Our Data Privacy Notice
(updated 30 December 2020)
Personal Data Protection Policy
This Personal Data Protection Policy Statement sets out how the Chaplaincy of Midi-Pyrénées & Aude uses and protects any personal information that you have provided.
We would like you to read this Policy Statement carefully as it contains important information about how and why we collect, use and disclose your personal data. You have our assurance that it will only be used in accordance with this statement.
Your Personal Data
Your record includes the information you provided as a visitor to, member of or regular worshipper at one or more of the Chaplaincy Worship centres. Any information provided by you may be used to update your record. When providing your data to us, we rely on you to ensure that it is complete and accurate in order for the Chaplaincy to maintain data accuracy.
Your personal data collected is limited to administrative purposes and what is necessary to facilitate the carrying out of activities by the Chaplaincy. It will be kept confidential and will be used strictly for Chaplaincy and Diocese in Europe purposes only. We do NOT share your personal data with external parties.
We gather your contact details using a commercial e-mail service called MailChimp. This holds the details securely, and we use what you provide to stay in contact with you. Upon registration and regularly thereafter we will send you reminders about how you can delete your details as well as amend them. You can read Mailchimp's Privacy Policies by clicking here.
We will not disclose the contents of individuals' personal data which is held within Mailchimp to any person or organisation other than to members of the Chaplaincy Ministry Team to enable them to make contact in the event of an urgent pastoral need. We will not permit other mailing lists to be derived from the data that you have provided except with your prior permission. We may notify you if a new Chaplaincy mailing list becomes available to which we think you might wish to subscribe but we will not auto-subscribe you.
In September 2020, the Chaplaincy Council determined that, with immediate effect, all personal data held in the Chaplaincy's Electoral Roll shall be treated as Confidential unless an individual opts to permit their personal data to be made public. In future, any request to inspect the Electoral Roll of the Chaplaincy, in accordance with the Church Representation Rules, will, if determined by the Chaplaincy Council to be a valid request, only give access to the names of persons who have given their positive consent to have their details made available. If you have not given your positive consent to this, your details will not be disclosed.
Please note that the Diocese of Europe and the French Authorities with responsibility for the oversight of the Association Cultuelle under which our Chaplaincy operates in France have the right to inspect the full Electoral Roll.
The Chaplaincy has put in place a number of security measures and physical, technical and administrative procedures to minimize the risk of unauthorized access or disclosure and unlawful destruction, loss or alteration, and also to ensure the appropriate use of information.
Subject Access Requests
If you wish to view your personal data being held by the Chaplaincy, we would be grateful if you will complete the Subject Access Request form available online here. We reserve the right to ask you to verify your identity before supplying you with the information you have requested. We will make a disclosure of your data within one month or confirm that no data is held. We reserve the right to refuse your request or levy a charge for processing your request if the request is manifestly unfounded or excessive and particularly if it is repetitive. You must send your request to the Chaplaincy Data Protection Officer (known in France as the Correspondant Informatique et Libertés (CIL)). A form is available here.
If you have subscribed to our mailing lists, we may use your email address to forward information about events and activities within the Chaplaincy, including church notices, to you. You may select which church(es) you wish to be updated about. Persons sending out notices have no access to information about membership of the mailing lists unless this is specifically authorised by the Chaplaincy Council.
If you believe that your personal information in the Chaplaincy database is incorrect or incomplete, you may write to the Chaplaincy Data Protection Officer, Clive Billenness ( email@example.com ) stating your full name, contact information and the details of your requested correction/update.
We will update any information found to be incorrect within 30 days. We reserve the right to verify your identity before making any amendments.
To opt out of receiving further communications from the Chaplaincy, please email your request to the Chaplaincy at firstname.lastname@example.org. You may also edit/delete your own details on your Mailchimp account by clicking the link on any e-mail that you received from us. We will be informed of any amendments that you make.
Please note that if you chose to opt out, we might not be able to stay in touch with you. In your request, please state your full name, including your contact information. Your request will be processed as quickly as possible and always within 1 month. We reserve the right to verify your identity before processing your request.
Your Right To Be Forgotten
In some circumstances, where we do not have a legal obligation to retain information about you (e.g. baptism and marriage records which we are required by law to maintain and financial records of donations which may be subject to inspection by tax authorities), you have the right to have all information concerning you deleted from our records.
To exercise this right, as opposed to simply opting-out of receiving further information, please contact email@example.com
Please note that there are various categories of data which must be retained in compliance with French civil and Canon Law, as well as for other legal purposes, for different periods of time. Your right to be forgotten does not over-ride our obligations in respect of these. Exercise of your right to be forgotten always includes removal from the current Chaplaincy Electoral Roll and therefore the loss of all rights to vote on Chaplaincy matters at Annual Meetings and to hold any office within the Chaplaincy or our associated Association Cultuelle and Association Caritative. Please therefore reflect carefully before exercising this right and feel free to contact the Chaplain or Data Protection Officer before doing so.
Should you subsequently re-register on the Chaplaincy Electoral Roll, we will treat this as a formal withdrawal of your request to be forgotten and will resume processing of your personal data (although previous data may have been lost).
As with Opting Out of receiving further communication, in your request, please state your full name, including your contact information. Your request will be processed as quickly as possible and always within 1 month. We reserve the right to verify your identity before removing any personal data.
Data Protection Officer (DPO) known in France as the Correspondant Informatique et Libertés (CIL)
The Chaplaincy has appointed a suitably qualified Data Protection Officer (DPO) to ensure that we comply with the EU GDPR. This person is Clive Billenness.
If you have any concerns or queries on the Chaplaincies policies relating to the GDPR, please contact him by email at firstname.lastname@example.org
For general queries, you will get a reply as soon as possible and normally within one calendar month.
The Chaplaincy will regularly review and update our Personal Data Protection Policy. The latest version will be available on the Chaplaincy website for you to check and to keep up-to-date with the Policy.
Website Management Cookies
We use Google Analytics and internal tracking on our site, these details are not shared with third parties and are purely to monitor statistics about page views and to investigate any suspicious visitor activity; ip addresses are stored and user names are recorded if the visitor is logged in. All other visitors are anonymous. We only store part of the IP address of visitors for statistical purposes, it is not possible to backtrack individual users.
The Chaplaincy is supported by Facebook pages which are managed by teams of volunteers. The pages are run in accordance with Facebook’s Acceptable Usage policies and contain only personal data originally disclosed to Facebook by subscribers. Facebook provides facilities for reporting issues and also for editing or removing all information about a subscriber.
The Information Commissioner for France is the Commission Nationale de l’Informatique et de Libertés – CNIL: www.cnil.fr
International transfers (w.e.f 1 January 2021)
We are part of the Diocese in Europe, a diocese of the Church of England. We may share personal data with the diocesan offices and diocesan registry (legal office), which are located in London, United Kingdom. This will involve a transfer of personal data outside the European Economic Area (EEA). We may also transfer data to other countries outside of the EEA if our service providers from time to time are located in those countries.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We may transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
· If we transfer data to a country which has not received an adequacy decision at the date of transfer, we may use specific contracts approved by the European Commission which give personal data the same protection as it has in the European Union.