METROPOLITAN TABERNACLE DATA PRIVACY NOTICE

THE PURPOSE OF THIS PRIVACY NOTICE

This privacy notice gives you information about our use of personal data for the purposes of our activities and ministries as a church.  We may need to update this privacy notice from time to time.

DATA CONTROLLER

The Data Controller is the Elders’ and Deacons’ Court of the Metropolitan Tabernacle (the “E&DC”).

The E&DC has appointed a data privacy manager who is responsible for overseeing the collection and processing of personal data by the Metropolitan Tabernacle, including questions arising from this privacy notice.  If you have any questions about this privacy notice, including any requests to exercise your legal rights as set out below, please contact the data privacy manager using the details below.

CONTACT DETAILS

Mailing address:                           
Data Privacy Manager
Metropolitan Tabernacle
Elephant & Castle
London
SE1 6SD
Email address: DataManager@MetropolitanTabernacle.org
Telephone number: 020 7735 7076

PERSONAL DATA

Personal data is any information relating to an identified or identifiable living individual.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

Our use of personal data is lawful where it is with your consent or is necessary for:

-The performance of a contract that we have with you
-Compliance with a legal obligation to which we are subject
-The purposes of legitimate interests that we pursue, except where such interests are overridden by your interests or fundamental rights and freedoms
-The protection of your vital interests

Some special categories of personal data may only be processed lawfully where certain additional conditions are satisfied.  As a not-for-profit body with a religious aim we process such categories of data in the course of our legitimate activities and solely in relation to our members, former members or persons who have regular contact with us. We may also process certain special category data in exceptional circumstances in your vital interests – see Disclosure of Your Personal Data below.

OUR USE OF PERSONAL DATA AND THE LEGAL BASIS FOR THAT USE

Our use of personal data: Extending pastoral care                       
Legal basis: Legitimate interest                       
Legitimate interest: Fulfilling ministry of church

Our use of personal data: Maintaining contact with visitors to services                      
Legal basis: Legitimate interest                         
Legitimate interest: Fulfilling ministry of church

Our use of personal data: Closed-circuit television cameras in pastoral staff rooms (images only)
Legal basis: Legitimate interest
Legitimate interest: Security of staff and premises 

Our use of personal data: Applications for baptism and church membership
Legal basis:  Legitimate interest                       
Legitimate interest: Fulfilling ministry of church

Our use of personal data: Baptism and membership records                       
Legal basis: Legitimate interest                         
Legitimate interest: Maintaining accurate records

Our use of personal data: Participation of volunteers in ministries and activities of church          
Legal basis: Legitimate interest                         
Legitimate interest: Facilitating volunteering while ensuring that participation is appropriate, including relevant safeguarding issues

Our use of personal data: Care of the elderly and infirm
Legal bases: Legitimate interest, vital interests
Legitimate interest: Fulfilling ministry of church

Our use of personal data: Assistance to those with social needs
Legal basis: Legitimate interest
Legitimate interest: Fulfilling ministry of church

Our use of personal data: Maintaining financial records, including Gift Aid
Legal bases: Legitimate interest, legal duty
Legitimate interest: Maintaining ministries of church and compliance with legal requirements

Our use of personal data: Tabernacle audio-visual ministry
Legal bases: Legitimate interest, fulfilling contract
Legitimate interest: Fulfilling ministry of church

Our use of personal data: E-magazine
Legal bases: Legitimate interest, fulfilling contract
Legitimate interest: Fulfilling ministry of church

Our use of personal data: London Reformed Baptist Seminary
Legal bases: Legitimate interest, fulfilling contract
Legitimate interest: Extending encouragement and help to serving and aspiring preachers and church workers in the UK and overseas.

