Data Protection Policy
C3 Hope is part of the charity Hope City Church. Our registration with the Information Commissioner’s Office is under the charity’s name.
As a family of churches, we use personal data about living individuals for the purpose of general church administration and communication.
We recognise 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 (GDPR).
Hope City Church fully endorses and adheres to the eight principles of the 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 C3 Hope 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 other countries or territories 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.
- Maintaining Confidentiality
Hope City Church will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the leadership and ministry overseers/coordinators and administrators of the church in order to facilitate the administration and day-to-day ministry of the church.
All Hope City Church staff and volunteers who have access to Personal Data will be required to agree to sign the Confidentiality and Data Protection Policies.
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.
- Use of Personal Information
Your data will be used for three main purposes:
- The day-to-day administration of the church; e.g. pastoral care and oversight including calls and visits, preparation of ministry rotas, maintaining financial records of giving for audit and tax purposes including collecting information from online giving platforms & for gift aid purposes. (this is not an exhaustive list)
- Contacting you to keep you informed of church activities, events and projects.
Statistical analysis; gaining a better understanding of church demographics.
N.B. although collated church data may be passed to a third party, such as number of small groups or small group’s attendance, no personal data will be disclosed.
- Collection of Data
Data is collected or passed through to C3 Hope in a variety of ways including:
- Sign Ups for more information about church (electronic app based or paper based)
- Children or Teenager registration forms (mostly app based) for Hope Kids or Youth
- Connection / Forms on C3 Hope website (and associated domains)
- Booking websites such as Eventbrite
- Interest Capture Sheets at Events or on Outreach
- Information Gathering through Consultation Forms / Surveys
- Through your communication with us
For all of these methods of data collection, the method of collection, storage and sharing will be subject to GDPR regulations.
- The Church Database
Information contained on the database will not be used for any other purposes than set out in this section. The database is accessed through the ‘cloud’ and therefore, can be accessed through any computer or smart device with internet access.
C3 Hope has selected Planning Center (https://www.planningcenter.com/) to host the pastoral database. Planning Center are a Data Processor of our data and they have extensive policies, Q&As and support on their website to give information on how they store and control data.
- 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. This is controlled by the Data Controller and other specified administrators. These are the only people who can access and set these security parameters. This list is regularly checked and maintained.
- People who will have secure and authorised access to the database include C3 Hope Staff, data in-putters, Department Heads, Ministry Team Leaders, Life Group Leaders, Connect Leaders, Hope City Church Resource Support team & Hope City Trustees.
- Each user will only be given access to the appropriate part of the Planning Center database.
- All access and activity on the database is logged and can be viewed by the Database Controller.
- Subject Access - all individuals who are the subject of personal data held by Hope City Church are entitled to:
- Ask what information the church holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed what C3 Hope is doing to comply with its obligations under the 1988 Data Protection Act.
- Personal information will not be passed onto any third parties outside of the church environment (with regard to Section 1 – Maintaining Confidentiality)
Subject Consent - The need to process data for normal purposes has been communicated to all data subjects. In certain cases, depending on the sensitivity of the information being processed and the usage of the information, express consent is required to process data. This will be communicated individually.
Planning Center servers are based in the US. C3 Hope has signed a Data Protection Addendum with Planning Center which includes a Standard Contractual Clause to ensure that your data is stored and processed in adherence to GDPR regulations.
C3 Hope will retain some data outside of Planning Center. This data will be stored in a manner consistent with all GDPR regulations.
The primary system will be our Office Management and Communication system (Microsoft Office 365). All the data stored on Microsoft 365 are stored securely on servers based in the UK.
We may also make use of additional applications. A log will be kept of these tools and what data is stored on them. These will only be used for specific purposes. (for example, we may make use of a Mail Management tool like MailChimp or a Text Out service). The data will only be available to be accessed by specific members of the team through individual user login.
- Rights to Access Information
Employees and other subjects of personal data held by Hope City Church have the right to access any personal data that is being held on them.
This right is subject to certain exemptions (see section 1 – Maintaining Confidentiality). Personal Information may also be withheld if the information relates to another individual.
All church members can access the data stored on Planning Center through the application itself. In the app, you are able to update any personal information which is incorrect.
Any person who wishes to exercise this right should make the request in writing to the C3 Hope Data Officer on email@example.com. We will contact you electronically to verify your identity (and to clarify the request if necessary)
If any personal details are inaccurate, they can be amended upon request.
We aim to comply with requests for access to personal information as quickly as possible but will ensure that it is provided within 30 days of receipt of a completed form 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.
The data will be provided in a readable electronic format.
- Further Information
Hope City Church is a Registered Charity Number 1119791 and a Company Limited by Guarantee Registered Number 05999100.
If you have any questions or require further information on anything data related, please contact us on firstname.lastname@example.org
Information Commissioner’s Office - https://ico.org.uk/
This is for governing body for Data Protection in the UK. It also includes information on changes post Brexit.
On the below links you can read about Planning Center’s Privacy Information and GDPR information.
Congregant Privacy - https://www.planningcenter.com/congregant-privacy
GDPR - https://www.planningcenter.com/gdpr
Title: Data Protection Policy
Policy Version: 1.2
Author: Viv Brownlee