St Philip’s Church Data Protection Policy
St Philip’s Church commits to follow the Data Protection principles laid out below.
St Philip’s Church needs to gather and use certain information about individuals. These can include members, attendees, church/business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the organisation’s data protection standards—and to comply with the law.
Why this policy exists
This data protection policy ensures St Philip’s Church:
- Complies with data protection law and follows good practice
- Protects the rights of staff, members and contacts
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data Protection Law
The Data Protection Act 1998 describes how organisations -including St Philip’s Church – must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be kept accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country of territory also ensures an adequate level of protection
This policy applies to all data that the organisation holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Plus, any other information relating to individuals
Data Protection Risks
This policy helps protect St Philip’s Church from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the organisation uses data relating to them.
- Reputational damage.For instance, the organisation could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with St Philip’s Church has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
- The Joint Church Council is ultimately responsible for ensuring that St Philip’s Church meets its legal obligations.
- The Team Vicar is responsible for:
- Keeping the JCC updated about data protection and responsibilities, risks and issues.
- Reviewing all data protection procedures.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data St Philip’s Church holds about them (also called ‘subject access requests’).
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Evaluating any third-party services the organisation is considering using to store or process data. For instance, cloud computing services.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosedto unauthorised people, either within the organisation or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Application of Guidelines
- Keeping ChurchSuite as our main database. We should minimise / eradicate where possible the number of places that personal information is stored. If other storage functionality is required, it must be password protected as a minimum standard.
- The number of people with access to ChurchSuite should be limited to essential users only. If people are not regular users / have never logged on, their access should be deleted until requested again and evaluated for need of access.
- Bi-annual checks should take place by all staff to ensure a regular review of data held is relevant and if unnecessary, shredded confidentially.
- All staff should ensure that their computers have regularly updated firewall protection and regular scans activated. The majority of computers have inbuilt protection – ensure this is on! If your usage would deem an external software package to be required, speak to the Team Vicar. E.g. any computer that processes card gifts is required to have recognised external software in addition to that which is inbuilt.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them,like a printer.
- Data printouts should be shreddedand disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Data should be backed up frequently. Those backups should be tested regularly.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Subject access requests
All individuals who are the subject of personal data held by St Philip’s Church are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the organisation is meeting its data protection obligations.
If someone contacts the organisation requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, St Philip’s Church will disclose requested data. However, the Team Vicar will ensure the request is legitimate, seeking assistance from the Joint Church Council and from the organisation’s legal advisers where necessary.
Adopted: May 2017
To be reviewed: May 2018