COVID-19 UPDATE, OCTOBER 2020
This update provides information on how we will collect and store personal data specifically in support of the NHS Scotland Test and Protect Service. It does not alter, override or remove any element of the AUC Data Privacy Statement found below the update.
Collection of Personal Data for NHS Scotland Test and Protect Service– Privacy Notice
For the health and safety of all our building users and staff, we are recording the name and contact details of everyone who enters to support NHS Scotland’s efforts in tackling COVID-19. This information will be used to enable NHS Scotland and statutory partners to contact you should you have been in the premises around the same time as someone who has tested positive for coronavirus. Contacting people who might have been exposed to the virus is an important step in stopping the spread.
This update to our privacy notice is intended to be read alongside our standard privacy notice and does not replace it. It is designed to give you specific information about the handling of your data with regard to the NHS Scotland’s Test and Protect Service.
1. Why do we need to collect this data?
As stated above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s efforts in tackling the coronavirus public health epidemic. This will involve the gathering and, when necessary, the sharing of information with NHS Scotland and statutory partners. Your data will not be used for any other purpose.
In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland and statutory partners.
2. What data will we collect?
Along with the date and time of your arrival and departure, we will collect the following personal data if applicable:
- your name; and
- contact telephone number.
If you do not have a telephone number, you have the option to provide:
- a postal address; or
- an email address.
3. What is our lawful basis for collecting this data?
Under data protection law, GDPR Article 6(1), we have a number of lawful bases that allow us to collect and process personal information. In this case, the lawful basis for processing your data is ‘legitimate interests’.
Broadly speaking ‘legitimate interests’ means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.
Our legitimate reason for processing your data is to assist with NHS Scotland’s Test and Protect strategy in relation to the coronavirus public health epidemic.
Before sharing any information we will carefully consider and balance any potential impact on you and your rights.
4. How long will we retain the data?
Your personal data will be retained only for the purposes stated in this privacy notice and will be held by us for no more than 3 weeks (21 days).
All personal data will be held and disposed of in a safe and secure manner.
5. Your rights
Your rights as defined in the data protection law, GDPR Article(s) 12-23, are unchanged from those in our main data privacy statement below.
Date: 22nd October 2020
AUC DATA PRIVACY STATEMENT
1. Personal data
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the ‘GDPR’).
2. Data Controller
The Church Council of Augustine United Church is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
3. How do we process your personal data?
The Church Council of Augustine United Church 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.
We use personal data for the following purposes: –
- to administer membership records;
- to maintain our financial accounts and records (including the processing of gift aid);
- to provide news and information about events, activities and services at the church;
- to fundraise and promote the interests of the church;
- to manage employees and volunteers;
- to enable the church to provide voluntary services for the benefit of the public in our local community;
- to provide contact details of officers and others with specific responsibilities to the Synod office and Church House. This enables the Synod and national administration of the United Reformed Church.
4. What is the legal basis for processing your personal data?
- Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided: –
- the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
- there is no disclosure to a third party without consent; or
- Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement; or
- Explicit consent of the data subject has been given.
5. Sharing 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 with your consent.
6. How long do we keep data?
We retain data on the following basis:
|Record Type||Retention Period|
|Minute Books and meeting records||Indefinitely|
|Members, adherents and friends contact details||24 months after the last contact|
|Emails and other social media||24 months unless required to resolve ongoing issues|
|Junior Church contact and
Parental Consent forms
|24 months after the last contact|
|Records of attendance of children/young people and helpers||Indefinitely for safeguarding purposes|
|Photographs and videos of events||Selected items retained for historical record with specific permission|
|Safeguarding matters||Indefinitely or until advised otherwise by authorities|
|PVG Forms||Indefinitely or until advised otherwise by authorities|
|Data protection records and consent forms||Indefinitely|
|Complaints (non -safeguarding)||3 years after resolution of complaint (unless further action is anticipated)|
|Personal data relating to events for which additional information is gathered e.g. Church holidays||Disposed of immediately after the event unless anything has occurred (e.g. an accident) which indicates that records should be retained for a longer period.|
|Gift aid declarations and paperwork||6 years after the last calendar year to which it relates|
|Legal and constitutional||Indefinitely|
|Documentation relating to the building||Indefinitely|
|Documentation relating to room letting||6 years|
|Financial and accounting records||6 years|
|Employee Records||6 years after the date of termination of employment|
|Accident Books||3 years from the date of last entry (or, if the accident involves a child/young adult, then until the person reaches 21)|
7. Your rights and your personal data Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of the personal data which Augustine United Church holds about you (a Subject Access Request or ‘SAR’);
- The right to request that the Church Council of Augustine United Church corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for Augustine United Church to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller.
- 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;
- The right to object to the processing of personal data;
- The right to lodge a complaint with the Information Commissioners Office.
8. Further processing
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.
9. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the Church Secretary at Augustine United Church, 41-43 George IV Bridge, Edinburgh EH1 1EL.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
The Church Council
Augustine United Church
Date : 22 May 2018