Data Protection Policy

Purpose

Harrow International Christian Centre needs to gather and use certain information about individuals.

These can include church members, employees, attendees, suppliers and business contacts.

This policy describes how this personal data must be collected, handled and stored to meet the church's data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Harrow International Christian Centre:

• Complies with data protection law and follows good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals' data
• Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 2018 describes how organisations — including Harrow International Christian Centre — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act 2018 is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Be processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

• The head office of Harrow International Christian Centre
• All branches of Harrow International Christian Centre
• All staff and volunteers of Harrow International Christian Centre
• All contractors, suppliers and other people working on behalf of Harrow International Christian Centre

It applies to all data that the church holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Plus any other information relating to individuals

Data protection risks

This policy helps to protect Harrow International Christian Centre from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately
• Failing to offer choice. For instance, all individuals should be free to choose how the church uses data relating to them
• Reputational damage. For instance, the church could suffer if hackers successfully gained access to sensitive data

Responsibilities

Everyone who works for or with Harrow International Christian Centre has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The church administrator is responsible for overseeing all issues relating to the processing of data and for giving advice on data protection legislation
• The church leadership is responsible for handling data protection queries and formally processing data access requests from individuals in writing

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers
• Harrow International Christian Centre will provide training to all employees to help them understand their responsibilities when handling data
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below
• In particular, strong passwords must be used and they should never be shared
• Personal data should not be disclosed to unauthorised people, either within the church or externally
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the church administrator or church leadership.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer
• Data printouts should be shredded and disposed of securely when no longer required

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service
• Servers containing personal data should be sited in a secure location, away from general office space
• Data should be backed up frequently. Those backups should be tested regularly, in line with the church's standard backup procedures
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones
• All servers and computers containing data should be protected by approved security software and a firewall

Data use

Personal data is of no value to Harrow International Christian Centre unless the church can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure
• Data must be encrypted before being transferred electronically. The church administrator can explain how to send data to authorised external contacts
• Personal data should never be transferred outside of the European Economic Area
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data

Data accuracy

The law requires Harrow International Christian Centre to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Harrow International Christian Centre should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer's details when they call
• Harrow International Christian Centre will make it easy for data subjects to update the information Harrow International Christian Centre holds about them. For instance, via the church office
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database
• It is the church administrator's responsibility to ensure marketing databases are checked against industry suppression files every six months

Subject access requests

All individuals who are the subject of personal data held by Harrow International Christian Centre are entitled to:

• Ask what information the church holds about them and why
• Ask how to gain access to it
• Be informed how to keep it up to date
• Be informed how the church is meeting its data protection obligations

If an individual contacts the church requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email or writing to the church administrator. The church administrator can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The church administrator will aim to provide the relevant data within 14 days.

The church administrator will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Harrow International Christian Centre will disclose requested data. However, the church administrator will ensure the request is legitimate, seeking assistance from the church leadership and from the church's legal advisers where necessary.

Providing information

Harrow International Christian Centre aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the church has a privacy statement, setting out how data relating to individuals is used by the church.

Processing sensitive personal data

Sometimes it is necessary to process sensitive personal information. Harrow International Christian Centre will only process sensitive data if:

• The individual has given explicit consent
• It is required by law
• It is necessary to protect the vital interests of the individual (e.g., if they are seriously hurt and unable to give consent)
• The individual has already made the information public

Before processing sensitive data, staff should always check with the church administrator to ensure the data is being processed appropriately.