Introduction
Welcome to the privacy notice for the Trustees for Methodist Church Purposes (TMCP).
TMCP respect your privacy and are committed to protecting your personal information (personal data). This privacy notice lets you know how we look after your personal data which either you provide to us or we obtain and hold about you and it tells you about your privacy rights and how the law protects you.
This privacy notice is available online in a layered format so you can click through to the specific areas that you may be interested in. These are set out below. Alternatively you can download a PDF version by clicking the 'Download' link at the top of this page or you may have been provided with a hardcopy (printed) version of the notice. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy as set out in this privacy notice under regular review. This version was last updated on 28 May 2019.
We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation. We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online notice regularly to see if any updates have been made.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This privacy notice aims to give you information on how TMCP collect and process your personal data which either you provide to us or we obtain and hold about you through your use of our websites (including any data you may provide when you subscribe to receive updates through the News Hub or contact us using the online contact form) or through other interactions with TMCP (including any data that you provide when you contact us for guidance, ask us to make payments, ask us to liaise with professionals on your behalf or in the case of members of staff and volunteers of TMCP, when you perform services for us).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or dealing with personal data about you (e.g. employment privacy notices) so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Trustees for Methodist Church Purposes (being a charitable body corporate established by the Methodist Church Act 1939 and registered charity number 1136358) (TMCP) is the controller and responsible for your personal data (collectively referred to as TMCP, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: | Trustees for Methodist Church Purposes |
Postal address: | Central Buildings Oldham Street Manchester M1 1JQ |
Name of Data Privacy Manager: | Laura Carnall, Legal Manager |
Telephone number: | 0161 235 6770 |
Email: | |
Web: |
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy as set out in this privacy notice under regular review. This version was last updated on 28 May 2019.
We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation. We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online notice regularly to see if any updates have been made.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about our Board Members, employees, visitors to our premises and our websites, Managing Trustees, ministers, volunteers, individuals who provide services to us and individuals who contact us. We have grouped the different kinds of personal data together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could
be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation under a tenancy agreement or process gift aid payments). We will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We take our obligations under data protection law (including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018) seriously. We keep personal data as up to date as possible and take active steps to rectify any personal data we find to be incorrect. We store and destroy personal data securely and do not collect or retain personal data which is in excess of our processing activities. We take steps to protect all personal data (including Special Category Data) from loss, misuse, unauthorised access and disclosure by ensuring that appropriate measures are in place to protect personal data.
We ensure that personal data is processed in accordance with the principles of the GDPR and is processed:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
In rare cases we may need to use your personal data in the following circumstances:
Refer to the Lawful Bases Guidance Notice (click here if you are reading this privacy notice online) to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting the Data Privacy Manager although this will not prevent processing where the law allows us to process for a different reason in addition to consent.
Where data processing relates to Special Categories of Data (e.g. health information included in your employment records or dietary requests) the following processing conditions apply in addition to the legal basis identified in the table in the Annex to this privacy notice:
We have set out in detail in the Annex to this privacy notice, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in the Annex.
We like to notify you about upcoming events including conferences, presentations and training opportunities so that you can benefit from the support and guidance available and play as much of a role in the life of TMCP and the wider Church as you choose from time to time. Most of the time we will let you know about such opportunities on the basis that we have a legitimate interest in doing so.
If we decide to contact you by email or telephone where you are registered with the telephone preference service we will provide you with choices as required to do so under data protection legislation and the Privacy and Electronic Communications Regulations 2003 (PECR).
We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages (e.g. messages about TMCP events or notification of new articles published on the News Hub section of our website) by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided to you e.g. although the marketing messages will be stopped we may still need to use your personal information for other purposes relating to your employment with us, guidance we provide to you and transactional issues etc.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please refer to the information available from www.aboutcookies.org.uk or see our cookie policy when it is available.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table in the Annex. Internal third parties such as:
We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may at times transfer and process personal data outside of the EEA. This is particularly relevant in relation to transactions, trust matters and data protection issues on the Channel Islands and Isle of Man.
However, storing, publishing or transmitting personal data via the internet, (this includes by email), is not completely secure and therefore whilst we take all reasonable and necessary precautions to protect personal data from unauthorised access, you acknowledge that there is a risk that your personal data may be transferred and accessed outside of the EEA.
We implement reasonable and appropriate security measures against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data in accordance with our internal data security policy. In addition, we limit access to your personal data to those members, volunteers, ministers and employees who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place reasonable and appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Full details of retention periods for data processed by us can be found in our retention policy which you can request from us by contacting us using the contact details in this privacy notice.
