Privacy Policy

THE PRESBYTERIAN CHURCH OF WALES PRIVACY NOTICE

WHAT’S INCLUDED IN THIS PRIVACY NOTICE?

The Presbyterian Church of Wales (‘PCW’) is one of the largest Christian denominations in Wales. PCW’s aims are to worship God and to spread the Gospel of the Lord Jesus Christ. As a Connexional Church, the PCW is governed by one Association which meets in three Provinces, and the General Assembly, its Boards, Departments and Sub-Committees in those matters devolved to the Assembly by the Association.

This document (our “privacy notice”) sets out information relating to how PCW use personal information relating to individuals we have dealings with, including members and elders of the church, adherents, people connected with the PCW, people who make donations to PCW, users of our website. It also sets out information about what rights individuals have in relation to their personal information and various other matters required under data protection law.

This privacy notice contains the following sections:

Section heading	Page number
1. WHO DOES THIS PRIVACY NOTICE APPLY TO?	3
2. WHAT’S OUR APPROACH TO PRIVACY?	4
3. HOW WILL WE USE YOUR PERSONAL INFORMATION?	6
4. ENGAGING WITH US ON SOCIAL MEDIA	24
5. INFORMATION ABOUT AUTOMATED DECISION MAKING	24
6. WHEN WILL WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS?	24
7. CIRCUMSTANCES IN WHICH WE WILL SEND YOUR PERSONAL INFORMATION OUTSIDE THE EEA	27
8. HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?	27
9. WHAT RIGHTS DO YOU HAVE UNDER DATA PROTECTION LAW?	28
10. WHEN AND HOW CAN YOU WITHDRAW YOUR CONSENT?	31
11. HOW CAN YOU GET IN TOUCH WITH US AND WHO OVERSEES OUR COMPLIANCE WITH DATA PROTECTION LAW?	31
12. RIGHT TO COMPLAIN TO THE INFORMATION COMMISSIONER’S OFFICE	31
13. CHANGES TO OUR PRIVACY NOTICE	31

1. WHAT’S INCLUDED IN THIS PRIVACY NOTICE?

This privacy notice applies to:

Members (see 3.1);
Elders and Office Holders (see 3.2);
Donors (see 3.3);
Individuals connected with the PCW (see 3.4);
Members from other churches (see 3.5);
Those who hire church premises including tenants (see 3.6);
Individuals who contact us with enquiries/complaints (see 3.7);
Individuals who use our website (see 3.8);
Individuals who feature in our newsletters or articles (see 3.9); and
Individuals who we engage to provide services to us (see 3.10);

2. WHAT’S OUR APPROACH TO PRIVACY?

We take your privacy extremely seriously and want you to feel confident that your personal information is safe in our hands.

We will only use your personal information in accordance with data protection law applicable to England and Wales.

Under data protection law, when we use your personal information, we will be acting as a data controller. Essentially, this means that we will be making decisions about how we want to use your personal information and why.

Below, we summarise the main rules that apply to us under data protection law when we use your personal information:

1.	We must be upfront about how we intend to use your personal information and must use your personal information fairly. Providing privacy information to individuals (such as this privacy notice) is one aspect that helps us to fulfil this obligation.
2.	We must only use your personal information if one of the legal grounds set out in data protection law apply. These legal grounds include that: You have consented to our use of your personal information; We need to use your personal information to perform a contract between us; We (or someone else) has a legitimate reason for needing to use your personal information and it would not be unfair to you if your personal information was used for this purpose. This is known as having a “legitimate interest”. We need to use your personal information to comply with the law.
3.	We must only use certain types of sensitive personal information (such as information relating to a person’s health, racial origin or religion) if we can also satisfy one of the conditions set out in data protection law. You have given us your explicit consent to use the information; We need to use the information in the course of the legitimate activities of PCW and the information is not being disclosed outside PCW; You have made the information public; We need to use the information to protect your vital interests or the vital interests of another person; We need to use the information in connection with a legal claim.
4.	We must only share your personal information with others if we have a legal ground for doing so (see point 2 above) and/or (in relation to sensitive personal information) we can satisfy a condition (see point 3 above).
5.	Generally speaking, we must only use your personal information for the specific purposes we have told you about. If we want to use your personal information for other purposes, we need to contact you again to tell you about this.
6.	We must not hold more personal information than we need for the purposes we have told you about and must not retain your personal information for longer than is necessary for that purpose (known as the “retention period”). We must also dispose of any information that we no longer need securely.
7.	We must ensure that we have appropriate security measures in place to protect your personal information.
8.	We must act in accordance with your rights under data protection law (see Section 9)
9.	We must not transfer your personal information outside the European Economic Area (“EEA”) unless certain safeguards are in place. One such safeguard is that the personal data is only transferred to a country that has been approved by the European Commission as having an acceptable level of data protection law or if this does not apply we will ask for your consent to transfer your personal information outside the EEA.

