ICIMA Generations
privary policy
ICIMA Generations PRIVACY POLICY
Section A: Terminology
Data Subject
The living person to whom the personal data refers or belongs to.
Data Controller
The Data Controller is ICIMA. This includes all Administrative volunteers of ICIMA Generations.
Data Processor
The Data Processor is any person (other than the data controller) that processes the data on behalf of ICIMA Generations. This includes our Church Membership, Core Leaders, Team Leaders and the Volunteers Team. Additional data processors may also include our Accountants, Finance.
Personal Data
Personal Data is any information relating to a living person who can be identified by the data directly or indirectly. It can be held in a computerised or paper filing system. All personal data is kept in compliance with General Data Protection Regulations (GDPR) details of which can be found below.
Section B: Your Rights
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Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
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The right to request a copy of your personal data which ICIMA Generations holds about you[1];
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The right to request that ICIMA Generations corrects any personal data if it is found to be inaccurate or out of date[2];
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The right to request your personal data is erased where it is no longer necessary for ICIMA Generations to retain such data[3]. Details of this can be found in Section E;
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The right to withdraw your consent to the processing at any time;
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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)[4];
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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;
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The right to object to the processing of personal data (where applicable);
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The right to lodge a complaint with the Information Commissioners Office.
Section C: How we process your data
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ICIMA Generations 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.
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We use your personal data for the following purposes:
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To enable us to provide a voluntary service for the benefit of the public in particular church activities, events, ministries and projects;
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To administer membership records;
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To fundraise and promote the interests of the church;
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To manage our volunteers;
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To maintain our own accounts and records (including the processing of donations);
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To inform you of news, events, activities and changes to the regular programming at ICIMA Generations.
Section D: The legal basis for processing your personal data
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Explicit consent of the data subject so that we can keep you informed about news, events, activities and services; to process your donations and keep you informed about ICIMA Generations events.
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Processing is necessary for carrying out obligations under Safeguarding, Health and Safety, Social Security or Social Protection Law, or a collective agreement[5];
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Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided: –
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The processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
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There is no disclosure to a third party without consent.
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Section E: Sharing and storing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the church in order to carry out a service to other church members or for purposes connected with the church. We will only share your data with third parties outside of the church with your consent (for example, event tickets, offsite activities).
We keep data in accordance with the guidance set out by ICIMA Generations. Further information of this can be found on the ICIMA Generations website.[6]
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Specifically, we retain data for the following periods;
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Membership Data,[7] pastoral and spiritual counselling while it is still current and for one calendar year on leaving ICIMA Generations for our Annual Church Report;
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Gift Aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate;
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Registers (baptisms, marriages, funerals) permanently[8]
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Employment records[9] and volunteer records are kept for the legal requirement of 6 years.
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Safeguarding records are kept in line with current Safeguarding laws.
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Health and Safety records are kept for 40 years as required by law.
Section F: Further Processing
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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.
Section G: Data Breaches
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ICIMA Generations has procedures in place to prevent data breaches. This includes procedures to detect, report and investigate breaches. The following good practice exist to prevent data breaches where possible;
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Only data controllers and data processors have access to personal data;
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A “clear desk/office policy” must be kept where no personal information must be visible;
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Data kept must be in a secure and lockable cupboard/drawer. Those with access must be named on the Data Audit;
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Electronic data must be password/passcode protected or encrypted;
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All computers must have malware/firewalls installed;
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If data is kept on a person, it must be secure.
Where a significant data breach occurs, we are required to report this to the ICO with undue delay and within no longer than 72 hours of the discovery of the breach. Data breaches will also be reported to the ICIMA Generations Data Protection Officer.
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Section H: Contact Details
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To exercise all relevant rights, queries or complaints please in the first instance contact the Church Office. You can also contact the Information Data Protection Officer.
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ICIMA Generations
47 Bowie Close
Clapham Park
London, SW4 8HB
Telephone: 020 3950 3833 / 020 867 42636
Email: info@icimagenerations.com
[1] A Subject Access Request (SAR) must be issued by ICIMA Generations to the data subject, at no cost, within 30 days. (This may be extended by a further two months in certain cases)
[2] This can be done by request via the Church Office or by the data subject via Church Suite.
[3] This is unless further legal implications are in place.
[4] This can be done by request via the Church Office.
[5] You will be notified in this instance if we are bound by law to keep personal data
[7] This includes data consent forms and “Connect” cards
[8] In compliance with current legal obligations.
[9] CVs and interview questions are only kept for 6 months unless required by Safeguarding laws for longer periods. Minimum Wage records are kept for 3 years after the end of employment