In some circumstances you can ask us to delete your data: see Section 9 and details about Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Unless personal data is subject to an exemption under GDPR, such as itis subject to the prevention, investigation, detection or prosecution of a criminal offence, you have the following rights with regards to your personal data:
Further information, guidance and advice is available from the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
If you wish to exercise any of the rights set out above, please contact the Data Privacy Manager.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
“controller” is the controller described in Section 1 of this privacy notice.
“data subject” is a living, identified or identifiable individual about whom personal data is held. e.g. our members, volunteers, lay employees, those who join us in worship and/or those who are interested in and supportive of the work of the Methodist Church and third parties such as community groups who use our buildings and other third parties.
“explicit consent” is a very clear and specific statement of consent.
"GDPR" means the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the safeguards specified in the GDPR.
“lawful bases” are the five lawful grounds on which we can lawfully process personal data set out under Article 6 of GDPR. The lawful basis or bases on which we rely are set out under Section 4 of this privacy notice.
“Managing Trustees” means the managing trustees of property held by the Methodist Church from time to time ascertained in accordance with the provisions of Part II of Schedule 2 to the Methodist Church Act 1976.
“Methodist Church in Great Britain”, “Methodist Church” or “Church” refers to the united church or denomination known as the Methodist Church formed under the provisions of the Methodist Church Union Act 1929 and a deed of union on 20 September 1932.
“personal data” is any information identifying a living individual or information relating to an individual that can be identified from that information/data (alone or in combination with other information in your hands or that can reasonably be accessed). Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal information includes an individual’s name, address, date of birth, telephone number, email address, a photograph or disability, health or ethnicity data.
“Processing” “processed” or “process” means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any activity or set of activities on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties. E.g. fulfilling obligations under an employment contract with you or responding to an enquiry that you raised with us.
“Websites” mean the websites that we run at https://www.tmcp.org.uk and the TMCP Trust Information System (TIS) at https://tis.tmcp.org.uk/.
Purpose/Activity | Type of data
Please refer to Section 2 for confirmation of what details these categories of data include | Lawful basis for processing including basis of legitimate interest |
---|---|---|
A(1) Administration – General To administer our office, staff and operation of the Board including managing and maintaining our premises, facilitating meetings, keeping accounts and tax records, taking audits and recording decisions reached at meetings. | a) Administrative (b) Contact (c) Identity (d) Financial (e) Tax (g) Technica | (a) Necessary for our legitimate interests (for running our charity, fulfilling our obligations under charity law, complying with the Constitution Practice and Discipline of the Methodist Church, the 1939 Trust Deed and providing support to Managing Trustees and the wider Church) (b) Performance of a contract with you (c) Necessary to comply with a legal obligation |
A(2) Administration - Website To administer, run and protect our website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data as well as facilitating sign up to our News Hub updates and notifications feature and enabling you to contact us through the website. | (a) Administrative (b) Contact (c) Image (d) Identity (e) Marketing and Communications (f) Member and Group (g) Technical | a) Necessary for our legitimate interests (for running our website and improving its functionality and service that it provides to you as part of our role in providing guidance and support to Managing Trustees and the wider Church) |
Administration – Promaster and Trust Information System (TIS) To administer, run and protect Promaster and the TIS including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data to enable you to access information on trusts and us to deal with enquiries relating to trusts and trust funds. | (a) Administrative (b) Contact (c) Identity (d) Member and Group (e) Technical | a) Necessary for our legitimate interests (for running the TIS and improving its functionality and service that it provides to you as part of our role in providing guidance and support to Managing Trustees and the wider Church) |
Administration - Controller To manage and administer our role as controller both internally and for the wider Church including dealing with requests made by data subjects e.g. subject access requests and assisting the Connexional Team in their role as controller. | (a) Administrative (b) Contact (c) Identity (d) Member and Group (e) Official Records (f) Special Category (e.g. health or safeguarding issues that might be raised in a subject access request) (g) Transaction | (a) Necessary for our legitimate interests (for fulfilling the duties placed on us as controller for the wider Church and point of contact with the ICO, helping Managing Trustees to deal with subject access requests and othe data subject rights) (b) Necessary to comply with a legal obligation |