3. HOW WILL WE USE YOUR PERSONAL INFORMATION?

How we will use your personal information, the legal bases we will rely upon, how long we will keep your personal information and other details will depend upon who you are and why we need your personal information in the first place.

In this section, we provide specific privacy information relating to the different categories of individuals that this privacy notice applies to.

3.1 MEMBERS

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Bank Account details; Whether you are a UK taxpayer; Your connection with the PCW (which will reveal your religious beliefs). Information regarding your health. Your photo, and/or audio and/or video recording of you, taken during a church activity, event or meeting to the extent that you are identifiable.
How we will obtain the personal information	The information will be provided by you to your local church.
What purposes we will use the personal information for	We will use the personal information for Member administrative purposes; and to inform you of events and activities within the church; for the provision of Pastoral care; to circulate prayer requests; and to note news items e.g. in newsletters, our website, social media. We will use the personal information in order to process your financial contributions (whether a one off or a regular financial contribution) and to obtain any tax reimbursements through gift aid. We will use your bank account details in relation to any financial contributions you make. We will record your name and the fact that you are a Member of the PCW. We will use the fact that you are a Member for historical research purposes.
Who we share your personal information with	Your name will be included in your local church’s Annual Report. You may appear in a local or national newsletter to members (e.g. Goleuad, Treasury), which may be published on our website and also sold to the public. You may appear in an audio and/or video recording from a church activity, event or meeting, which may be posted on the church (or PCW) website or church (or PCW) social media pages or shown in a church (or PCW) meeting. Your name may appear in the Year Book and Diary, Presbytery’s Directory, Agendas, and/or Minutes of any meeting held internally in the PCW. Your name may appear in a church rota such as flowers rota, organ rota, or on the church notice board. We will hold your name, amount of your donation and whether tax is reclaimed for accounting and records purposes. We will share your personal information with HMRC in order to obtain any gift aid tax reimbursements, where applicable. Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed. Many of our publications and documentation e.g. Annual Reports, are archived in the National Library of Wales, and such publications and documentation may include your personal details. The consent of the Historical Society of the Presbyterian Church of Wales is required to access the archives. Where you have signed ‘Form 2: Consent - Members’, and depending on which boxes you tick, your contact details, financial contributions and gift aid reclaimed on financial contributions, may appear in the Annual Report. The information will be provided by you to your local church.
Circumstances in which we will send your personal information outside the EEA	On occasion it will be necessary for us to send your personal information to countries outside the European Economic Area, for example if you visit Presbyterian churches within these countries. In such circumstances, we will need to send some of your personal information to the overseas church in order to arrange your visit. We will only transfer your personal information in such circumstances where we have your explicit consent to do so.
The legal grounds we rely upon	We rely on the fact that processing your information in order to facilitate your membership and to provide pastoral care are legitimate activities of the PCW. We rely on the fact that you have manifestly made public your religious belief through the declaration of faith that you made upon becoming a member of the PCW, to allow us to include your name, photo, audio or video recordings in our documentation, publications, on our website, on our social media pages, on our notice board etc. We rely on the fact that it is in our legitimate interests to process the personal information to process your financial contributions and to obtain any tax reimbursements. These financial contributions allow the PCW to further its aims and interest. By making a financial contributions you are supporting those aims. If and to the extent that your financial contributions to the PCW reveals your religious beliefs, our processing of that information will be carried out only where it is in the course of our legitimate activities. Your telephone number, email address, address, financial contributions, gift aid reclaimed on financial contributions, will only appear in the Annual Report where you have provided explicit consent. Necessary for archiving purposes in the public interest or historical research purposes.
How long we retain the personal information and why	Your contact details will be retained for the duration of your membership. Many of our publications and documentation e.g. Annual Reports, are archived in the National Library of Wales for historic research purposes, and such publications and documentation may include your personal details. Details of your financial contributions will be retained for 7 years for financial reporting reasons.
Consequences of not providing/permitting us to obtain personal information	If your name and contact details are not provided you will not be able to become a member of the PCW. Failure to provide us with your name and bank account details will mean we cannot process any financial contributions other than a cash or cheque financial contribution.

