22 May 2018

Personal Data Privacy Statement/Notice

What is the purpose of this Statement?

Personal Data is data which by itself or with other data can be used to identify you as an individual. It
does not include data where the identity has been removed (anonymous data). There are "special
categories" of more sensitive personal data which require a higher level of protection.

This statement sets out how we, the North England Conference of Seventh-day Adventists ("NEC"), as a
data controller will use your personal data.

NEC is a "data controller". This means that we are responsible for deciding how we hold and use
personal information about you. We are required under the General Data Protection Regulation to
notify you of the information contained in this privacy statement. This statement does not form part of
any contract to provide service and it may be updated at any time.


It is important that you read this statement, together with any other privacy statement we may provide
on specific occasions when we are collecting or processing personal information about you, so that you
are aware of how and why we are using such information.

You can contact the Data Protection Officer ("DPO") for NEC at 22 Zulla Road, Nottingham, NG3 5DB or
you can email at gdpr@necadventist.org.uk

DATA PROTECTION PRINCIPLES

We will comply with Data Protection Law. This says that the personal information we hold about you
must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is
incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

DATA WE COLLECT ABOUT YOU

Who do we collect information about?

We have to process personal data in order to promote our organisation which includes Seventh-day
Adventist Churches across the NEC. We also process data for the provision of services and to maintain
our accounts and records. If you are, or if you are potentially, a member, visiting friend,
parent/guardian of a child that is below the age of thirteen years old, supplier or service provider,
advisor, consultant or professional advisor or any other stakeholder then we will process your personal
data, to the extent necessary.


What types of Personal Data do we collect and use?

We may collect, store and use some or all of the following categories of personal information about you:


• Personal contact details, such as: title, name, addresses, telephone numbers and personal email addresses.

• Financial data: such as, details of bank accounts.

• Family, lifestyle or social circumstances, if relevant, to the product or service we supply to you.

• Record of products or services obtained or applied for

• Payment and compensation history.


We also collect, use and share aggregated data such as statistical or demographical data for any
purpose. Aggregated data may be derived from your personal data but is not considered personal data
in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate
your usage data to calculate the percentage of users accessing a specific website feature. However, if
we combine or connect aggregated data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also collect, store and use the following "special categories" of more sensitive personal information:

• Information about your health, including any medical condition, disabilities or vulnerabilities.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or
are trying to enter into with you (for example, to provide you with services). In this case, we may have to
cancel a service you have with us but we will notify you if this is the case at the time.

How do we collect Personal Data?

We collect personal data that you correspond directly to us in relation to our organisation or services.
We will also collect personal data about you from third parties who are essential to the goods or
services we provide, for example British Union Conference. In addition, we may collect personal data
from other publicly available sources.
How will we use your personal data?
We will only use your personal information when the law allows us to. Most commonly, we will use
your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal or regulatory obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.


We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

We need all the categories of data listed above to fulfil our requirements. In some cases, we will use
your personal information to pursue legitimate interests of our own or those of third parties, provided
your interests and fundamental rights do not override those interests.

We have set out below in a table format, a description of the main ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

Purpose / Activity Type of Data Lawful basis for processing including
basis of legitimate interest
To register you as a new
customer, member and,
visiting friend

• Identity
• Contact

Performance of a contract with you
e.g. Tithes, Camp meeting, trips
overseas
To process and deliver
your order including:

• Manage payments,
fees and charges
• Collect and
recover money
owed to us
• Identity
• Contact
• Financial
• Communications
• Performance of a contract with
you
• Necessary for our legitimate
interests (to recover
outstanding monies due to us)
To manage our
relationship with you
which will include:
• Notify you about
changes to our
terms or privacy
policy
• Asking you to
leave a review or
take a survey
• Identity
• Contact
• Communications
• Performance of a contract with
you
• Necessary to comply with a
legal obligation
• Necessary for our legitimate
interest (to keep our records
updated and to analyse data on
the customers that use our
services, to develop and grow
our organisation/services
To enable you to partake
in a survey
• Identity
• Contact
• Usage
• Communications
• Performance of a contract with
you
• Necessary for our legitimate
interest (to keep our records
updated and to analyse data on
the customers that use our
services, to develop and grow
our organisation/services
To administer and
protect our organisation
and this website
including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting or hosting data
• Identity
• Contact
• Technical
• Necessary for our legitimate
interest (for running our
business, provision of
administration and IT services,
network security, to prevent
fraud and in the context of a
business reorganisation)
• Necessary to comply with a
legal obligation


When will we use your personal data for another purpose?

