Privacy and Data Policy

We are Clergy Support Trust and for the purposes of UK Data Protection Law, we are registered with the ICO. We are an independent charity supporting serving and retired clergy and ordinands in the Church of England, Church in Wales, Church of Ireland and Scottish Episcopal Church in times of need. We also support their spouses, partners, widows and widowers. In certain circumstances, former clergy as well as former spouse/partner can also access limited provision.

Please click on the relevant appendices below

Appendix 1 – Human Resources

Appendix 2 – Service Users

Appendix 3 – Fundraising and Marketing

Under data protection laws in the UK and EU, you have certain rights over the personal information that we hold about you. If you would like to exercise your rights, please get in contact with any of the details listed above. Here is a summary of the rights we think apply:

a. Right to be Informed

You have the right to be informed about how we use your data and under what lawful basis we carry out any processing. This Privacy Notice sets this information out; however, please get in touch if you want further information.

b. Right of Erasure – also known as the right to be forgotten

You may ask us to delete some or all your information we hold about you. Sometimes, where we have a legal obligation, we cannot erase your personal data.

c. Right to Object

You have the right to object to processing where we are using your personal information such as where it is based on legitimate interests or for direct marketing.

d. Inaccurate personal information corrected

Inaccurate or incomplete information we hold about you can be corrected. The accuracy of your information is important to us, and we are working on ways to make this easier for you to review and correct the information that we hold about you. If any of your information is out of date or if you are unsure of this, you can update these details by logging into our online system or contact us to amend any information after you have submitted your application.

e. Right of restriction

You have a right to restrict the processing of some or all your personal information if there is a disagreement about its accuracy, or we are not lawfully allowed to use it.

f. Right to Access your information

You have a right to request access to a copy of the personal information that we hold about you, along with the information on what personal information we use, why we use it, who we share it with, how long we keep it for and whenever it has been used for automated decision making. You can make a request for access free of charge and proof of identity is required.

g. Automated decision making

Automated decision-making occurs when an electronic system uses personal information to make a decision without human intervention. You have the right to question the outcome of automated decisions that may create legal effects, or create a similar significant impact on you.

h. Portability

You can ask us to provide you or a third party with some of the personal information that we hold about you.

i. Right to withdraw consent

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

Where personal data is stored outside of the UK and the EEA, safeguards to protect personal data may include but are not limited to the UK Addendum used in conjunction with the EU Standard Contractual Clauses (SCCs), or UK International Data Transfer Agreement (IDTAs). Such safeguards will be subject to Transfer Risk Assessments (TRAs).

If you are unhappy with how we process your data, please contact us using one of the contact methods above. You can also raise a complaint with the Information Commissioner’s Office (ICO) which regulates the use of information in the UK. They can be contacted by at 0303 123 1113 or you can write to them at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

This privacy notice is kept under regular review. If we make any significant changes to the way in which we process your information, we will let you know by either contacting you via email or publishing the information on our website. 

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment/engagement. In some cases, we will collect data about you from third parties, such as employment agencies or former employers, when gathering references, and the Disclosure Barring Service where required.

We keep several categories of personal data on our employees/freelancers/job applicants/ trustees/advisors to carry out effective and efficient processes. Specifically, depending on your type of engagement with Clergy Support Trust, we may process the following types of data:

1. a.    personal details such as name, address, phone numbers, email addresses
2. b.    name and contact details of your next of kin
3. c.    your photograph, marital status
4. d.    footage of the organisation events where you may appear
5. e.    information of any disability or other medical information you have disclosed
6. f.    Right-to-Work and identification documents
7. g.    information gathered via the recruitment process, such as that included in a CV, cover letter or application form, references from former employers, details on your education and employment history, interview notes and written tests, etc
8. h.    National Insurance number, bank account details and tax codes
9. i.    information relating to your employment with us (e.g. job title, job description, salary, terms and condition of the contract, annual leave records, appraisal and performance indication, formal and informal proceedings involving you such as letters of concern and disciplinary, disciplinary and grievance proceedings
10. j.    internal and external training modules undertaken
11. k.    information on time off from work, including sickness absence, family-related leave etc
12. l.    IT equipment use, including telephones and internet access
13. m.    your biography and photograph for the website (if applicable)

We may also process special category data which may include health information for any reasonable adjustments. When we help you undertake an occupational health assessment with an external provider for assessing any reasonable adjustments, this information is provided to us by you. We would keep a copy of the occupational health assessment as a part of our records. We process a criminal records declaration with our applications, and may also process criminal records information if the role involves a DBS check.

