Privacy Notice

Privacy Notice

1. INTRODUCTION

The Diocese of Shrewsbury (the “Diocese”) is a charity registered with the Charity Commission in England and Wales. Our charity number is 234025 and our registered address is 2 Park Road South, Prenton, Wirral CH43 4UX. In this Notice, references to ‘we’ and ‘us’ mean the Diocese.

When you provide us with Personal Data in order to engage with us and/or benefit from our activities, we will keep a record of the data you give to us in order to enable us to comply with our statutory obligations and to achieve our charitable objects of advancing and maintaining the Roman Catholic religion through the operation of our parishes and our other activities.

For the purpose of the General Data Protection Regulation 2016/279 (GDPR), the Diocese through its Trustees will be a Data Controller in respect of your Personal Data. In some cases, the Diocese may be a joint Data Controller of your Personal Data (e.g. where your data is shared between the Diocese and another organisation for a particular purpose, for example a school or another Diocese). Please be aware that our parishes form part of the Diocese and are not separate legal entities. Parishes are not Data Controllers nor do they process Personal Data on behalf of the Diocese as a Data Processor.

Everyone has rights with regard to how their Personal Data is handled by organisations. The Diocese is committed to ensuring that Personal Data is properly and securely managed in accordance with the relevant data protection laws and believes this is an important part of achieving trust and confidence between the Diocese and those with whom it interacts. Please read this Notice to understand how we use and protect the information that you provide to us or that we obtain or hold about you, and to understand what your rights are in relation to information that we hold. This Notice applies to information about living identifiable individuals only.

2. WHAT PERSONAL DATA DO WE HOLD ABOUT YOU?

We may hold the following types of Personal Data:

We may also hold Special Categories of Personal Data e.g. information about your religious beliefs, information about your health and wellbeing, information revealing racial or ethnic origins, information concerning your sexual orientation or in the case of background checks, information about criminal records or proceedings.

We may also receive Personal Data about you from third parties, for example, your family members, other parishioners, other dioceses, medical professionals, the police and other law enforcement bodies.

3. HOW AND WHY DO WE PROCESS YOUR PERSONAL DATA?

The Personal Data which we hold about you, whether it is collected directly from you or whether we receive it from a third party, may be Processed in a number of ways, for example:

4. ANY OTHER WAYS.

Any information gathered through cookies and similar technologies via the Diocesan website or the website of any parish, is used to measure and analyse information on visits to the website, to tailor the website to make it better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.

5. ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

We must have a lawful basis for Processing your information; this will vary according to the circumstances of how and why we have your information but typical examples include:

If we Process any Special Categories of Personal Data we must have a further lawful basis for the processing. This may include:

If we Process any Personal Data comprising criminal convictions or offences we must also have a further lawful basis for the processing. This may include:

6. WHO WILL WE SHARE YOUR INFORMATION WITH?

We will only use your Personal Data within the Diocese for the purposes for which it was obtained, unless you have explicitly agreed that we may share your Personal Data with another organisation or unless we are otherwise permitted or required to under the Data Protection Rules or order of a Court or other competent regulatory body or as set out in this Notice.

We may share your information with other members of the Church seeking relief and any ecclesiastical body enjoying canonical jurisdiction or powers of governance as detailed in the Code of Canon law or the Apostolic Constitution Pastor Bonus.

We may share your information with government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime.

Sometimes the Diocese contracts with third parties whom we ask to Process Personal Data on our behalf (e.g. IT consultants, distributors of parish newsletters and directories).  We require these third parties to comply strictly with our instructions and with the GDPR.

We also may be required to share your Personal Data so that the Diocese can benefit from Gift Aid nominations you have made e.g. with HMRC.

We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the Personal Data that we hold.

In the course of Processing your Personal Data, or disclosing it to the recipients referred to above, we may transfer it to countries which are outside the European Economic Area (EEA), some of which may not have laws which provide the same level of protection to your Personal Data as laws inside the EEA. In such cases we will take steps to ensure that the transfers comply with the GDPR and that your Personal Data is appropriately protected. We do so by taking the following measures:

putting in place a contract with the recipient that means they must protect the personal information to the same standards as is required in the EEA;

transferring it to a non-EEA country with privacy laws that give the same protection as the EEA;

transferring it to organisations that are part of Privacy Shield (or any successor or replacement scheme). This is a framework that sets privacy standards for data sent between the US and EU countries to ensure that those standards are similar to what are used within the EEA;

transferring it to organisations or countries that have other approved certification schemes or codes in place; or

relying on another appropriate ground under applicable data protection laws.

7. HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

Your information will be kept in accordance with our Retention & Disposal of Records Policy, copies of which are available from the Diocesan Data Protection Officer. In any event, we will endeavour to only keep Personal Data for as long as is necessary and to delete it when it is no longer so.

8. YOUR RIGHTS

You have rights in respect of the Personal Data you provide to us. In particular:

the right to request a copy of some or all of the Personal Data that we hold about you (including, in some cases, in a commonly used, machine readable, format so that it can be transferred to other Data Controllers). We do not make a charge for this service;

if we Process your Personal Data on the basis that we have your consent, the right to withdraw that consent;

the right to ask that any inaccuracies in your Personal Data are corrected;

the right to have us restrict the Processing of all or part of your Personal Data;

the right to ask that we delete your Personal Data where there is no compelling reason for us to continue to Process it;

the right to object to us Processing your Personal Data for direct marketing purposes e.g. in relation to fundraising carried out by the Diocese; and

the right not to be subject to legal or other significant decisions being taken about you on the basis of an automated process (i.e. without human intervention).

