The Data Protection Working Party received a number of constructive comments of a practical nature from Managing Trustees in relation to the Data Collection Consent Form (‘the Consent Form’) which was published on the TMCP website in March 2018. In light of those comments the Consent Form has been updated to include the following:
- Additional space for contact details expressly for publication in the Local Church/Circuit/District Directory;
- A signature strip; and
- Date confirmation showing clearly the date consent was given
The first addition has been included because some individuals may be happy for their Local Church, Circuit and/or District to contact them about fundraising, for instance but perhaps do not want all of their details published in the Directory.
The second and third additions have been added so that it can be recorded that the Consent Form has been completed by the individual concerned and shows the date when their consent was given. It is generally recognised that consent lasts for a period of up to two years but this is subjective. Managing Trustees will need to consider and record reasons why consent may need to be renewed in certain circumstances more frequently than 2 years.
An important point for Managing Trustees to note there is no need for consent to be obtained from Ministers in Full Connexion or probationers, for the inclusion of their contact details within the Directory or for administration purposes. The General Data Protection Regulation contains several lawful basis for processing data, only one of which is consent. As a membership organisation, it is expected the Methodist Church will generally be relying on the lawful basis of legitimate interest for dealing with the personal data of members, particularly officeholders.
The contact details of ministers need to be processed, not only for the administration of the District, but also because ministers need to be available and contactable by members of a Local Church and those seeking pastoral care. Presbyters when ordained enter into a life long ministry of word, sacrament and pastoral responsibility in the Church of God which they fulfil in various capacities and to a varying extent throughout their lives, see Standing Order 700(1). Deacons when ordained to a life-long ministry of serve and witness in and on behalf of the Church of God, which they fulfil in pastoral care, outreach and worship in various capacities and to a varying extent throughout their lives, see Standing Order 701(1). In light of the ministry of both presbyters and deacons, it is a reasonable expectation for any minister to have their contact details processed by the District for its directories along with those of the Circuit. Finally a comprehensive Toolkit for Managing Trustees will be provided by the Working Party before 25 May 2018 which will include key policies and procedures along with various template documents, including a Consent Register. A separate article is being produced for the website on this issue and will contain more details.