Privacy Policy v20180519

The German Church of Liverpool 

1. Who are we?

The German Church of Liverpool is the data controller of your personal data (contact details below). This means we decide how your personal data is processed and for what purposes.

The Church is affiliated with other congregations to the Synod of German-Speaking Lutheran, Reformed and United Congregations in Great Britain. The Church works with the pastors and other office holders of the Synod and other congregations affiliated to the Synod to enable it to perform its mission.

As the Church is made up of all of these persons and organisations working together, we may need to share personal data we hold with them so that they can carry out their responsibilities to the Church and our community. The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.

Each of the data controllers has their own tasks within the Church, the Synod and other congregations. A description of what data is processed and for what purpose is set out in this Privacy Notice.

2. Your Personal Data – What is it?

Personal data relates to a living individual who can be identified from that data. This ranges from your name to your IP address or other online identifiers. 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. In the EU the processing of personal data is governed by the General Data Protection Regulation (the GDPR).

3. Your Rights 

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights. Once we have received your request, see contact details below, we will respond within one month. There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.

• The right to request a copy of your personal data which we hold about you (the right of access).
• The right to request that we correct any personal data if it is found to be inaccurate or out of date (the right to rectification);
• The right to request your personal data is erased where it is no longer necessary for us to retain such data or we are not required to hold it for regulatory purposes or our legitimate interests (the right to be forgotten).
• Alternatively, 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. This means we retain your personal data but are not allowed to use it (the right to restrict processing);
• The right to withdraw your consent to the processing of personal data at any time where the lawful basis of holding it is explicit consent;
• The right to object to the processing of personal data where applicable. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
• The right to lodge a complaint with the Information Commissioner’s Office (contact details see section 7).

4. How do we process your Personal Data?

The German Church of Liverpool complies with its 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.

The data processing is carried out using pen and paper, computers, software and cloud IT services, following procedures strictly related to the purposes indicated. We use third party data processors to process personal data on our behalf, for our Internet services and our cloud IT services, e.g. data storage (see section 5. below). These third parties have been carefully chosen and all of them comply with the GDPR. All these third parties are based in the USA and are EU-U.S. Privacy Shield compliant.

4.1 Members of the German Church of Liverpool

1. What personal data do we process?
   • Names, titles and aliases (we need to know who you are)
   • Contact details, such as address, phone numbers, email address; (we need to be able to contact you)
   • Photographs (we take pictures at events from time to time)
   • Gift aid status and records of financial transactions (we need to account for membership fee payments, donations and taxation thereof)

Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, family composition, and dependants.

1. We use your personal data for the following purposes: 
   • to enable those who undertake pastoral care duties to do so
   • to enable us to meet all legal and statutory obligations
   • to carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments
   • to deliver the Church’s mission to our community, and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in the constitution of each organisation and the statutory framework of each data controller 
   • to administer the membership records of the Church
   • to fundraise and promote the interests of the Church and charity
   • to manage our employees and volunteers
   • to maintain our own accounts and records
   • to seek your views or comments
   • to notify you of changes to our services, events and role holders
   • to send you communications which you have requested and that may be of interest to you (these may include information about campaigns, appeals, other fundraising activities)
   • to inform you of news, events, activities and services running at the German Church of Liverpool and of relevance for German speaking people in Great Britain
   • to process a grant or application for a role
   • to enable us to provide a voluntary service for the benefit of the public
   • to share your contact details with the Synod so they can keep you informed about news in the Synod and events, activities and services that will be occurring in the Synod and in which you may be interested.

1. What is the legal basis for processing your personal data?

Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as the Synod). Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.

Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.

1. Sharing your personal data
   • Your personal data will be treated as strictly confidential.
   • It will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ tasks or where you first give us your prior consent. 
   • It is possible that we will need to share your data with role-holders of the Synod and affiliated congregations including the other data controllers; 
   • We also ask third party data processors of our choosing to process your data (for example, we ask a commercial provider to send out newsletters on our behalf, or to host our IT services).
2. How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so or for historical reasons. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.

