This Template Fair Processing Statement (FPS) is a suggested form of wording for Managing Trustees to use to tell people where to find the privacy information required under the General Data Protection Regulation (GDPR). Unlike the Managing Trustees’ Privacy Notice (Privacy Notice) , the FPS is a template only and can be adapted by Managing Trustees to make the information as accessible as possible to their target audience.
While Managing Trustees are free to use alternative wording or vary the template FPS, please make sure individuals are directed to the Privacy Notice whether by hyperlinks or details of where the physical copy is displayed and ensure that nothing is included that contradicts the Privacy Notice produced by the Working Party. Please contact TMCP if you would like us to check the wording of your own fair processing statement for you.
Example 1 - Email or other electronic notification with hyperlinks:
Use the following form of FPS in electronic communications e.g. email, to tell people where to find your privacy information (the Privacy Notice).
Note that this FPS is directed at the person whose personal information the Local Church, Circuit or District is handling e.g. members, adherents, supporters of the Church and third party users. “Us” and “Our” refers to the local managing trustee body:
“[NAME OF CHURCH/ CIRCUIT/DISTRICT]*1 cares about your privacy and your trust is important to us. Our Privacy Notice explains how Local Churches, Circuits and Districts within the Methodist Church in Great Britain collect, use and protect your personal information. It also provides information about your rights and who to contact if you have any questions about how we use your information. Click here to read our Privacy Notice online or download a PDF version here. A copy is also displayed [DESCRIBE WHERE A PHYSICAL COPY IS DISPLAYED e.g. on the noticeboard in the room known as the “blue room”]. [NAME]*2 will try to deal with any questions as a local point of contact.”
The wording lets individuals know that the Church cares about their privacy and tells them where to find the detailed privacy information in the Privacy Notice. This electronic version uses hyperlinks meaning that clicking on the blue, underlined words in the text takes people directly to the document being referred to as well as the specific sections informing individuals about their rights and how to contact the Church.
Example 2 - Hardcopy documents:
Use the following form of wording in hardcopy documents e.g. letters, newsletters and forms to tell people where to find your privacy information (the Privacy Notice).
Note that this FPS is directed at the person whose personal information you are handling e.g. members, adherents, supporters of the Church and third party users:
“[NAME OF CHURCH/ CIRCUIT/DISTRICT]*1 cares about your privacy and your trust is important to us. Our Privacy Notice explains how Local Churches, Circuits and Districts within the Methodist Church in Great Britain collect, use and protect your personal information. It also provides information about your rights (paragraph 9 of the Privacy Notice) and who to contact (paragraph 1 of the Privacy Notice) if you have any questions about how we use your information. You can find our Privacy Notice online (www.tmcp.org.uk/about/data-protection/managing-trustees-privacy-notice) or displayed [INSERT DESCRIPTION OF WHERE PEOPLE CAN FIND YOUR HARDCOPY VERSION e.g. on the noticeboard in the blue Room]. [NAME]*2 will try to deal with any questions as a local point of contact. [Please ask us for a copy of the Privacy Notice if this would be of assistance.]*3”
The wording in this FPS lets individuals know that the Church cares about their privacy and tells them where to find the detailed privacy information in the Privacy Notice. It highlights the sections of the Privacy Notice dealing with individuals rights and how to make contact. This version of the FPS does not include any hyperlinks and relies on there being sufficient information in the notice itself.
Example 3 – Spoken word
If you are giving information over the telephone or in person please adapt the information in Example 2. Make it clear where the individual can find the Privacy Notice and offer to send them a hard copy or a link to a PDF version by email.
|*1||Insert the name of the Local Church, Circuit or District as appropriate e.g. High Street Methodist Church|
Insert a description or name of the person whom an individual can contact locally if they have any questions about the Privacy Notice.
The Privacy Notice includes contact details for the two controllers and lets individuals know who to contact locally if they have not been given specific information in the fair processing statement.
However, if possible please give a specific contact so that individuals have somebody to talk to locally. Remember that many of the individuals whose personal information the Church handles will already be familiar to the local contact being Church members, adherents, ministers, volunteers and lay employees etc.
If you have a local data champion please give their details, otherwise, somebody locally who would be happy to field enquiries.
Requests by individuals to exercise their legal rights (set out in paragraph 9 of the Privacy Notice) may be directed at the local contact but the controllers would assist that person in dealing with the requests and provide guidance on how to respond.
This section in square brackets relating to Managing Trustees providing a copy of the Privacy Notice on request is optional. Consider whether the local managing trustee body has the resources to provide a copy or if the managing trustee body is satisfied that the Privacy Notice is already sufficiently accessible.
If you have any questions please contact email@example.com on general data protection issues or firstname.lastname@example.org for queries specifically relating to safeguarding or complaints and discipline matters. We are reviewing the enquiries received and will continue to add to the existing frequently asked questions so that everybody can benefit from the practical points that you have raised with us.
Please note that this document is to provide guidance and assistance to Managing Trustees and their professional advisers. This guidance note is general in nature, may not reflect all recent legal developments and may not apply to the specific facts and circumstances of any particular matter.
Also note that nothing within the documents and guidance notes provided by TMCP nor any receipt or use of such information, should be construed or relied on as advertising or soliciting to provide any legal services. Nor does it create any solicitor-client relationship or provide any legal representation, advice or opinion whatsoever on behalf of TMCP or its employees.
Accordingly, neither TMCP nor its employees accept any responsibility for use of this document or action taken as a result of information provided in it.
Please remember that Managing Trustees need to take advice that is specific to the situation at hand. This document is not legal advice and is no substitute for such advice from Managing Trustees' own legal advisers.