If you require any therapeutic or supervision support due to the role performed in the organisation, we do not receive any personal information from these organisations.  We only receive invoice information (anonymised) and/or number of sessions used. All sessions are confidential.

We are required to use your personal data for various legal and practical purposes to administer your contract of employment or your trustee agreement, without which we would be unable to employ you. Holding your personal data enables us to meet various administrative tasks, legal obligations or contractual/agreement obligations. We process information about the DBS for our safe recruitment practices.  When we receive any occupational health assessment, we rely on this only to make reasonable adjustments.

We mainly use ‘contractual obligation’ as a lawful basis for processing personal data for employees, job applicants, freelancers and advisors. We mainly use ‘legitimate interest’ for trustees. We may also have a legal obligation to process and share your data, for example, we need to share salary information to HRMC or use some of your data to enrol you as a new employee on a pension scheme.

We may rely on our legitimate interest for processing activity such as keeping supervision and appraisal records; using your image, biography and videos/photographs of the organisations’ events where you may appear on our website, social media, or marketing/fundraising materials to promote the charity.

Some special categories of personal data, such as information about health or medical conditions, are processed to carry out employment law obligations (such as those concerning colleagues living with disabilities and for health and safety purposes). When processing criminal records (for example, to perform a DBS check), the organisation relies on the lawful basis of legitimate interest. When processing special category of data and criminal records, we rely on additional conditions of the UK GDPR and DPA 2018.
 

We only keep your data for as long as we need it for, which will be at least for the duration of your employment/engagement with us, though in some cases we will keep your data for a period of 6 years after your employment/engagement has ended. If you’ve applied for a vacancy but your application hasn’t been successful, we will keep your data only for 6 months.

Some data retention periods are set by the law. Retention periods can vary depending on why we need your data. Please get in touch by contacting us using the details above if you want to know more about the retention period.

Data is destroyed or deleted in a secure manner as soon as the retention date has passed.

Personal Data about your salary is shared with HRMC as part of our legal obligation. Personal Data may be shared with third parties for the following reasons: for the administration of payroll, pension, HR functions (for example, the online annual leave booking system), administering other employee benefits and for any security passes. When sharing information with third parties, we have data sharing, processor agreements or contracts in place to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We may collect the following information about you when you apply for grants, complete feedback surveys or fill out an application on our website for one of our services, such as counselling. This information can include: name, date of birth, gender, ethnicity, religion, contact details, health conditions, details of how you interact with us, life background, health information, safeguarding information. It may also include any sensitive data that you may voluntarily provide, as part of your description of your circumstances. This information is provided to us by you when you apply to us and is processed by us and potentially, the external service providers we engage. We may also collect information for our case studies. On certain occasions, we also conduct surveys through survey forms.

We may use your personal information to  

• Carry out a thorough assessment of your needs
• Provide an appropriate service which best meets your needs
• Monitor and manage risk
• Protect you and the general public
• Identify and monitor safeguarding concerns
• Carry out evaluation of our services and charitable activities
• Create case studies
• Collate anonymised or pseudonymised statistical information for funders, the charity and delivery partners 
   

We mainly rely on legitimate interest as our lawful basis for processing your personal data for the main activities we provide. When we process special category of data and criminal records, the lawful basis is substantial public interest, read with conditions from the Data Protection Legislation.

For case studies, we rely on your consent. For research and evaluation purposes, we rely on our legitimate interest.

We retain the personal data of all service users and beneficiaries for a period of 6 years in line with our retention periods. If you would like to know more about this, please contact us at the email address above.