3.2 ELDERS AND OFFICE HOLDERS (INCLUDING A ROLE HELD IN THE CHURCH E.G. SUNDAY SCHOOL TEACHER, TREASURER, SECRETARY).

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Date of Birth where you are a charity trustee Your Bank Account details; Your connection with the PCW (that reveal your religious beliefs). Your photo, and/or audio and/or video recording of you, taken during a church activity, event or meeting to the extent that you are identifiable.
How we will obtain the personal information	The information will be provided by you to your local church and/or General Assembly Office and/or committee that you are a member of.
What purposes we will use the personal information for	We will use the personal information for Member administrative purposes; We will use your bank account details in relation to expenses owed to you; We will record your name and the fact that you are a member of the PCW and the fact that you are an Elder and/or Office Holder; We will use the personal information to provide you with information relevant to you as an Elder and/or Office Holder, such as meeting papers and issues for discussion at meetings (e.g. Elders’ meetings; Presbytery meetings; Association meetings, meetings of General Assembly and its Boards, Committees and Groups) We will use the fact that you are an Elder and/or Officer Holder and the period of office for historical research purposes.
Who we share your personal information with	We will share your contact details In your local church’s Annual Report, newsletter or notice sheet (and others as appropriate); In your local Presbyteries Directories; (and other documents/publications as appropriate) In the PCW Year Book and Diary. In agendas or Minutes or Proceedings of any meeting held internally in the PCW On the church notice board. to enable individuals within PCW to contact you in your capacity as an Elder and/or Office Holder to discuss PCW work. Where you are a Charity Trustee, your personal details will be provided to the Charity Commission and your name will be published on the Charity Commission’s website and a link to other charities for which you also act as trustee. Also your name and office held will appear in the accounts of the PCW which are published on the Charity Commission’s website. Many of our publications and documentations e.g. Annual Reports are archived in the National Library of Wales, and such publications and documentation may include your personal details. The consent of the Historical Society of the Presbyterian Church of Wales is required to access the archives. You may appear in a photo and/ or audio and/ or video recording from a PCW activity, event or meeting, which may be posted on the PCW website or PCW social media pages or shown in a PCW meeting. We will hold your name and expenses details for accounting and records purposes. Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed.
Circumstances in which we will send your personal information outside the EEA	On occasion it will be necessary for us to send your personal information to countries outside the European Economic Area, for example if you visit Presbyterian churches within these countries. In such circumstances, we will need to send some of your personal information to the overseas church in order to arrange your visit. We will only transfer your personal information in such circumstances where we have your explicit consent to do so.
The legal grounds we rely upon	Use of your personal information for administrative purposes and to provide you with relevant papers and documents and to share with other members of the PCW are legitimate activities of the PCW to ensure that the Church is run efficiently and effectively. Where your personal information is shared outside the PCW for example in the PCW’s Year Book and Diary, we will rely upon the fact that you have manifestly made public your religious belief through the declaration of faith that you made upon becoming a member of the PCW and in being ordained as an Elder and/or appointed as an Office Holder within the PCW. Necessary for archiving purposes in the public interest or historical research purposes.
How long we retain the personal information and why	Your contact details will be retained for the duration of time that you are an Elder and/or Office Holder in the PCW. Financial details regarding expenses will be retained for 7 years, for financial reporting reasons. Many of our publications and documentation e.g. Year Book and Diary, are archived in the National Library of Wales for historic research purposes, and such publications and documentation may include your personal details.
Consequences of not providing/permitting us to obtain personal information	If your name and contact details are not provided you will be unable to act as an Elder or Officer Holder in the PCW as we will not be able to provide you with information relevant to your role. Failure to provide us with your name and bank account details will mean we cannot process any expenses.