B(1) Contact - Internal To contact you and circulate information relating to internal TMCP matters including the Board and your employment with us. | (a) Contact (b) Correspondence (c) Employment (d) Identity (e) Marketing and Communications (f) Member and Group (g) Technical (h) Transaction | (a) Necessary for our legitimate interests (to process payment and trusts requests, to deal with enquiries or forward information from third parties relating to property, to provide support and guidance to you and notify you about things which may be of interest to you to help you to fulfil your role within TMCP and the wider Church and to generally function as a custodian trustee body and employe |
B(2) Contact – Wider Church To contact you and circulate information about trusts, bequests, payments, charity trustee and property matters and other matters that you are involved in as a Managing Trustee. To contact, update and notify you about events and changes to the law including changes/updates to Methodist law, policy and best practice where you have signed up to updates through our websites or otherwise. | (a) Contact (b) Correspondence (c) Employment (d) Identity (e) Marketing and Communications (f) Member and Group (g) Technical (h) Transaction | (a) Necessary for our legitimate interests (to process payment and trusts requests, to deal with enquiries or forward information from third parties relating to property, to provide support and guidance to you and notify you about things which may be of interest to you to help you to fulfil your role within TMCP and the wider Church and to generally function as a custodian trustee body. |
C Correspondence To contact you to respond to/deal with enquiries that you or others within and outside the Church have raised, to provide guidance. | (a) Contact (b) Correspondence (c) Employment (d) Identity (e) Marketing and Communications (f) Member and Group (g) Special Category (e.g. health or safeguarding issues that might be raised in incoming correspondence) (h) Transaction | (a) Necessary for our legitimate interests (to fulfil our role as custodian trustee and employer by dealing with enquiries and providing support and guidance to you). |
D HR Management To administer and manage our relationship with our employees including keeping and maintaining records of staff development, carrying out reviews and appraisals, dealing with employment issues including disciplinary issues, absence, illness and requests for changes in working patterns and supporting our employees generally. | (a) Administrative (b) Contact (c) Employment (d) Financial (e) Identity (f) Image (g) Recruitment (h) Special Category (e.g. health and disciplinary information) (i) Tax | (a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and looking after our employees) (b) Performance of a contract with you (c) Necessary to comply with a legal obligatio |
E Lists To keep and maintain records of: (a) contact details for Board Members, employees, Ministers, office holders, Managing Trustees and others within and associated with the Church (b) roles held by you within TMCP and the Church generally including Managing Trustees responsible for particular properties (c) members of internal and external committees (d) attendance at training and other events that we may organise from time to time and those who have completed training e.g. Managing Trustees who have completed rent smart Wales training (e) bank details where payments are made to individuals | (a) Contact (b) Employment (c) Identity (d) Member and Group (e) Official Records (f) Recruitment | (a) Necessary for our legitimate interests (to operate as a membership organisation, keep our records updated, study how our membership changes over time, identify the needs of the communities in which we operate and support our members) |
F Payments Making payments to your bank account including to pay staff wages and other employment related benefits, to pay invoices, grants and fulfil payment requests, to reimburse you or expenses incurred by you and obtaining, keeping and maintaining records of your account details to facilitate payments. | (a) Contact (b) Employment (c) Identity (d) Financial (e) Transaction | (a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and reimbursing people for out of pocket expenses). (b) Performance of a contract with you (c) Necessary to comply with a legal obligation |
G Record keeping To keep and maintain records including charity records, correspondence and guidance given, discussions and decisions reached including grants given and applications considered, property and financial transactions, trustee decisions, ID records for Bank etc. and usage or our Websites. | (a) Contact (b) Correspondence (c) Financial (d) Identity (e) Official Records (f) Tax (g) Transaction (h) Usage | (a) Necessary for our legitimate interests (for keeping official records of decisions, running our charity recording compliance with trusts and charity law and providing support to the wider Church, records of bequests and trusts matters, disposals, acquisitions and other property transactions (including money based transactions) to assist in decision and policy making and day to day running of the charity including visitors to our premises.) (b) Performance of a contract with you (c) Necessary to comply with a legal obligation |
H Recruitment To administer applications for job vacancies including the interview process and keeping and maintaining records of applicants and the recruitment process e.g. interview notes and scores. | (a) Contact (b) Identity (c) Employment (d) Financial (e) Recruitment (f) Special Category (e.g. health information) | (a) Necessary for our legitimate interests (for running our charity and filling job vacancies). |
Security To record and use images. | (a) Image (b) Identity | (a) Necessary for our legitimate interests (to keep church premises and our members, ministers, volunteers, employees and third parties secure) |
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