Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”)
This privacy notice is provided by Trinity Church Islington, which is the data controller for your data. In the rest of this notice “we” refers to Trinity Church Islington.
How Trinity Church Islington uses your information
We will process some or all of the following where necessary to perform our tasks:
Names, titles and aliases, photographs;
Contact details such as telephone numbers, addresses and email addresses;
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, education/work histories, academic/professional qualifications, hobbies, family composition, and dependents;
Where you make donations, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
The data we process is likely to constitute sensitive personal data because as a church, the fact that we possess your data at all may be suggestive of your religious beliefs.
How do we process your personal data?
The data controller will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
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 minister to you and provide you with pastoral and spiritual care (such as arranging to meet with you)
To deliver the Church’s mission and to carry out any other voluntary or charitable activities for the benefit of the public as provided for in the constitution and statutory framework of the data controller
To fundraise and promote the interests of the church
To administer the church attenders
To maintain our own accounts and records
To process a donation that you have made (including Gift Aid information);
To seek your views or comments;
To notify you of changes to our 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, events, other activities
To process a grant or application for a role
Why are we collecting your personal data?
We collect personal data to provide appropriate pastoral care and to fulfil our purposes as a church and to comply with the law regarding data sharing. Most of our data is processed because it is necessary for our legitimate interests. An example of this would be our safeguarding work to protect children and adults at risk. We will always take into account your interests, rights and freedoms. Some of our processing is necessary for compliance with a legal obligation. For example, we are required by HMRC to provide details of your personal data when your donations are eligible for Gift Aid.
Where your data is used for purposes other than one of these legal bases, we will first obtain your consent for that use.
Religious organisations are also permitted to process information about your religious beliefs to administer membership or contact details.
We do not share your information with others except as described in this notice.
Sharing your personal data
Your personal data will be treated as strictly confidential. We will not share your information with third parties without your consent unless the law requires us to do so. It is likely that we will need to share your data with some or all of the following (but only where necessary):
Within Trinity Church Islington: We will share your data amongst staff, trustees, treasurers, elders, small group leaders, for example, only when it is relevant to do so. When you give us your email address for church communications that is stored in Mailchimp. Staff use that information for their specific roles and if you join a small group or serving team that information may be collected by leaders of those groups. Alternatively it may be passed on from Mailchimp. Children’s data may be seen by their leaders on a Sunday.
For legal compliance: We may be legally obliged to share some information to comply with UK law. For example as a registered charity our accounts need to be audited by a 3rd party accountant. We also need to fulfil our legal obligations for safeguarding (e.g. DBS checks), for which it may be necessary to share your information with law enforcement bodies.
Agents, servants and contractors: We use a variety of 3rd party systems to help Trinity Church Islington function and provide services that we could not provide in-house. Examples of these are: Google for administrative tools like Google Forms, Sheets and Docs, Stewardship for accountancy services and Squarespace for our website & Wordpress for our blog.
Other churches or para-church organisations: On occasion we may share your data with other churches or para-church organisations if we are hosting joint events and the data is necessary for the running of those events.
Storing your personal data
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. 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.
Your rights and your personal data
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.
1. The right to access information we hold on you
At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request 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.
2. The right to correct and update the information we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us, and your data will be updated.
3. The right to have your information erased
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
4. The right to object to processing of your data
You have the right to request that we stop processing your data. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. 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.
5. The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
You can withdraw your consent easily by email (kirsten@trinityislington.org), by post (Trinity Church Islington Office, 5 Woodbridge Street, London, EC1R 0EX) or by clicking ‘unsubscribe’ on church communications that come from Mailchimp.
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
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. Our website is also accessible from overseas so on occasion some personal data (for example in a photo or newsletter) may be accessed from overseas.
Further processing
If we wish to use your personal data for a new purpose, not covered by this 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.
Contact Details
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
You can contact the Data Controller for Trinity Church Islington by using the following email: kirsten@trinityislington.org
You can contact the Information Commissioners 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.