, titles, and aliases.

Contact information including telephone numbers, postal /residential addresses, and email addresses.

Where there is a legitimate interest to facilitate our charitable aims and activities, or where you have added them to our database or provided them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, and dependants.

We may collect your data in the form of CCTV footage used to maintain security at our various places of ministry, storage or offices, as well as collect your data in the form of photos and/or videos taken at one of our numerous ministry, training, outreaches, or fellowship events. We may collect and use your data to contact you with information about further services or events that may be of interest to you. Most commonly, we will use your personal data where it is necessary for our legitimate interests. Legitimate Interest means the interest of Grace Bible Church Rugby in conducting and managing our activities to enable us to give you the best church community, events, products and services and the best and most secure experience.

Where you give financially in support of Grace Bible Church Rugby or pay for church activities (event bookings, etc.).

As a church (religious organisation), the data we process is likely to constitute sensitive personal data because the very 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: mental and physical health, details of injuries, medication/treatment received, data concerning criminal records, fines, and other similar judicial records. This is especially applicable in our new members application, our Grace Bible Academy class registration, and our church's Biblical Counselling Ministry application process.

As a Data Controller, our staff and volunteers 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. If you have any concerns about how your data is being used, please speak with our Data Protection Lead.

What are we doing with your data?

We only hold data that either we are legally obliged to or that helps us fulfil our missional and charitable aims as a church. We are a membership organisation and good communication with our membership is an essential part of being church.

Therefore, we will hold and process data to:

Enable us to meet all legal and statutory obligations.
Comply with and facilitate our comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice with the aim of ensuring that all children and adults-at-risk are provided with safe environments.
Deliver our church’s mission and carry out any other voluntary or charitable activities for the benefit of the public as outlined in the constitution and statutory framework, including all training and biblical counseling.
Administer our membership records.
Enable us to follow up on membership, course, and event inquiries.
Maintain our own accounts and records.
Process and record financial donations you have made (including Gift Aid information).
Communicate with you about our services, events, meetings, missions, and other matters relevant to you as part of our church community.

What is our legal basis for processing your personal data?

Our legal basis is as follows:

Most of our data is processed because it is necessary for our legitimate interests to enable our charitable and missional aims. For example, maintaining membership records, safeguarding children and adults at risk of abuse, recording our financial donations, and operating team rotas for the effective function of Sunday services or other groups.
Some of our processing is necessary for compliance with a legal obligation. Retaining safeguarding records and gift aid declarations are examples of this.
We may also process data if it is necessary for the performance of a contract with you, or to provide a direct service to you. For example, if you buy tickets for a church event.
As a religious organisation, we are permitted to process information about your religious beliefs to administer our membership.

Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use. For example, if you are a regular attender and request to receive our weekly news.

Will we share your data?

You can be reassured that we will treat your personal data as strictly confidential.

The main church database is only accessible by our church elders or those appointed by the elders to assist with specific administrative tasks. Basic contact details of church members are made available to other church members via a "Members Only" group on GBCR's Basecamp app. GBCR Members are instructed NOT to share church members details with those outside the GBCR Membership unless they have expressed, written or verbal consent from the GBCR Member to have their contact details shared with others.

Data 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):

Our agents, servants and contractors. For example, if we utilise commercial providers to send out newsletters on our behalf, or to maintain our database software.
On occasion, other churches with which we are carrying out joint events or activities.

Our primary database is Dropbox, and our financial records are stored on QuickBooks. Our Biblical Counselling digital forms are stored on Jotform EU servers, and our Biblical Counselling information that is in printed and hand-written form are kept in a locked and secured facility. In addition, some data may be held by individual staff on church email accounts hosted by Google, Microsoft, and Apple.

How long will we keep your personal data?

Our general rule is to keep data no longer than necessary. Where you continue to actively engage with our church services, activities and events, we will retain the appropriate data for you so that we can best serve your involvement. We operate an annual process of review, by which we assess who is actively engaging in church life, and where this is not the case, we will remove your data.

Additionally:

We will keep some records permanently if we are legally required to do so. For example, this covers wedding registers and some safeguarding records.
We may keep some other records for an extended period. For example, it is current best practice to keep financial records for a minimum period of seven years to support HMRC audits.

What are your rights regarding your personal data?

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 it, and where we obtained it. Once we have received your request, we will respond within one month. There are no fees 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 about you is out of date, incomplete, or incorrect, you can inform us and your data will be updated.

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 it, you can request that we erase the data we hold. 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 purposes).

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 processing 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 withdraw your consent to processing at any time. You can withdraw your consent easily by telephone, email, or by post.

The right to lodge a complaint with the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at 0303 123 1113 or via email at ico.org.uk/global/contact-us/email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Transfer of data abroad

Any electronic personal data transferred to countries or territories outside the UK will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the UK. Our website is accessible from overseas; however, it is our general practice not to publish any personal data on our website.

Further Processing

If we wish to use your personal data for a new purpose not covered by this policy, then we will provide you with a new policy prior to commencing the processing to explain this new use and set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

You are very welcome to get in contact with us…

If you have any queries or concerns about how we use your data, please do get in contact with us.

Our Data Protection Lead and their contact details are given on the first page of this document.