3.3 DONORS

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Bank Account details; Whether you are a UK tax payer; Your association with the PCW (which is likely to reveal your religious beliefs).
How we will obtain the personal information	The information is provided directly by you to your local church or to the General Assembly Office.
What purposes we will use the personal information for	We will use the personal information in order to process your donation (whether a one off or a regular donation) and to obtain any tax reimbursements through gift aid. We may use the fact that you are a Donor for historical research purposes.
Who we share your personal information with	We will hold your name, amount of your donation and whether tax is reclaimed for accounting and records purposes. We will share your personal information with HMRC in order to obtain any gift aid tax reimbursements, where applicable. The following will ONLY apply where you have given explicit consent on Form 3. (If you have ticked some but not all of the boxes, then only some of the following will apply): Your name, contact details, donation and gift aid reclaimed on your donation, may appear in the church Annual Report Many of our publications and documentation e.g. Annual Reports, are archived in the National Library of Wales, and such publications and documentation may include your personal details. The consent of the Historical Society of the Presbyterian Church of Wales is required to access the archives. Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed.
The legal grounds we rely upon	Is that it is in our legitimate interests to process the personal information to process your donation and to obtain any tax reimbursements. These donations allow the PCW to further its aims and interest. By making a donation you are supporting those aims. If and to the extent that your donation to the PCW reveals your religious beliefs, our processing of that information will be carried out only where it is in the course of our legitimate activities, and won’t be transferred outside the PCW, or published in the Annual Report, without your consent. Necessary for archiving purposes in the public interest or historical research purposes.
How long we retain the personal information and why	Your contact details and amount of donation(s) will be retained for 7 years for financial reporting reasons. Many of our publications and documentation e.g. Annual Reports, are archived in the National Library of Wales, for historical research purposes, and such publications and documentation may include your personal details.
Consequences of not providing/permitting us to obtain personal information	Failure to provide us with your name and bank account details will mean we cannot process any donation other than a cash or cheque donation.

3.4 INDIVIDUALS CONNECTED WITH THE PCW (ADHERENTS, CHILDREN, YOUNG PERSONS AGED 16 AND 17 WHO ARE NOT MEMBERS)

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Bank Account details; Whether you are a UK tax payer; Your association with the PCW, which is likely to reveal your religious beliefs. Information regarding your health. Your photo, and/or audio and/or video recording of you, taken during a PCW activity, event or meeting.
How we will obtain the personal information	Provided by you to your local church.
What purposes we will use the personal information for	We will use the personal information for member administrative purposes; and to inform you of events and activities within the church for the provision of Pastoral care; to circulate prayer requests; and to note news items e.g. in newsletters, our website, social media. We will use the personal information in order to process your financial contributions (whether a one off or a regular financial contribution) and to obtain any tax reimbursements through gift aid. We will use your bank account details in relation to any financial contributions you make; We will record your name and your connection with the PCW; We will use information regarding your connection with the PCW for historical research purposes.
Who we share your personal information with	We will hold your name, amount of your donation and whether tax is reclaimed for accounting and records purposes. We will share your personal information with HMRC in order to obtain any gift aid tax reimbursements, where applicable. The following will ONLY apply where you have given explicit consent on form 2, 3, 4 or 5 (If you have ticked some but not all of the boxes, then only some of the following will apply). Your name/photo may be included in your local church’s Annual Report. You may appear in a local or national newsletter to members (e.g. Goleuad, Treasury), which may also be published on our website and also sold to the public. You may appear in an audio and/or video recording from a church activity, event or meeting, which may be posted on the church website or church social media pages or shown in a church meeting. You may appear in the church news section of the local paper Your name may appear in the Presbytery’s Directory, Year Book and Diary, Agendas or Minutes or Proceedings of any meeting held internally in the PCW. Your name may appear in a church rota such as flowers rota, organ rota, on the church notice Board. Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed. Many of our publications and documentation e.g. Annual Reports, are archived in the National Library of Wales, and such publications and documentation may include your personal details. The consent of the Historical Society of the Presbyterian Church of Wales is required to access the archives. Your contact details, financial contributions and gift aid reclaimed on financial contributions, may appear in the Annual Report.
The legal grounds we rely upon	Use of your personal information for administrative purposes, to provide pastoral care and to provide you information about PCW activities, will be carried out only where it is in the course of our legitimate activities. Your personal information will not be transferred outside the church without your consent, except where required by law. Is that it is in our legitimate interests to process the personal information to process your financial contributions and to obtain any tax reimbursements. These financial contributions allow the PCW to further its aims and interest. By making a financial contributions you are supporting those aims. If and to the extent that your financial contributions to the PCW reveals your religious beliefs, our processing of that information will be carried out only where it is in the course of our legitimate activities. Your financial contributions and gift aid reclaimed will only be published in the Annual Report where you have provided explicit consent. Where your child/ren is/are under 16, their names, photos, will only appear in the Annual Report, newsletters, website, social media pages, and their financial contributions in the Annual Report, where you have provided explicit consent. Necessary for archiving purposes in the public interest or historical research purposes.
How long we retain the personal information and why	We will retain your contact details for as long as you are connected with PCW. Many of our publications and documentations e.g. Annual Reports, are archived in the National Library of Wales for historic research purposes and such publications and documentation may include your personal details. Details of your financial contributions will be retained for 7 years for financial reporting purposes.
Consequences of not providing/permitting us to obtain personal information	If your name and contact details are not provided we cannot continue to engage with you.

