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ICCM Privacy Notice
Please read this notice carefully as it provides information about the different types of personal data that we collect and how we will use it, and your rights to it.
1. Personal data
Personal data is information that relates to a living individual who can be identified from that information. Identification can be by the information alone or in conjunction with any other information in the controller’s possession or likely to come into such possession. The processing of personal data is governed by data protection law including the General Data Protection Regulation (the ‘GDPR’).
Data protection law recognises certain categories of personal data as sensitive and therefore requiring more protection. These categories of data include information about your religious beliefs, and health data, among others. We will only process this data if there is a valid reason for doing so and where the law allows us to do so.
2. Data Controller
ICC Missions (company number 4272228, charity number 1092123) is the 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?
ICC Missions 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 personal data for the following purposes: -
• to administer membership (including to maintain records);
• for pastoral care;
• to provide events, activities and services;
• to promote the interests of the church;
• to manage employees and volunteers;
• to maintain our financial accounts and records (including the processing of Gift Aid);
• to administer contributions and payments;
• to comply with any legal requirements (including employee payroll reporting, DBS checks);
• to communicate with you in general when you contact us;
• where necessary, to protect the church, its employees, volunteers, and members.
4. What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests in fulfilling our charitable aims to advance the Gospel of Jesus Christ and the relief of poverty. The law allows us to process personal data where we have a legitimate interest and our use of the personal data is fair, balanced and does not unduly impact your rights.
We may also request consent to process your personal data for a specific purpose (for example, when taking photographs in certain situations). You always have the right to withdraw your consent.
We also process personal data where:
• it is necessary for the performance of a contract with you; or
• it is necessary for us to comply with a legal obligation.
5. Sharing 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. To facilitate church activities and events, we may share personal data with venues and hosts.
ICC Missions is part of a worldwide fellowship of churches and from time to time we may share your personal data with them for the purposes of facilitating the fellowship and maintaining contact between the churches (see for example https://www.disciplestoday.org/).
Your personal data will be provided to our employees and volunteers who require it in connection with our work, and may be provided to third party suppliers who process personal data on our behalf. The third parties in question will be required to use any personal data they receive in accordance with our instructions.
We may disclose your personal data to third parties:
• such as professional advisers e.g. accountants and lawyers, where necessary to protect the church and its members, volunteers and employees;
• if we are under a legal or regulatory obligation to do so; and/or
• in connection with any legal proceedings in order to protect the church and its members, volunteers and employees.
6. International data transfers
From time to time the personal data we collect from you may be transferred to and stored in a location outside the UK or the European Economic Area (‘EEA’). For example, when we use cloud providers such as ChurchSuite whose servers may be based in other countries.
Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal data, including lower security protections. Where your personal data is transferred outside the UK or EEA in a country which does not offer an equivalent standard of protection, we will take all reasonable steps to ensure that the recipient implements appropriate safeguards to protect your personal data. If you have any questions about the transfer of your personal data, please contact us using the details below.
7. How long do we keep data?
We will keep your personal data only for as long as required in connection with the purpose for which it is held. For example:
We may keep membership records for longer for the purposes of pastoral care and historic referencing, and we will keep financial records for a minimum of 6 years as required by statute.
If you would like further information about this, please contact us using the details below.
8. 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: -
• If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time;
• The right to request a copy of the personal data which ICC Missions holds about you (a Subject Access Request or ‘SAR’);
• The right to request that ICC Missions 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 ICC Missions to retain such data;
• The right, in certain circumstances, to request that ICC provide you with your personal data and where possible, to transmit that data directly to another data controller.
• 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;
• The right to lodge a complaint with the Information Commissioners Office.
9. Updating this privacy notice
We may update this notice, for instance if we wish to use your personal data for a new purpose or change the way in which we process your personal data. If we update this notice in a way that significantly changes how we use your personal data, we will bring these changes to your attention where reasonably possible. Otherwise, you can access the latest version of this notice on our website.
10. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the ICC Missions UK Administrator at [email protected] or write to us at Tower Bridge House, St. Katharine’s Way, London E1W 1DD.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
[16-May-2019]
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