This is the privacy notice for the Trustees for Methodist Church Purposes (TMCP) explaining how TMCP deals with personal information that it collects and uses for its own purposes. This privacy notice was last updated on 28 May 2019 and is available online or on request from firstname.lastname@example.org. Where this date is later than the “last updated” date on the webpage this is because formatting amendments have been made that do not impact on the content of this privacy notice.
Welcome to the privacy notice for the Trustees for Methodist Church Purposes (TMCP).
TMCP respect your privacy and are committed to protecting your personal information (personal data). This privacy notice lets you know how we look after your personal data which either you provide to us or we obtain and hold about you and it tells you about your privacy rights and how the law protects you.
This privacy notice is available online in a layered format so you can click through to the specific areas that you may be interested in. These are set out below. Alternatively you can download a PDF version by clicking the 'Download' link at the top of this page or you may have been provided with a hardcopy (printed) version of the notice. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how TMCP collect and process your personal data which either you provide to us or we obtain and hold about you through your use of our websites (including any data you may provide when you subscribe to receive updates through the News Hub or contact us using the online contact form) or through other interactions with TMCP (including any data that you provide when you contact us for guidance, ask us to make payments, ask us to liaise with professionals on your behalf or in the case of members of staff and volunteers of TMCP, when you perform services for us).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or dealing with personal data about you (e.g. employment privacy notices) so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Trustees for Methodist Church Purposes (being a charitable body corporate established by the Methodist Church Act 1939 and registered charity number 1136358) (TMCP) is the controller and responsible for your personal data (collectively referred to as TMCP, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:
|Full name of legal entity:||Trustees for Methodist Church Purposes|
|Postal address:||Central Buildings |
|Name of Data Privacy Manager:||Laura Carnall, Legal Manager|
|Telephone number:||0161 235 6770|
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation. We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online notice regularly to see if any updates have been made.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about our Board Members, employees, visitors to our premises and our websites, Managing Trustees, ministers, volunteers, individuals who provide services to us and individuals who contact us. We have grouped the different kinds of personal data together as follows:
- Administrative Data includes details about you included in minutes taken at Board, executive and committee meetings, internal staff and team meetings and external meetings; invoices; supplier and contractor details; catering records and back-up files e.g. something that you said in a staff or Board meeting that could identify you.
- Contact Data includes home address, email address and telephone numbers e.g. information used to contact you.
- Correspondence Data includes information and opinions expressed in correspondence that you enter into with us via our website contact functions, email, post and records of telephone conversations with us.
- Employment Data includes employment history, training/development records, pension and wage information, details about next of kin, records from internal reviews, appraisals, sick notes, internal complaints and discipline, requests made by you and other details relating to your employment by us.
- Expenses Data includes details of expenses claimed by you and payments made to you including those relating to out of pocket expenses relating to attendance at meetings and events.
- Financial Data includes bank account and payment card details.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, signature and gender including any copy ID documents that you may provide to us from time to time.
- Image Data includes photographs taken of you where it is possible to identify you e.g. portraits of employees and Board members on our websites, images of you caught by any CCTV or similar devices at our premises and images of you taken to be used in training videos, webinars or promotional materials.
- Marketing and Communications Data includes your preferences in receiving information from us about TMCP, our work and wider Methodist Church in Great Britain events and our third parties and your communication preferences.
- Member and Group Data includes details of membership of the Methodist Church in Great Britain and specific managing trustee bodies and boards of trustees including the TMCP Board, offices held, other duties and roles that you carry out in relation to TMCP and the wider Church and details of members e.g. biographical information.
- Official Records includes lists of Board Members, records of resolutions and lists of visitors to our offices.
- Recruitment Data includes information relating to candidates for paid and unpaid roles with TMCP including CVs, application letters and forms, interview records and score sheets.
- Special Categories of Data includes your race or ethnicity, your religious beliefs, sex life, sexual orientation, information about your health, also information about criminal convictions and offences in keeping with the Safeguarding Policy of the Methodist Church in Great Britain.