• We may share your data with the service providers we engage with to provide support. These organisations act as data processors and process such data on our behalf.
• We may use the website, email newsletters and several social media channels to share your information, like case studies, relying on your consent.
• When sharing information with funders, we will provide information anonymously.
• To comply with our duty of care and safeguarding, we may need to pass some information to raise a safeguarding concern with one or more of the appropriate statutory authorities, which includes the police and/or associated Diocesan Safeguarding Leads. In such circumstances, we apply vital interest and legitimate interest as our lawful basis. Data subjects’ rights and other UK GDPR provisions may be restricted when concerning personal data processed in these circumstances. Exceptions and exemptions are applied on a case-by-case basis. Please refer to our safeguarding statement on our website.
• Please note that as a part of our assessment of your application, we may carry out a disciplinary or criminal background check in some circumstances. However, we only use publicly available resources for this and reserve the right to investigate. We rely on legitimate interest for conducting such searches.
• We may use your photographs for our website or for our case studies, for which we take your consent through forms.

Information is provided by you via a donation form on our website or via third party donation platforms (such as Stewardship, CAF and JustGiving). The information gathered may be: name, email address, Gift Aid declaration, the name of your company, livery company, church or charitable trust if the donation is made by an organisation, donation details, reasons to engage, postal address.  We store the information on Gift Aid declarations for 6 years.

This information allows us to process your donation, and deal with any potential enquiry. We rely on our legitimate interest to process this data.  If you agree that we can claim Gift Aid on your donations, we are legally required to keep a record of the claim and your Gift Aid declaration.  If you are donating using a third party, please also refer to the privacy notice published on their websites.

On occasion that you decide to leave us a legacy gift through our free will scheme provider (such as FareWill), we would only receive information about the prospective amount of your gift. We would also be recipient to your location in the UK, but we would not have identifiable data on you unless you choose to tell us.

To identify potential supporters, we may use profiling and screening techniques. We may undertake research either in-house or through an external provider to gather information about you from publicly available sources, including Companies House, the Electoral Register, company websites, social networks and news archives.

We gather publicly available information regarding previous charity support, connection to our cause, geographical and demographic details, financial situation, career information, peer networks and other publicly available information (e.g. age, address, listed directorships, trusteeships, memberships and interests).

This information also allows us to understand how likely it is that you would be interested in supporting us. We rely on our legitimate interest to profile and screen your information. If you would like to be excluded from this, please let us know and we will respect your wishes. Otherwise, following our initial profiling and screening, we may contact you either via phone, letter or electronic communication. If you are happy to engage with us, we will proceed with establishing our relationship with you, which will include further engagement and profiling.

Information is mainly provided by you via our website forms, via third party platforms or in person during the events by the same digital forms or by paper forms. The information gathered may include: name, email address, phone number, organisation details, donation/payment details, reasons to engage, postal address, email address, your contact and other preferences.

This information allows us to administer your sign up, process payments, and deal with any potential enquiry. We rely on the legitimate interest to process this data.   

During these types of events, we may also take photographs and videos of people attending where you may be included. This information allows us to showcase our work and have effective external communications. We rely on legitimate interest to process this data. These photographs and videos may be used on our website, social media, in presentations or shared with the media. Press may be invited to our events, with photographs and filming potentially gathered and used in their broadcasts, publications, websites or social media.  If you are signing up to an event using a third party, please also refer to the privacy notice published on their websites.

Information is provided mainly by yourself, via online or paper forms or phone/email conversation with us. The information gathered may include: occupation, title, details of any correspondence you have had with us, age, fundraising appeal responses, event participation and your reasons for engaging with us. This information allows us to deal with your enquiry. We rely on our legitimate interest to process this data.

Your contact details may be used to provide you with information about our services or our fundraising opportunities via email, letter, text, or other electronic message. We will only send you fundraising and marketing communications by letter, email, text or other electronic message, if you have provided your consent. You may opt-out of our fundraising and marketing communications at any time.