GENERAL PRIVACY NOTICE

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This Privacy Notice is for non-role holders.

Date of Policy: Effective as of 26th Feb 2026 

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This is the privacy statement and data protection policy for St Mary the Virgin, Riverhead with Dunton Green. 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. As with all policy statements, it is a bit wordy! Please don’t let this put you off, and if you require clarification on any points, please get in touch with our Data Protection Lead, who will be happy to help.

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Your personal data – what is it?

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“Personal data” is any information about a living individual which allows them to be identified from that data (for example, a name, photographs, videos, email address, or address).

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Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Bill/Act 2017 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).

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Who are we?

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This Privacy Notice is provided to you by the Parochial Church Council (PCC) of St Mary the Virgin, Riverhead with Dunton Green. 

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The Church of England is made up of a number of different organisations and office-holders who work together to deliver the Church’s mission in each community.

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The PCC works together with:

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the incumbent of the parish (that is, our [vicar or rector]);
the bishops of the Diocese of Rochester; and
the Diocesan Office, which is responsible for the financial and administrative arrangements for the Diocese of Rochester.

As the Church is made up of all of these persons and organisations 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 community. The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

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Each of the data controllers have their own tasks within the Church and a description of what data is processed and for what purpose is set out in this Privacy Notice. This Privacy Notice is sent to you by the PCC on our own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.

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What data do the data controllers listed above process?

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St Mary the Virgin, Riverhead with Dunton Green.  processes data containing:

 

Names, titles, aliases, photographs;

Contact details such as telephone numbers, addresses, and email addresses;

Where there is a legitimate interest to carry out our charitable aims and activities, or where you have provided them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependents.

Where you give financially in support of St Mary the Virgin, Riverhead with Dunton Green, or pay for church activities (event bookings, etc.), financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;

The data we process is likely to constitute sensitive personal data because, as a church, the 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: racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received or data concerning criminal records.

How do we process your personal data?

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The data controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; not to collect or retain excessive amounts of data; to keep personal data secure; 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.

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What do we use your data for?

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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 a church.

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Therefore, we will hold and process data to:

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• enable us to meet all legal and statutory obligations (which include maintaining and publishing our electoral roll in accordance with the Church Representation Rules);

• carry out comprehensive safeguarding procedures (including due diligence and complaints handling) 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;

• minister to you and provide you with pastoral and spiritual care (such as visiting you when you are gravely ill or bereaved) and to organise and perform ecclesiastical services for you, such as baptisms, confirmations, weddings and funerals;

• deliver the Church’s mission to our community, and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in the constitution and statutory framework of each data controller;

• administer the parish, deanery, archdeaconry and diocesan membership records;

• fundraise and promote the interests of the Church and charity;

• maintain our own accounts and records;

• process and record financial donations that you have made (including Gift Aid information);

• seek your views or comments;

• notify you of changes to our services, events and role holders;

• send you communications which you have requested, and that may be of interest to you. These may include information about campaigns, appeals, and other fundraising activities.

• process a grant or application for a role;

• enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;

What is the legal basis for processing your personal data?

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Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as another organisation in the Church of England). For example, maintaining membership records, safeguarding our children, recording our financial donations and operating team rotas for the effective function of Sunday services.

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.
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 the hire of church facilities or buying tickets for a church event.

Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.

Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.

Will we share your personal data?

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Your personal data will be treated as strictly confidential. 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):

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The appropriate bodies of the Church of England, including the other data controllers;

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• Our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software.

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

• On occasion, other churches with which we carry out joint events or activities.

How long will we keep your personal data?

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In general, we will endeavour to keep data only for as long as we need it. Where you continue to actively engage with our church services, activities and events, we will retain the appropriate membership data for you so that we can best serve your involvement. This means that we may delete it when it is no longer needed.

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Additionally:-

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We will keep some records permanently if we are legally required to do so.

We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 7 years to support HMRC audits.

What are your rights in respect of your personal data?

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You have the following rights with respect to your personal data:

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When exercising any of the rights listed below, 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

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1. The right to access information we hold on you

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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 the information and where we obtained the information from. Once we have received your request, we will respond within one month.
There are no fees or charges for the first request, but additional requests for the same data may be subject to an administrative fee

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2. The right to correct and update the information we hold on you

If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.

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3. The right to have your information erased

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If you feel that we should no longer be using your data or that we are illegally using your data, 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 purpose(s).

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4. The right to object to the 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 to process 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.

5. The right to data portability

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You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.

6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.

You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).

7. The right to lodge a complaint with the Information Commissioner’s Office.

Transfer of Data Abroad

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Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas, so on occasion, some personal data (for example, in a newsletter) may be accessed from overseas.

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Further processing

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If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use before 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.

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