- Tax Data includes national insurance numbers and other information that may be required by HMRC relating to tax related payments and receipts.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites or social media operated by us or our suppliers.
- Transaction Data includes details about payments to and from you and personal information contained in deeds and documents relating to transactions e.g. sales, purchases, tenancies, leases and licences that you enter into with us and/or Managing Trustees relating to premises.
- Usage Data includes information about how you use our websites, products and services.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation under a tenancy agreement or process gift aid payments). We will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct exchanges. You may choose to provide personal information to us direct e.g. by speaking to us over the telephone, in person, by corresponding with us by post, phone, email, through the online contact form, signing up to the News Hub section of our website or otherwise. This includes personal data you provide when you:
- apply for paid or voluntary roles with us; or
- enter into contracts with us to provide services; or
- sign up to receive notifications from us;
- compete forms including treasurer and trustee update forms and expense forms;
- provide identification documents; or
- otherwise contact us.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Your family members;
- Professional advisers;
- Local Churches, Circuits and Districts;
- The Connexional Team;
- Ecumenical partners of Local Churches, Circuits and Districts in the case of shared churches and Local Ecumenical Partnerships;
- General members of the public who contact us from time to time e.g. neighbours of Church property;
- Identity and Contact Data from publicly available sources such as Companies House, the Charity Commission and the Electoral Register based inside the EU;
We take our obligations under data protection law (including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018) seriously. We keep personal data as up to date as possible and take active steps to rectify any personal data we find to be incorrect. We store and destroy personal data securely and do not collect or retain personal data which is in excess of our processing activities. We take steps to protect all personal data (including Special Category Data) from loss, misuse, unauthorised access and disclosure by ensuring that appropriate measures are in place to protect personal data.
We ensure that personal data is processed in accordance with the principles of the GDPR and is processed:
- Lawfully, fairly and in a transparent manner;
- For specified, explicit and legitimate purposes and not processed in a manner which is incompatible with those purposes;
- Accurately, relevantly and limited to what is necessary in relation to the purposes for which it is processed;
- Kept accurate and where necessary kept up to date, with all reasonable steps being taken to ensure that all inaccurate data is erased or rectified without delay;
- Is not kept longer than is necessary for the purposes for which the personal data is processed; and
- In a manner that ensures appropriate security of the Personal Data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical and organisational measures.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Legitimate interests mean our interests in running our charity, fulfilling our role as custodian trustee and employer, complying with the Constitution Practice and Discipline of the Methodist Church, the 1939 Trust Deed and obligations under charity law and providing support to Managing Trustees and the wider Church to help fulfil the calling of the Methodist Church in Great Britain. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Privacy Manager.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract including employment contracts.
- Where we need to comply with a legal or regulatory obligation.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
In rare cases we may need to use your personal data in the following circumstances:
- Where we need to protect your vital interests e.g. in an emergency life or death situation where the emergency services are called to treat you when you are with us.
- Vital interests means where it is necessary to use your personal data to protect your "vital interests" or those of another person (such as a child) in a life-or-death situation.
- Where we need to perform a task carried out in the public interest e.g. in certain safeguarding situations.
Refer to the Lawful Bases Guidance Notice (click here if you are reading this privacy notice online) to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting the Data Privacy Manager although this will not prevent processing where the law allows us to process for a different reason in addition to consent.
SPECIAL CATEGORY DATA
Where data processing relates to Special Categories of Data (e.g. health information included in your employment records or dietary requests) the following processing conditions apply in addition to the legal basis identified in the table in the Annex to this privacy notice:
- Explicit Consent has been given by the data subject;
- Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
- Processing is carried out by a not for profit body with a religious aim provided:
- the processing relates to member or former members (or those who have regular contact with it in connection with those purposes; and there is no disclosure to a third party without consent;
- Processing relates to personal data manifestly made public by the data subject;
- Processing is necessary for the establishment, exercise, defence of legal claims or where the courts are acting in their judicial capacity; or
- Processing is necessary for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in detail in the Annex to this privacy notice, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in the Annex.