Please note that the above rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to Process your Personal Data. Also, we may need you to provide us with proof of identity for verification and data security purposes before you can exercise your rights.

Rights may only be exercised by the individual whose information is being held by the Diocese or with that individual’s express permission. Children from around 12 years upwards are entitled to make their own requests (where the Diocese is of the reasonable view that they have an appropriate understanding of the request they are making) and parents / guardian / family members do not have an automatic right to see information about their child or prevent their child from making a request to the Diocese.

9. CHANGES TO THIS NOTICE

We may make changes to this Notice from time to time as our organisational practices and/or applicable laws change.  We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by data protection laws.

10. CONTACT DETAILS

If you have any questions, require further information about how we protect your Personal Data, if you wish to exercise any of the above rights, if you wish to opt out of receiving further communications from the Diocese or if you would like to provide feedback or make a complaint about the use of your information, please contact the Acting Diocesan Data Protection Officer, Carol Lawrence at the Curial Office, 2 Park Road South, Prenton, Wirral, CH43 4UX, 0151 6529855:

Any complaints will be dealt with in accordance with the Diocese’s Complaints Policy.

We hope that we can satisfy any queries you may have about the way in which we Process your Personal Data. However, if you have unresolved concerns you also have the right to complain to the Information Commissioner (‘ICO’) (www.ico.org.uk).

11. COOKIES

Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions e.g. to know who you are if you log into a restricted part of a website, for shopping carts, and for tracking purposes.

The Diocese uses the following cookies:

Google analytics. We use Google analytics cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website for example number of visitors and length of time on site. This process does collect data, but in an anonymous form, to help us make improvements, develop the website and enhance the user experience.

Privacy preferences. We use a tracking cookie, which is added to your computer, to remember your cookie preferences i.e. if you have allowed or disallowed them

Register for events. We have the ability for you to register for events on the website. If you do so this information goes directly into our database. In order to register our database adds an essential cookie (reaction server) to your computer.

12. MANAGE COOKIES

If you would like to opt-in or opt-out of using cookies then you should be able to do so using your browser. You can review your cookie settings at any time.

Please note that you cannot opt-out of the deployment of cookies that are necessary for delivery of our website or services to visitors.

13. COVID-19 TEST AND TRACE

During these unprecedented times, we have a legal duty to protect and promote the welfare of our parishioners, staff, volunteers and our clergy.

If an individual informs us that they have tested positive for COVID-19 or have symptoms of the virus we will notify you if you had been present with that individual at one of our Masses/events, so that you can take the necessary steps to protect yourself, your families and those who you have come into contact with.

In this situation we will not seek your consent to share your data with the health authorities as there is a Public Interest for us to do so. Your contact details will only be shared with the Health Authorities if required and within the Diocese of Westminster. We will keep a record of what information has been shared.

What information about you do we collect?

For the processing to which this notice relates, we collect the following information:

personal information – your name, residential address, email address, mobile or landline number

special category personal information – such as information about virus symptoms

How do we collect information about you?

Information is collected from parishioners who have booked to attend any Mass/event or from any existing parish database.   Identified individuals may provide details of other people they have had contact with, who may in turn be asked for details of others they have had contact with.

How will your information be used?

Your information will be used to contact you and persons who you have stated you have had contact with.

The legal basis for using your information

The legal basis for which we use your information is that it is of substantial public interest and to protect public health.

Who will your information be shared with?

We sometimes need to share your information within the Diocese of Westminster or with the Health Authorities. We will only share your information when necessary and when the law allows us to, and we will only share the minimum information we need to. The Diocese will never sell your information to anyone else.

How long will we keep your information?

We will keep your information for a maximum of 1 month after the date of the Mass/event that you attended.

 

14. GLOSSARY

Data Controller” means a person, organisation or body that determines the purposes for which, and the manner in which, any Personal Data is processed. A Data Controller is responsible for complying with the data protection laws including the GDPR and establishing practices and policies in line with them.

Data Processor” means any person, organisation or body that Processes personal data on behalf of and on the instruction of the Diocese. Data Processors have a duty to protect the information they process by following data protection laws.

Data Subject” means a living individual about whom the Diocese processes Personal Data and who can be identified from the Personal Data. A Data Subject need not be a UK national or resident. All Data Subjects have legal rights in relation to their Personal Data and the information that the Diocese holds about them.

Personal Data” means any information relating to a living individual who can be identified from that information or in conjunction with other information which is in, or is likely to come into, the Diocese’s possession. Personal Data can be factual (such as a name, address or date of birth) or it can be an opinion (e.g. a performance appraisal). It can even include a simple email address. A mere mention of someone’s name in a document does not necessarily constitute Personal Data, but personal details such as someone’s contact details or salary (if it enabled an individual to be identified) would fall within the definition.

Processing” means any activity that involves use of Personal Data. It includes obtaining, recording or holding the information or carrying out any operation or set of operations on it, including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring or disclosing Personal Data to third parties.