3.5 MEMBERS FROM OTHER CHURCHES

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Date of Birth where you are a charity trustee Your Bank Account details; Your connection with the PCW (that reveal your religious beliefs). Your photo, and/or audio and/or video recording of you, taken during a church activity, event or meeting to the extent that you are identifiable.
How we will obtain the personal information	The information will be provided by you to your local church and/or General Assembly Office and/or committee that you are a member of.
What purposes we will use the personal information for	We will use the personal information for Member administrative purposes; We will use your bank account details in relation to expenses owed to you; We will record your name and the fact that you are a member of the PCW and the fact that you are an Elder and/or Office Holder; We will use the personal information to provide you with information relevant to you as an Elder and/or Office Holder, such as meeting papers and issues for discussion at meetings (e.g. Elders’ meetings; Presbytery meetings; Association meetings, meetings of General Assembly and its Boards, Committees and Groups) We will use the fact that you are an Elder and/or Officer Holder and the period of office for historical research purposes.
Who we share your personal information with	We will share your contact details In your local church’s Annual Report, newsletter or notice sheet (and others as appropriate); In your local Presbyteries Directories; (and other documents/publications as appropriate) In the PCW Year Book and Diary. In agendas or Minutes or Proceedings of any meeting held internally in the PCW On the church notice board. to enable individuals within PCW to contact you in your capacity as an Elder and/or Office Holder to discuss PCW work. Where you are a Charity Trustee, your personal details will be provided to the Charity Commission and your name will be published on the Charity Commission’s website and a link to other charities for which you also act as trustee. Also your name and office held will appear in the accounts of the PCW which are published on the Charity Commission’s website. Many of our publications and documentations e.g. Annual Reports are archived in the National Library of Wales, and such publications and documentation may include your personal details. The consent of the Historical Society of the Presbyterian Church of Wales is required to access the archives. You may appear in a photo and/ or audio and/ or video recording from a PCW activity, event or meeting, which may be posted on the PCW website or PCW social media pages or shown in a PCW meeting. We will hold your name and expenses details for accounting and records purposes. Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed.
Circumstances in which we will send your personal information outside the EEA	On occasion it will be necessary for us to send your personal information to countries outside the European Economic Area, for example if you visit Presbyterian churches within these countries. In such circumstances, we will need to send some of your personal information to the overseas church in order to arrange your visit. We will only transfer your personal information in such circumstances where we have your explicit consent to do so.
The legal grounds we rely upon	Use of your personal information for administrative purposes and to provide you with relevant papers and documents and to share with other members of the PCW are legitimate activities of the PCW to ensure that the Church is run efficiently and effectively. Where your personal information is shared outside the PCW for example in the PCW’s Year Book and Diary, we will rely upon the fact that you have manifestly made public your religious belief through the declaration of faith that you made upon becoming a member of the PCW and in being ordained as an Elder and/or appointed as an Office Holder within the PCW. Necessary for archiving purposes in the public interest or historical research purposes.
How long we retain the personal information and why	Your contact details will be retained for the duration of time that you are an Elder and/or Office Holder in the PCW. Financial details regarding expenses will be retained for 7 years, for financial reporting reasons. Many of our publications and documentation e.g. Year Book and Diary, are archived in the National Library of Wales for historic research purposes, and such publications and documentation may include your personal details.
Consequences of not providing/permitting us to obtain personal information	If your name and contact details are not provided you will be unable to act as an Elder or Officer Holder in the PCW as we will not be able to provide you with information relevant to your role. Failure to provide us with your name and bank account details will mean we cannot process any expenses.

3.6 THOSE WHO HIRE CHURCH PREMISES, INCLUDING TENANTS

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Your Bank Account details;
How we will obtain the personal information	Provided by you to your local church.
What purposes we will use the personal information for	We will use the personal information for administrative purposes for the performance of the contract between us. We will use your bank account details in relation to payments made to hire the premises or rent payments.
Who we share your personal information with	Your name and contact details may appear in a church magazine or website or notice board (only applicable to groups who hire church premises). Where there is a requirement for the financial statements to be independently examined or audited, your personal information will be shared with the independent examiner or auditor in order for this task to be completed.
The legal grounds we rely upon	Use of your personal information for the performance of a contract between us. Use of your personal information, to ensure that the hire or tenancy arrangements are carried out efficiently and effectively, and are in the legitimate interests of the PCW.
How long we retain the personal information and why	We will retain your personal information for the duration of the contract and for 7 years thereafter.
Consequences of not providing/permitting us to obtain personal information	If your name and contact details are not provided you will be unable to act as an Elder or Officer Holder in the PCW as we will not be able to provide you with information relevant to your role. Failure to provide us with your name and bank account details will mean we cannot process any expenses.

