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Data Protection Policy
CATHEDRAL PARISH OF
THE RUSSIAN ORTHODOX CHURCH ABROAD (LONDON)
Data Protection Policy
October 2010: first approved by Archbishop Mark
May 2013: reviewed, amended and approved by Archpriest Peter Baulk
May 2016: reviewed, amended and approved by Archpriest Peter Baulk
April 2018: reviewed and approved by Bishop Irenei
May 2018: reviewed, amended and approved by Bishop Irenei
The Cathedral Parish of the Russian Orthodox Church Abroad (London) [hereafter “the Parish”] uses personal data about living individuals for the purpose of general church administration and communication.
The Parish recognises the importance of the correct and lawful treatment of personal data. All personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the General Data Protection Regulation 2017 [GDPR].
The Parish fully endorses and adheres to the eight principles of GDPR. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for the Parish must adhere to these principles.
The principles require that personal data shall:
- Be processed fairly and lawfully and shall not be processed unless certain conditions are met.
- Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose.
- Be adequate, relevant and not excessive for those purposes.
- Be accurate and where necessary, kept up to date.
- Not be kept for longer than is necessary for that purpose.
- Be processed in accordance with the data subject’s rights.
- Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures.
- Not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
1. Maintaining Confidentiality
The Parish will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the clergy, the Parish Trustees, and the Parish Council in order to facilitate the administration and day-to-day ministry of the Parish.
All Parish staff and volunteers who have access to Personal Data will be obliged to adhere strictly to the implementation of confidentiality in connection with Personal Data.
There are four exceptional circumstances to the above permitted by law:
- Where we are legally compelled to do so.
- Where there is a duty to the public to disclose.
- Where disclosure is required to protect your interest.
- Where disclosure is made at your request or with your consent.
2. Use of Personal Information
The Parish will use your data for three main purposes:
- Day-to-day administration of the Parish: e.g. pastoral care and oversight including but not limited to maintenance of membership lists; placing on the Parish noticeboard a list of members of the Parish in preparation for the Annual Parish Meeting; maintenance of financial records for audit and tax purposes; maintenance of identity documents for inspection by the Home Office (UK Visas & Immigration); and the maintenance of documentation related to D&BS checks.
- Contacting you to keep you informed of Parish activities and events.
- Statistical analysis; gaining a better understanding of parish demographics.
Information contained on the database will not be used for any other purposes than set out in this section.
- Access to the database is strictly controlled through the use of name specific passwords, which are selected by the individual.
- Those authorised to use the database only have access to their specific area of use within the database.
- People who may have secure and authorised access to the database include clergy, Parish Trustees, and members of the Parish Council. The database will NOT be accessed by any authorised users outside of the EU, in accordance with the Data Protection Act, unless prior consent has been obtained from the individual whose data is to be viewed.
- Subject Access – all individuals who are the subject of personal data held by the Parish are entitled to:
- Ask what information the Parish holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed what the Parish is doing to comply with its obligations under the 1988 Data Protection Act and the 2017 General Data Protection Regulation.
- Subject Consent – The need to process data for normal purposes will be communicated to all data subjects. In some cases, if the data is sensitive, (for example, information about health, race or gender) express consent to process the data must be obtained.
Rights to Access Information
Employees and other subjects of personal data held by the Parish have the right to access any personal data that is being held in certain manual and computerised filing systems. This right is subject to certain exemptions: personal Information may be withheld if the information relates to another individual.
Any person who wishes to exercise this right should make the request in writing to the Parish Secretary, using the standard letter which is available online from https://ico.org.uk/ and enclosing payment of the subject access request fee, currently £10. If personal details are inaccurate, they can be amended upon request. The Parish aims to comply with requests for access to personal information as quickly as possible and will ensure that it is provided within 40 days of receipt of a properly completed request, unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.