Home Church Data Protection Policy
Home Church uses personal data about living individuals for the purpose of general church administration and communication.
These can include names, personal contact numbers, addresses, children's names and information, health data and other information about people we have a relationship with.
This policy describes how this personal data is collected, handled and stored to meet our data protection standards - and to comply with the law. This is inline with the EU General Data Protection Regulations (GDPR).
Why this policy exists
This data protection policy ensures Home Church:
Complies with data protection law and follows good practice.
Protects the rights of staff, the congregation and any associated partners.
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 Home 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 carefully collected, safely stored stored 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 specified, lawful purposes.
Be adequate, relevant and not excessive.
Be 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 or territory also ensures an adequate level of protection.
Data Protection Risks
This policy helps to protect Home 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 company uses data relating to them.
Reputation damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Home Church has 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 Board of Directors are ultimately responsible for ensuring that Home Church meets its legal obligations.
The Senior Leadership is responsible for:
Keeping the board updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Home Church holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Data Controller is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The Staff Team are responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
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.
Home Church will provide guidance to all employees and applicable volunteers to help them understand their responsibilities when handling data.
Employees and volunteers 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 disclosed to unauthorised people, either within the church 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 and approved volunteers should request help if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Controller.
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 on a printer.
Data printouts should be shredded and 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.
If data is stored on removable media (like a USB or CD), these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the church’s standard backup procedures.
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.
Personal data is of no value to Home Church unless the organisation can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
connect cards & prayer requests
As a religious organisation, Home Church provide Connect Cards in all services to give people the opportunity to get connected into the life of the church. When an individual fills out one of these connect cards, the following actions are taken:
- When a connect card is filled, this will be loaded into a secure database that staff and key volunteers are given access to by the data controller.
- Where a phone number is provided, a member of staff will call the individual to help with the enquiry.
- Once the information request has been fulfilled, the individuals information is removed from the database permanently.
Prayer Requests are also added to a central database that staff members and key volunteers are given access to by the data controller. Requests are actioned by the below ways:
- Prayer requests are collected and data placed into a central secure database. Staff members and key volunteers have access given to the by the data controller.
- If the individual has requested prayer, a member of staff or a key volunteer will call them during the week to pray for them.
- Prayer requests remain on the database for a maximum of two weeks, after which requests will be deleted.
The law requires Home Church to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Home Church should put into ensuring its accuracy.
It is the responsibility of all employees and approved volunteers who work with data to take reasonable steps to ensure it kept as accurate and up to date as possible.
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a person’s details when they call.
Home church will make it easy for data subjects to update the information Home Church holds about them. For instance, via the church website and church database using ChurchSuite.
Data should be updated as inaccuracies are discovered. For instance, if a person can no longer be reached on their stored telephone number, it should be removed from the database.
Subject Access Requests
All individuals who are subject of personal data held by Home 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 how the church is meeting its data protection obligations.
If an individual contacts the organisation requesting this information, this is called a subject access request.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
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, Home Church will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the organisation’s legal advisers where necessary.
Home Church aims to ensure that individuals are aware that their data is being processed, and that they understand:
How the data is being used
How to exercise their rights