3.7 INDIVIDUALS WHO CONTACT US WITH ENQUIRIES/COMPLAINTS

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or email address); Details of your enquiry; Your connection with the PCW (which will reveal your religious beliefs), if relevant.
How we will obtain the personal information	Provided by you when you contact us (e.g. by making a phone call or emailing us).
What purposes we will use the personal information for	We will use the personal information to deal with your enquiry/complaint; We will make a record of your enquiry/complaint for internal administrative purposes.
The legal grounds we rely upon	Use of your personal information for the purpose dealing with your enquiry/complaint is based on our legitimate interest in ensuring the Church is run efficiently and effectively; Keeping a record of your enquiry is based on our legitimate interest in ensuring we can run an efficient Church. Where the details of your enquiry reveal your religious belief because of your connection with or contact with the PCW, our processing of that information will be carried out only where it is in the course of our legitimate activities, and won’t be transferred outside the PCW without your consent.
How long we retain the personal information and why	Records of your enquiry/complaint and related documentation are retained until the matter is resolved to everyone’s satisfaction.

3.8 INDIVIDUALS WHO USE OUR WEBSITE

What personal information we will use	Technical information, including the internet protocol address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit, including the full Uniform Resource Locators (“URL”), clickstream to, through and from our website (including date and time), page response times, download errors, length of visit to certain pages and methods used to browse away from the page.
How we will obtain the personal information	Some of the information is obtained by us automatically whenever you use our website in an anonymized form; Some of the information is collected by us each time you use our website through our use of cookies. Further information about the cookies we use and the purposes for which we use them can be found in our Cookies Policy.
What purposes we will use the personal information for	The information used by us to help us to continually improve our website. Information collected through our use of cookies is used in the ways described in our Cookies Policy.
The legal grounds we rely upon	Our collection and use of the information is based on our legitimate interest in ensuring that our website is user-friendly and appeals to the users.
How long we retain the personal information and why	We don’t hold identifiable personal information but do retain usage data in an anonymous form. The data is held permanently on the Google Analytics platform.
Consequences of not providing/permitting us to obtain personal information	If you disable our Cookies, you will be unable to use certain parts of/functions on our website. Further information about this can be found in our Cookies Policy.

3.9 INDIVIDUALS WHO FEATURE IN OUR NEWSLETTERS OR ARTICLES

What personal information we will use	Your name; Your contact details (such as your postal address, telephone number and/or e-mail address). Your geographical location; Your church Your association with the PCW, which is likely to reveal your religious beliefs; Other personal details you provide to us as part of your testimony.
How we will obtain the personal information	Provided by you when you agree to feature in a newsletter or article.
What purposes we will use the personal information for	Your contact details will be used for administrative purposes; We will use the personal information provided within the article/newsletter;
Who we share your personal information with	The article/newsletter will be published in the relevant PCW magazine, and/or posted on the church (or PCW) website or the church or PCW’s social media pages.
The legal grounds we rely upon	Use of your personal information for administrative purposes is in the legitimate interests of both yourself and the PCW in order to facilitate the publication of the article/ newsletter. We will use your personal information to write and publish the newsletter/article based upon the following – For Members, the fact that you have manifestly made public your religious belief For others, explicit consent.
How long we retain the personal information and why	Articles and newsletters are archived in the National Library of Wales for historical research purposes.

3.10 INDIVIDUALS WHO WE ENGAGE TO PROVIDE SERVICES TO US

What personal information we will use	Your name and contact details; Your bank account details.
How we will obtain the personal information	Provided by you when you agree to provide us with services.
What purposes we will use the personal information for	To enter into an agreement with you, to contact you, to administer the agreement for services and to pay you.
The legal grounds we rely upon	The use of your personal information to enter into an agreement for services, for correspondence in relation to the services and associated matters and to make payment for services provided will be necessary for the purposes of taking steps prior to entering into a contract with you and for the performance of the contract between us.
How long we retain the personal information and why	We will retain your personal information for the duration of the provision of services and for 7 years therefore in case there should be any contractual dispute, and for financial reporting reasons.
Consequences of not providing/permitting us to obtain personal information	Without your personal information, we will not be able to engage you to provide us with services nor will we be able to pay you.