NOTIFYING YOU ABOUT EVENTS
We like to notify you about upcoming events including conferences, presentations and training opportunities so that you can benefit from the support and guidance available and play as much of a role in the life of TMCP and the wider Church as you choose from time to time. Most of the time we will let you know about such opportunities on the basis that we have a legitimate interest in doing so.
If we decide to contact you by email or telephone where you are registered with the telephone preference service we will provide you with choices as required to do so under data protection legislation and the Privacy and Electronic Communications Regulations 2003 (PECR).
We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages (e.g. messages about TMCP events or notification of new articles published on the News Hub section of our website) by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided to you e.g. although the marketing messages will be stopped we may still need to use your personal information for other purposes relating to your employment with us, guidance we provide to you and transactional issues etc.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table in the Annex.
Internal third parties such as:
- Other Methodist organisations which also form part of the Methodist Connexion and family, such as Local Churches, Circuits, Districts and the Connexional Team.
- Other Methodist organisations dealing with payroll and pension provision.
- Other Methodist charities which may be involved in property transaction or bequests including Action for Children (charity registered number 1097940) and MHA (charity registered number 1083995).
- External third parties such as:
- Professional advisers including lawyers, surveyors, bankers, auditors and insurers based in the UK who provide legal, employment/HR, surveying, consultancy, banking, insurance and accounting services to TMCP or internal third parties.
- Our Bank who provide banking and investment facilities for us.
- Estate agents who provide advice and administrative support in relation to transactional matters and ongoing residential tenancy matters.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances including the Charity Commission and Information Commissioners Office.
- Ecumenical partners in the case of shared churches and Local Ecumenical Partnerships.
- IT support services including those who provide development, advice, support and any external storage for our Websites, case management system and other databases that we use.
- Providers of office equipment containing hard drives such as the photocopier and franking machine.
We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may at times transfer and process personal data outside of the EEA. This is particularly relevant in relation to transactions, trust matters and data protection issues on the Channel Islands and Isle of Man.
However, storing, publishing or transmitting personal data via the internet, (this includes by email), is not completely secure and therefore whilst we take all reasonable and necessary precautions to protect personal data from unauthorised access, you acknowledge that there is a risk that your personal data may be transferred and accessed outside of the EEA.
We implement reasonable and appropriate security measures against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data in accordance with our internal data security policy. In addition, we limit access to your personal data to those members, volunteers, ministers and employees who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place reasonable and appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Full details of retention periods for data processed by us can be found in our retention policy which you can request from us by contacting us using the contact details in this privacy notice.
In some circumstances you can ask us to delete your data: see Section 9 and details about Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Unless personal data is subject to an exemption under GDPR, such as it is subject to the prevention, investigation, detection or prosecution of a criminal offence, you have the following rights with regards to your personal data:
- Where consent is used as the legal basis for processing personal data, you have the right to withdraw consent to the data processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or processing carried out using an alternative legal basis such as performance of a contract or legal obligation;
- The right to request a copy of the personal data which we hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like to exercise this right then please complete the relevant Data Subject Access Form and forward to the Data Privacy Manager;
- The right to request that we correct any Personal Data which is found to be inaccurate. Note that we may need to verify the accuracy of the new data you provide to us;
- The right to request that we erase any Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Where consent or the performance of a contract is used as the legal basis for processing Personal Data, you have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you and this right is unlikely to apply to personal data held by us.
- The right to request for a restriction on data processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Where legitimate interest is used as the legal basis for processing Personal Data, you have the right to object to the processing of personal data where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; and
- The right to lodge a complaint with the Information Commissioners Office (ICO).