4.2 Users of our Internet Services (Website, Email)

1. Website 

• (Purpose) We provide a website https://deutschekircheliverpool@blogspot.co.uk in order to interact with the general public and to inform members and interested parties of the general public about news, events, activities and services running at the German Church of Liverpool as well as other information of general interest or of relevance for German speaking people in Great Britain.
• (Processing and Sharing) Sending information over the internet is generally not completely secure. However, while you browse our website your interactions with our website are protected via an HTTPS connection, which provides encryption of the data stream going back and forth.
• Our website is hosted by Google LLC. We consider Google to be a third party data processor (see section 5.0 below). Google will collect information of your visit to our website (e.g. your IP address, date, URLs, etc. See Google privacy policy for further reference) in their server logs out of their legitimate interest in providing a responsive service and keeping forensic evidence in case of service disruptions or data breaches.
• When you fill in forms on our website the relevant data will be stored in our online Google Drive.
• We do not use Facebook widgets. Instead we only use an image with a link to our Facebook page that avoids tracking your visit to our website by Facebook.
• Our website does not use cookies. But you can always disable cookies in your internet browser altogether:
  • In Internet Explorer you can manage your cookie settings by clicking “Tools”, “Internet Options”.
  • In Firefox you can change your cookie settings by clicking the menu button and choosing Preferences. Select the Privacy & Security panel and go to the History section. In the drop-down menu next to “Firefox will”, choose  “Use custom settings” for history. Un-check the „Accept cookies from sites“ checkbox to disable cookies. 
  • In Chrome you can manage your cookie settings by clicking “Settings”, “Show advanced settings…” and then pressing the “Content settings…” button under “Privacy”.
  • In Safari you can manage your cookie settings by clicking “Preferences”, “Privacy”.

1. Email

• (Purpose) We provide an email address deutschekircheliverpool@gmail.com as a means to contact the church council of the German Church of Liverpool.
• (Processing and Sharing) Should you choose to contact us using an email, you transmit your correspondence in clear text using the Simple Mail Transfer Protocol (SMTP) unless the transfer is protected by encryption. Our SMTP servers (of our third party data processor Google) are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. So, as long as your (and all other email server along the way) are protected by TLS/SSL the content of the transferred email will be secure from prying eyes. But not all SMTP servers are configured like this. Therefore you should never disclose sensitive information in an email.
• Note, this is not an end-to-end encryption as with pgp-encrypted emails,  meaning Google (like any other email service) has access to the clear text content of the email when it reaches their servers.
• (Retention) We will store all correspondence by email for 10 years unless requested you ask us to erase it and the correspondence is no longer necessary for the German Church of Liverpool to process.

1. “Newsletter” and other email lists

• (Purpose) We maintain the “Newsletter” and other email lists in order to inform you of news, events, activities and services running at the German Church of Liverpool that are of general interest or of relevance for German speaking people in Great Britain.
• (Processing and Sharing) If you choose to join the “Newsletter” and other email lists, the email address (required) and your first and last name (optional) that you submit to us will be forwarded to MailChimp who provide us with email management services. We consider MailChimp to be a third party data processor (see section 5. below). The information that you submit will not be stored within our internal or cloud computer systems.
• (Retention) Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email management 
• or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in the footer of any email that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
• If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

4.3 Contractors, Tenants

1. What personal data do we process?
   • first and last name;
   • address;
   • phone numbers;
   • email address;
   • records of financial transactions;
   • mentioning of name in meeting minutes;
   • information in letters and email correspondence;
2. We use your personal data for the following purposes: 
   • To keep a record of our contractors and tenants; 
   • To manage our contractors and tenants;
   • To keep contractors and tenants informed;
   • To conduct financial transactions;
   • To handle insurance cases;

1. What is the legal basis for processing your personal data?

The bases for processing personal data of contractors and tenants are contractual and legitimate interest.

1. Sharing your personal data

1. Your personal data will be treated as strictly confidential and will only be shared with other members of the church council for purposes connected with the church and your tenancy. 
2. We may share your contact details with other tenants if the necessity arises after seeking you consent beforehand. 
3. We may share your details with our bank or insurance company. 
4. Otherwise we will only share your data with third parties outside of the church with your explicit consent.
5. How long do we keep your personal data?
   • Tenant details for as long as the tenancy lasts plus 6 years;
   • Email addresses in the tenant newsletter email list for as long as the tenancy lasts.

5. Third Party Data Processors

We use third parties to process personal data on our behalf for our Internet services and our cloud IT services. Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. As such, our chosen third party data processors have servers based in the USA but are, both, GDPR and EU-U.S. Privacy Shield compliant:

• Google LLC (Privacy policy)
• Mailchimp (The Rocket Science Group, LLC.) (Privacy policy)

6. Data Controller Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the German Church of Liverpool at deutschekircheliverpool@gmail.com.

7. The Information Commissioner’s Office Contact Details

You can contact the Information Commissioner’s Office on 0303 123 1113 

or via email https://ico.org.uk/global/contact-us/email/ 

or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

8. Changes to our Privacy Policy

If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, 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, otherwise, we recommend that you check this privacy notice occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

8.1 Change Log

19/5/2018 – adjusted retention periods and tenant section, expanded description of SMTP emails, added mentioning of Facebook links, removed reference to Google Analytics as we do not use it, added reference to Google server logs, merged additional text from Synod template

30/4/2018 – Initial version