4. ENGAGING WITH US ON SOCIAL MEDIA

Any social media posts or comments you send to us (on the PCW Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they're written and could be made public. Other people, not us, control these platforms. We are not responsible for this kind of sharing. So, before you make any remarks or observations about anything, you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you'll understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you're unhappy about it.

5.INFORMATION ABOUT AUTOMATED DECISION MAKING

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention.

We do not undertake any processing activities which involve making decisions about you using automated means.

6.WHEN WE WILL SHARE YOUR PERSONAL INFORMATION WITH OTHERS?

Sometimes, we will need to share your personal information with others. This section sets out details of who we will share your personal information with and why (some of this information has already been provided in section 3). It also tells you about our legal ground for doing so under data protection law and steps we will take to protect your personal information.

Please note that we will never sell your personal information on to third parties.

6.1 SERVICE PARTNERS

Information about our service partners	Our service partners are businesses that we enter into contracts with. They include: Suppliers and sub-contractors; Suppliers of IT products and services; We haven’t included the names of our service partners in this privacy notice because we will deal with different service providers from time to time. However, if you would like further information about any of our current service providers, please contact your church, or the General Assembly office.
Why we need to share your personal information	We use suppliers and sub-contractors to perform certain aspects of our contracts with our tenants. For example, providing maintenance services; We use suppliers of IT products and services in connection with the supply, maintenance and/or improvement of our IT network.
The legal grounds we rely upon	The sharing of your personal data with suppliers and sub-contractors is necessary for the performance of our contract with you; The sharing of your personal data with businesses used by us in connection with the supply, maintenance and/or improvement of our IT network is based on our legitimate interests in ensuring that the Church can function properly and efficiently and that our IT network is secure.

6.2 OTHER PARTS OF THE PCW

Information about the different parts of the PCW	The PCW is a single data controller however there may be circumstances where it is necessary in the course of the legitimate activities of the PCW for your personal information to be shared with different parts within the PCW. Information about the structure of the PCW can be found in the Handbook of Order and Rules.
Why we need to share your personal information	It is necessary in the course of the legitimate activities of the PCW to for example: sharing contact details between churches, Presbyteries, Association, General Assembly sharing information about the work of the churches, the Presbyteries, Association, the General Assembly and its Boards, Departments and Groups.
The legal grounds we rely upon	Sharing of personal data within the PCW will be based on it being carried out in the course of the legitimate activities with appropriate safeguards by the PCW .
What precautions do we take?	Personal data is only shared within the PCW where this can be done fairly and lawfully, in accordance with the data protection principles and data protection laws. To this end the PCW aims to ensure; that only personal data that needs to be shared in connection with the operations and activities of the PCW is shared; that personal data is only shared when it is necessary and appropriate to do so; that personal data is shared on a ‘need to know’ basis and is not shared more widely than is necessary; and that personal data is shared securely

6.3 OTHER THIRD PARTIES

In addition to the situations described above, we may also need to share your personal information with third parties in the following circumstances:

Legal or regulatory requirements	On occasion, we may be required to disclose your personal information to organisations such as regulatory bodies, the courts and the police (including the Interdenominational Protection Panel and Disclosure and Barring Service) to comply with legal obligations we are subject to and/or to prevent fraud or crime.
Professional advice and legal action	We may need to disclose your personal information to our professional advisers (for example, our lawyers and accountants) in connection with the provision by them of professional advice.
Legal or regulatory requirements	On occasion, we may be required to disclose your personal information to organisations such as regulatory bodies, the courts and the police (including the Interdenominational Protection Panel and Disclosure and Barring Service) to comply with legal obligations we are subject to and/or to prevent fraud or crime.
Translators	Your personal information may be included in documentation that is translated by translators.
Printing Service Providers	Your personal information may be included in documentation or newsletters which is printed (and sometimes distributed) by printing service providers.
Other churches and Denominations, and Interdenominational organisations	Your name and contact details may need to be disclosed as part of the work of the PCW (e.g. in order to attend a committee or to preach).
Service providers such as Travel agents, Hotels, Universities	Your name and contact details may need to be disclosed in order to make travel arrangements in connection with the work of the PCW (e.g. to attend the General Assembly).

7. CIRCUMSTANCES IN WHICH WE WILL SEND YOUR PERSONAL INFORMATION OUTSIDE THE EEA

On occasion it will be necessary for us to send your personal information to countries outside the European Economic Area, for example if you visit Presbyterian churches within these countries or attend a CWM conference. In such circumstances, we will need to send some of your personal information to the overseas church in order to arrange your visit. We will only transfer your personal information in such circumstances where we have your explicit consent to do so.

