The Parochial Church Council of St Luke's church in Tunbridge Wells is committed to protecting your privacy and the overall integrity of the Internet.

To that end, we are disclosing here any issues related to privacy in the collection by ourselves of personally identifiable information from users of our website. We hold all of your data in accordance with our own data protection policy, and the General Data Protection Regulation (the "GDPR"). It is updated, without notification, following advice published from time to time by the Information Commissioner. We are not responsible for the content or the privacy policies of Web sites to which our website may link. Please read on for more details about our Privacy Policy.

The summary

• Information you provide is never provided or sold to any third parties, unless there is a law that forces us to do so.
• Information you provide on the website is used only for the purpose of tracking how you navigate the site, replying to your enquiry or sending email newsletters. We only use your data for the purpose(s) for which we collected it.
• Any email newsletters we might send always include a simple unsubscribe mechanism.
• You have the right to access the data which we hold about you and have any errors corrected.
• We cannot hold your data for longer than necessary, and we must keep it up to date and secure.
• You have the right to have factually incorrect data we hold about you corrected.

Your personal data - what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

Controllers of personal information

Any personal information provided or to be gathered is controlled primarily by the PCC who functions as the Data Controller. Their contact address is c/o St Luke's Vicarage, 158 Upper Grosvenor Road, Tunbridge Wells, Kent, TN1 2EQ, United Kingdom. As the Data Controller, the PCC decides how your personal data is processed and for what purposes.

What information do we collect?

• On this website, we collect information via our enquiry forms and via cookies placed in order to track site statistics.
• We use cookies for the purposes of collecting statistics on site visitors and determining the level of repeat visitors. These help us develop the design and layout of the web site. These cookies are not personally identifiable - see our Cookie Policy for more information.

How do we process your personal data

The PCC must comply with their obligations under the “GDPR” by keeping personal data up-to-date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. On this website:

• the information we collect allows us to respond to your enquiry. It provides us with your contact details;
• we may perform statistical analyses of enquiries submitted via the website. This information is not disclosed to any third parties;
• in addition, if you choose to receive our email newsletters or if you send us an enquiry, your information will be held in order to respond to you. Our email newsletter always includes a simple unsubscribe mechanism.

In our general practice (online and offline), we use your personal data for the following purposes:

• To enable us to provide a voluntary service for the benefit of the public in the ecclesiastical parish of Tunbridge Wells: St Luke;
• To administer membership records - what the Church of England refers to as an Electoral Roll;
• To fundraise and promote the interests of our parish church;
• To manage our employees and volunteers;
• To maintain our own accounts and records (including the processing of Gift Aid applications);
• To inform you of news, events, activities and services running at our parish church or in other ways associated with St Luke's.

What is the legal basis for our processing of your personal data?

• Explicit consent of the data subject, so that we can keep you informed about news, events, activities and services and keep you informed about diocesan events.
• Processing is necessary for carrying out legal obligations in relation to Gift Aid or under employment, social security or social protection law, or a collective agreement, or related to legal obligations for marriages and funerals;
• Processing can be carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided: -
  • the processing relates only to members 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.

Do we share the information we collect?

Your personal data will be treated as strictly confidential and will only be shared with other members of the church in order to carry out a service to other church members or for purposes connected with the church. We only share your data with third parties outside of the parish with your express consent.

• We never sell, trade or rent your personal information to others.
• We do not provide aggregate statistics about our visitors, traffic patterns and related site information from this website to third-party vendors.
• We will provide visitors with a summary of all personal information that we process on them upon request. We will charge £10 for such requests. To make such a request, send an email to us and include the email address that you registered with along with any organisation name. Personal information will be provided within 28 days.

How long do we keep your personal data?

We keep data in accordance with the guidance set out in the guide “Keep or Bin: Care of Your Parish Records” which is available from the Church of England website. Specifically, we retain Electoral Roll data while it is still current; Gift Aid declarations and associated paperwork for up to six years after the calendar year to which they relate; and Parish Registers (baptisms, marriages, funerals) permanently. We retain e-mailing lists of a wider group of church members and those who have attended worship. Our email newsletters always includes a simple unsubscribe mechanism so that you can stop receiving such emails at any time.

How do we protect and store your information?

As required by the GDPR, we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you. Information from this website is stored securely on the servers of our web design partner, ChurchEdit (www.churchedit.co.uk). Their servers are protected by a central firewall and back-up firewall which monitor activity and hostile attacks. Other records are stored offline in lockable safes and filing cabinets.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -

• The right to request a copy of your personal data which the PCC holds about you;
• The right to request that the PCC correct any personal data if it is found to be inaccurate or out-of-date;
• The right to request your personal data is erased where it is no longer necessary for the PCC to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right to request that the Data Controller provide the Data Subject with his/her personal data and where possible, to transmit that data directly to another Data Controller, (known as the right to Data Portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the Data Subject and in either case the Data Controller processes the data by automated means].
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
• The right to lodge a complaint with the Information Commissioners Office.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Your consent

By using our web site, you consent to the collection and use of this information collected on this website. If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

Contacting us

If you have a privacy concern regarding our churches, or this policy, and if you cannot satisfactorily resolve it through the use of this web site, you should contact us using the contact page link. In the event that we are still unable to resolve your concerns we are committed to cooperating to achieve a proper resolution of your privacy concerns.

To exercise all relevant rights, queries or complaints please in the first instance contact the Vicar c/o St Luke's Vicarage, 158 Upper Grosvenor Road, Tunbridge Wells, Kent, TN1 2EQ. If you object to any sharing of your personal information that may be permitted under this policy, you may do so by writing to us at the above address. We will take reasonable steps to accommodate your requests as they relate to our practices. In some instances, honouring your requests may interfere with or preclude your ability to use the website.

The Information Commissioner

You can contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.