DATA PRIVACY NOTICE
WORD International Ministries Ireland (“WIN-Ireland”)
- 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 EU General Data Protection Regulation (the “GDPR”).
- Who are we?
The WIN Ireland is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
- How do we process your personal data?
The WIN Ireland 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.
We use your personal data for the following purposes: –
- To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our by-laws;
- To administer membership records;
- To fundraise and promote the interests of the charity/church;
- To manage our employees and volunteers;
- To maintain our own accounts and records (including the processing of volunteer/members donations (tithes and offerings)/ ChurchTrac website);
- To inform you of news, events, activities and services running at WIN Ireland;
- To share your contact details with the WIN Ireland Administration office so they can keep you informed about news in the charity and events, activities and services that will be occurring in the charity/church and in which you may be interested.
- What is the legal basis for processing 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 charity events.
- Processing is necessary for carrying out legal obligations in relation to donations or employment, social security or social protection law, or a collective agreement;
- Processing is 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.
- Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the charity/church in order to carry out a service to other charity/church members or for purposes connected with the church. We will only share your data with third parties outside of the charity/church with your consent.
- How long do we keep your personal data?
We keep data in accordance with the guidance set out in the guide “Keep or Bin”.
Specifically, donations (tithes and offerings) and associated paperwork for up to 6 years after the calendar year to which they relate; and charity / church registers (water baptisms, marriages, funerals) permanently.
- Your rights and your personal data
Unless subject to an exemption under the EU GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which WIN Ireland holds about you;
- The right to request that the WIN Ireland corrects 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 WIN Ireland 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 Ireland Charities Office.
- Further processing
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.
Pictures and Video Under GDPR Regulation to Inform All the Members and Guest. That in this Charity/Church We Record the Worship Services in Video and Audio for sharing only within its membership and not in public.
Pictures and video are not exempt from GDPR. While GDPR is not designed to stop you from recording services or taking pictures of charity/church events, it does ask that you are very careful about what you do with these images, whether moving or still.
- Taking photographs
You do not necessarily need consent to take a picture or video of someone inside the charity/church, or at a church event, as most of the time this will count as a public place. Law allows you to take photos in a public place. However, if the person could have a reasonable expectation of privacy (for example, a support group, pastoral meeting or other more intimate setting) then you would need to get their consent.
- Displaying photographs
As churches, we need to take extra care with images or video, which identify people as Christians. This also applies if the images identify someone’s political affiliation or another special characteristic. If you would like to display these images, you will need to consider who is going to see them.
GDPR allows churches to process special category data under the ‘legitimate interest’ lawful basis, so long as they do not share the data outside the church body. Therefore, you may not need to get consent to display pictures which contain special category data so long as you are only displaying them inside the church.
However, if you wanted to put the pictures on your website (remember, this is only for pictures which contain special category or other sensitive data) you should get consent from anyone who is identifiable. This is because you will be broadcasting the images outside the charity/church.
- Video-streaming services
The same restrictions apply to moving images as to still. If the video is going to identify the people in it through special category or other data, then you must get consent before broadcasting the video.
Some churches may routinely video special services, for example weddings and dedications, in order to provide the family with a copy. There is no issue with doing this, but if you are going to share the video outside of the church body (for example, if you want to put it on your website or Facebook Public Page) you must gain permission. The family can show the video to whomever they like; churches need only be concerned about what happens to data within their own control.
- Do these restrictions apply to every photo or video taken inside the church?
No. A picture of someone inside Church does not necessarily identify him or her as a Christian. Neither does a video of someone attending a wedding or dedication. However, pictures or video of someone being water baptised, receiving Communion, or otherwise actively engaging in praise and worship would do so.
Even if the image does not contain any special category data, you should also consider if any other identifying information is visible, e.g. a car number plate from an image obtained using CCTV.
- What about large-scale faith-based events like family conferences or anniversaries?
It is not always feasible to get individual consent from everyone attending a large faith-based event. In addition, attending such an event does not necessarily identify someone’s faith or other special category statistic, and it will almost certainly count as a public place, in which case EU law allows photography and videography.
In this case, they advise that you take the following steps:
- At the point of booking, make attendees aware that photos/videos will be taken
- At the event, have signs reminding people that photos/videos may be taken
- If possible, have some areas in which photography is not allowed
- Get consent before photographing or videoing any situation in which the subject could have a reasonable expectation of privacy
- Consider the special category data content of photos and videos before you display or stream them and get consent at that point, if you need it
- Document your decision-making process
- Let attendees know who they should contact if they have any concerns
If you are not sure, the best practice is always to get consent. However, that consent will only be valid if it is freely and explicitly given, documented, and you do not create or use images for any other purpose than the one for which consent was given.
- Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the WIN Ireland Relationship Department at [firstname.lastname@example.org].
You can contact one of the Pastors/ Ministry Heads via web site at this link below http://wordinternationalireland.com/?page_id=49