8.HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We take various steps to protect your personal information while it is in our possession, including:

Implementation of appropriate security measures to protect our IT infrastructure;
Implementation of internal data security policies and training for members of staff in relation to such policies.

9. WHAT RIGHTS DO YOU HAVE UNDER DATA PROTECTION LAW?

Under data protection law, you have a number of different rights relating to the use of your personal information. The table below contains a summary of those rights and our obligations. More information about your rights and our obligations can be found on the ICO website https://ico.org.uk/.

Your rights	What this involves	What our obligations are
A right of access	This is a right to obtain access to your personal data and various supplementary information.	We must provide you with a copy of your personal information and the other supplementary information without undue delay and in any event within 1 month of receipt of your request; We cannot charge you for doing so save in specific circumstances (such as where you request further copies of your personal information).
A right to have personal data rectified	This is a right to have your personal information rectified if it is inaccurate or incomplete.	We must rectify any inaccurate or incomplete information without undue delay and in any event within 1 month of receipt of your request; If we have disclosed your personal information to others, we must (subject to certain exceptions) contact the recipients to inform them that your personal information requires rectification.
A right to erasure	This is a right to have your personal information deleted or removed. This right only applies in certain circumstances (such as where we no longer need the personal information for the purposes for which it was collected). We have the right to refuse to delete or remove your personal data in certain circumstances.	If this right applies, we must delete or remove your personal information without undue delay and in any event within 1 month of receipt of your request; If we have disclosed your personal information to others, we must (subject to certain exceptions) contact then recipients to inform them that your personal information must be erased. Users can also initiate deletion directly via the App by going to the Profile section and selecting the “Delete Account” option.
A right to data portability	This is a right to obtain and re-use your personal information for your own purposes; It includes a right to ask that your personal information is transferred to another organisation (where technically feasible). This right only applies in certain limited circumstances.	If this right applies we must provide your personal information to you in a structured, commonly used and machine reasonable form Again, we must act without undue delay and in any event within 1 month of receipt of your request; We cannot charge you for this service.
A right to object	This is a right to object to the use of your personal information. The right applies in certain specific circumstances only. You can use this right to challenge our use of your personal information based on our legitimate interests; You can also use this right to object to use of your personal information for direct marketing.	If you object to us using your personal information for direct marketing, we must stop using your personal information in this way as soon as we receive your request. If you object to other uses of your personal information, whether we have to stop using your personal information will depend on the particular circumstances.
A right to restrict processing	This is a right to ‘block’ or suppress processing of your personal information. This right applies in various circumstances, including where you contest the accuracy of your information.	If we are required to restrict our processing of your personal information we will be able to store it but not otherwise use it. We may only retain enough information about you to ensure that the restriction is respected in future. If we have disclosed your personal information to others, we must (subject to certain exceptions) contact them to tell them about the restriction on use.

If you wish to exercise any of your rights, you can make a request by contacting the General Assembly Office (swyddfa.office@ebcpcw.org.uk and/or 029 2062 7465)

If you request the exercise of any of your rights we are entitled to ask you to provide us with any information that may be necessary to confirm your identity.

10. WHEN AND HOW CAN YOU WITHDRAW YOUR CONSENT?

If you have given us your consent to process your personal information, you can withdraw your consent at any time. To do so, please contact your local church.

11. HOW CAN YOU GET IN TOUCH WITH US AND WHO OVERSEES OUR COMPLIANCE WITH DATA PROTECTION LAW?

You can get in touch with us in the following ways:

Postal address	Presbyterian Church of Wales, Tabernacle Chapel, 81 Merthyr Rd, Whitchurch, Cardiff. CF14 1DD
Email address	Swyddfa.office@ebcpcw.org.uk
Phone number	029 20627465

We have appointed the Head of Corporate to oversee our compliance with data protection law and this privacy notice. If you have any questions about this privacy notice, how we handle your personal information or if you wish to make a complaint, please contact our Head of Corporate.

12. RIGHT TO COMPLAIN TO the information commissioner’s officer

If we are unable to deal with a complaint to your satisfaction or if you are unhappy with the way we are using your personal data, you also have the right to make a complaint at any time to the UK’s supervisory authority for data protection issues, the Information Commissioner’s Office.

13. CHANGES TO our privacy notice

We may update this privacy notice from time to time. If we make any substantial updates, we will provide you with a new privacy notice. We may also notify you in other ways from time to time about the processing of your personal information.