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 Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998].
Who are we?
The FFWPU UK is made up of a number of different groups and office-holders who work together to deliver the movement’s mission in each community. The Trustees work together with:
- the incumbents of the local communities (that is, our pastors and local committees);
- the incumbents of the HQ departments (such as General Affairs, Blessed Family, Education, HARP, CARP etc.)
- the National Director of the FFWPU UK;
- the National Council and Council of Communities; and
- the Finance Committee, which is responsible for the financial and administrative arrangements for the assets of FFWPU UK.
As the movement is made up of all of these persons and groups working together, we may need to share personal data we hold with them so that they can carry out their responsibilities to the movement and our communities. The groups referred to above are joint data controllers. This means we are all responsible to you for how we process your data.
What data do the data controllers listed above process? They will process some or all of the following where necessary to perform their tasks:
- Names, titles, aliases and 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 and blessing status, blessing group, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants;
- Where you make donations or pay for activities such as use of a hall, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers;
- The data we process is likely to constitute sensitive personal data because, as a religious movement, the fact that we process your data at all may be suggestive of your religious beliefs.
How do we process your personal data?
The data controllers 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 visiting you when you are gravely ill or bereaved) and to organise and perform ministerial services for you, such as Blessings and Seonghwas;
- To deliver the movements 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 and statutory framework of each data controller;
- To administer the local communities, regions and national membership records;
- To fundraise and promote the interests of the movement and charity;
- 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 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 process a grant or application for a role;
- To enable us to provide a voluntary service for the benefit of the public in a particular geographical area as specified in our constitution;
- Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
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 another organisation connected to the FFWPU UK). 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.
- We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the hire of the movements’ facilities.
- 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.
Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties that are connected to our movement (such as the International FFWPU (Korea) or FFWPU Europe & Middle East Office) where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- The appropriate bodies of the FFWPU UK including the other data controllers;
- Our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software;
- Assistant or temporary pastors, missionaries and envoys with the National Directors permissions may participate in our mission in support of our regular pastors, local communities and HQ departments;
- On occasion, other associated organisations (such as WFWP, UPF UK, WAIT UK etc.) or religious groups with which we are carrying out joint events or activities.
How long do we keep 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.
- 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.
- 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.
- 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)).
- 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.
- 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.
- 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 telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- 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 newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Policy, then we will provide you with a new policy 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.
The Data Controller
43 Lancaster Gate,
T: 020 7723 0721