Our use of personal data: Annual School of Theology
Legal bases: Legitimate interest, fulfilling contract
Legitimate interest: Extending ministry on current issues of interest and concern

Our use of personal data: Other special meetings and events
Legal bases: Legitimate interest, fulfilling contract
Legitimate interest: Extending ministry on current issues of interest and concern

Our use of personal data: Provision of support for pastors and Christian workers in other churches including publication of news about their ministries
Legal basis: Legitimate interest
Legitimate interest: Fulfilling ministry of church

Our use of personal data: English classes
Legal basis: Legitimate interest
Legitimate interest: Provision of assistance to those with no or limited knowledge of English

Our use of personal data: BSL classes
Legal basis: Legitimate interest
Legitimate interest: To enlarge the number of hearing persons able to communicate with the deaf 

Our use of personal data: Information about our ministries and other events sent by email
Legal basis: Consent

We also use personal data for the following purposes, for which we have separate privacy notices:

Our Activities for Children
The Sword & Trowel magazine and certain other materials sent by post 
The Tabernacle Bookshop 

FAILURE TO PROVIDE OR UPDATE DATA

It is important that the data we hold about you is accurate and current.  Please keep us informed if there are any changes.

We may be unable to keep in contact with you, to provide you with care or assistance that you have requested or to perform contractual obligations to you if your data is not kept up-to-date.

DISCLOSURE OF YOUR PERSONAL DATA

We will not disclose your personal data to any external third party except:

-With your consent, or
-For the purposes of processing payments, or
-Where we are required to do so by law, or
-As stated in the separate privacy notices referred to above, or
-In the exceptional circumstances described immediately below

If we are helping to provide care for you and we have important information about your health, we may disclose it if it is in your vital interests to do so in an emergency in which you are unable to give consent for yourself.

DATA SECURITY

We deal with all personal data carefully and have put in place measures with a view to preventing any such personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We issue each year to members of the church a list of the names of all current church members with the dates when each became a member, and a list of the names and ages of children under the age of 16 of current church members.  Access to all other personal data is strictly limited to those of our officers, employees, volunteers, agents and contractors who have a need to know it.  They are under a duty of confidentiality and a duty only to use such personal data for the relevant purposes of the church as set out in this notice.

DATA RETENTION

We will retain your personal data for as long as is reasonably necessary for the relevant purpose set out in this notice and in order to comply with legal requirements for the retention of certain data.

We retain indefinitely records of those who are or have been members of the church.  Otherwise, unless we have specific consent, and subject to any legal requirements for the retention of data, we delete special category data (including data relating to health conditions) that we hold for any person who no longer has regular contact with us.

Debit or credit card details provided to us for the purposes of making a payment are deleted or destroyed as soon as the payment has been processed.

In some circumstances you can ask us to delete your data (see erasure request below).

In addition to your legal right to request erasure you can ask us to delete information we hold about you (other than membership information) at any time.  We will review any such request and unless there is some legal reason for us to retain the information we will delete it.

YOUR LEGAL RIGHTS

Unless subject to an exemption under relevant legislation you have the following rights in respect of your personal data:

-Where we rely on your consent to process your data you may at any time withdraw your consent but this right does not affect the lawfulness of any processing of your personal data before such withdrawal
-The right to request a copy of your personal data which we hold
-The right to request transfer of your data to another person (data portability)
-The right to request correction of any personal data that is inaccurate, incomplete or out of date
-The right to request erasure of your personal data where it is no longer necessary for us to continue processing it, where you have successfully exercised your right to object to processing, where we have processed your data unlawfully or where the law otherwise requires your data to be erased
-The right to object to processing of your personal data where you consider that your interests or personal rights and freedoms override our legitimate interests described above
-The right to request restriction of processing where you have disputed the accuracy of the data or the lawfulness of the processing, or where you wish us to retain data that we would otherwise delete

Your right to request transfer of your data to another person applies to data that you have provided to us and that we process by electronic means either with your consent or for the purpose of a contract that we have with you.

We can transfer such data where you have provided it to us via our website to enable us to send you information about our ministries by email.

Information that you have given us for the purpose of a contract that we have with you consists of your name, contact details and the goods or services requested.  It is held in manual records and an OMNIS database.  While we will endeavour to provide such data we are not able to develop systems to enable it to be transferred automatically in a machine readable format.

Before responding to a request or objection we may need to request specific information from you as a security measure to ensure that your or your child’s personal data is not disclosed to any person who has no right to receive it.

You will not have to pay any fee to exercise these rights.  However, we may charge a reasonable fee for, or may refuse to comply with, any request that is clearly unfounded, excessive or repetitive.

We try to respond to all requests within one month.  If it will take longer because your request is complex we will notify you and keep you updated.

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

Issue 2
24 August 2018