Contacting the ICO
Further information, guidance and advice is available from the ICO at:
Information Commissioner’s Office
Tel: 0303 123 1113
If you wish to exercise any of the rights set out above, please contact the Data Privacy Manager.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
“controller” is the controller described in Section 1 of this privacy notice.
“data subject” is a living, identified or identifiable individual about whom personal data is held. e.g. our members, volunteers, lay employees, those who join us in worship and/or those who are interested in and supportive of the work of the Methodist Church and third parties such as community groups who use our buildings and other third parties.
“explicit consent” is a very clear and specific statement of consent.
"GDPR" means the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the safeguards specified in the GDPR.
“lawful bases” are the five lawful grounds on which we can lawfully process personal data set out under Article 6 of GDPR. The lawful basis or bases on which we rely are set out under Section 4 of this privacy notice.
“Managing Trustees” means the managing trustees of property held by the Methodist Church from time to time ascertained in accordance with the provisions of Part II of Schedule 2 to the Methodist Church Act 1976.
“Methodist Church in Great Britain”, “Methodist Church” or “Church” refers to the united church or denomination known as the Methodist Church formed under the provisions of the Methodist Church Union Act 1929 and a deed of union on 20 September 1932.
“personal data” is any information identifying a living individual or information relating to an individual that can be identified from that information/data (alone or in combination with other information in your hands or that can reasonably be accessed). Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal information includes an individual’s name, address, date of birth, telephone number, email address, a photograph or disability, health or ethnicity data.
“Processing” “processed” or “process” means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any activity or set of activities on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties. E.g. fulfilling obligations under an employment contract with you or responding to an enquiry that you raised with us.
Purposes for which we will use your personal data
|Purpose/Activity||Type of data |
Please refer to Section 2 for confirmation of what details these categories of data include
|Lawful basis for processing including basis of legitimate interest|
(a) Necessary for our legitimate interests (for running our charity, fulfilling our obligations under charity law, complying with the Constitution Practice and Discipline of the Methodist Church, the 1939 Trust Deed and providing support to Managing Trustees and the wider Church)
a) Necessary for our legitimate interests (for running our website and improving its functionality and service that it provides to you as part of our role in providing guidance and support to Managing Trustees and the wider Church)
a) Necessary for our legitimate interests (for running the TIS and improving its functionality and service that it provides to you as part of our role in providing guidance and support to Managing Trustees and the wider Church)
(a) Necessary for our legitimate interests (for fulfilling the duties placed on us as controller for the wider Church and point of contact with the ICO, helping Managing Trustees to deal with subject access requests and other data subject rights)
(a) Necessary for our legitimate interests (to process payment and trusts requests, to deal with enquiries or forward information from third parties relating to property, to provide support and guidance to you and notify you about things which may be of interest to you to help you to fulfil your role within TMCP and the wider Church and to generally function as a custodian trustee body and employer.
(a) Necessary for our legitimate interests (to process payment and trusts requests, to deal with enquiries or forward information from third parties relating to property, to provide support and guidance to you and notify you about things which may be of interest to you to help you to fulfil your role within TMCP and the wider Church and to generally function as a custodian trustee body.
(a) Necessary for our legitimate interests (to fulfil our role as custodian trustee and employer by dealing with enquiries and providing support and guidance to you).
(a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and looking after our employees)
(a) Necessary for our legitimate interests (to operate as a membership organisation, keep our records updated, study how our membership changes over time, identify the needs of the communities in which we operate and support our members)
(a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and reimbursing people for out of pocket expenses).
(a) Necessary for our legitimate interests (for keeping official records of decisions, running our charity recording compliance with trusts and charity law and providing support to the wider Church, records of bequests and trusts matters, disposals, acquisitions and other property transactions (including money based transactions) to assist in decision and policy making and day to day running of the charity including visitors to our premises.)
(a) Necessary for our legitimate interests (for running our charity and filling job vacancies).
(a) Necessary for our legitimate interests (to keep church premises and our members, ministers, volunteers, employees and third parties secure)