We will only use your personal information for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If we need to use your personal information for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.


How will we monitor communications?

Subject to applicable laws, we may monitor and record: calls, emails, text messages, social media
messages and other communications in relation to our dealings with you. We will do this for regulatory
compliance, self-regulatory practices, crime prevention and detection. Also to protect the security of
your communications systems, for quality control, staff training and when you need to see a record of
what's been said. All monitoring will be justified by our legitimate interests or our legal obligations.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other
entities in our Seventh-day Adventist group such as the British Union Conference, Trans European
Division, General Conference, Adventist Risk Management (ARM) and Stanborough Press. This includes
also the local church, which you attend.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. Where we do this, this will only be carried
out with compliance of the EU Model Contract Clauses, which have been approved by the UK Data
Protection Authority the Information Commissioner's Office ("ICO").

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary
to administer the working relationship with you or where we have another legitimate interest in doing so.

What third parties do we share information with?

For the reasons provided above we may share your data with the British Union Conference, Trans
European Division, General Conference, Adventist Risk Management (ARM), Stanborough Press, ADRA
UK, Citation, Anthony Collins, Chubb, PayPal, World Pay, Diversity Travel, Atlantic Data, Microsoft and
any other Direct Service Provider contracted to carry our work on behalf of the NEC.
How do we protect the security of your information when we share it with third-parties?
All our third-party service providers are required to take appropriate security measures to protect your
personal information in line with our policies. We do not allow our third-party service providers to use
your personal data for their own purposes. We only permit them to process your personal data for
specified purposes and in accordance with our instructions.


DATA SECURITY

What measures have we put in place to secure your personal data?

We have put in place appropriate security measures to prevent your personal information from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and
any applicable regulator of a suspected breach where we are legally required to do so.


DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To
determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data. In addition to this we consider the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means, and the applicable legal
requirements.

In some circumstances we may anonymise your personal information so that it can no longer be
associated with you, in which case we may use such information without further notice to you. All
personal data will be kept in line with our Data Retention and Disposal Policy.


RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

What is your duty? Do you have to inform us of changes?

It is important that the personal information we hold about you is accurate and current. Please keep us
informed if your personal information changes during your relationship with us.

What are your rights in connection with personal information?

Under certain circumstances, by law you have the right to:


• Request access to your personal information (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal information we hold about you and to
check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have
any incomplete or inaccurate information we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.

• Request erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also have the
right to ask us to delete or remove your personal information where you have exercised your right to
object to processing (see below), where we may have processed your information unlawfully or where
we are required to erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request for erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.

• Object to processing of your personal information where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation, which makes you want
to object to processing on this ground. You also have the right to object where we are processing your
personal information for direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which overrides your rights and freedoms.

• Request the restriction of processing of your personal information. This enables you to ask us to
suspend the processing of personal information about in the following circumstances: (a) if you want us
to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to
erase it; (c) where you need us to hold the data even if we no longer required it as you need it to
establish, or exercise or defend legal claims; or (d) you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal information to another party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note this right only applies to automated information, which you initially provided consent for
us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data.
However this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw consent, we may not be able to provide certain services to you. We will advise
you if this is the case at the time you withdraw consent.

If you want to review, verify, correct or request erasure of your personal information, object to the
processing of your personal data, withdraw consent to processing or request that we transfer a copy of
your personal information to another party, please contact the DPO in writing.

Will we charge you for this?

You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Is there anything that the NEC may need from you?

We may need to request specific information from you to help us confirm your identity and ensure your
rights as listed above, for example, the right for you to access the information we hold about you. This is
another appropriate security measure to ensure that personal information is not disclosed to any
person who has no right to receive it.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.


CONTENT & CHANGES TO THIS PRIVACY NOTICE

This website may include links to third party websites, plug-ins and applications. Clicking on those links
or enabling that content may allow third parties to collect or share data about you. We do not control
these third-party's websites and are not responsible for their privacy statements. When you leave our
website, we encourage you to read the privacy policy of every website you visit.

The NEC reserves the right to amend this Privacy Notice at any time and without prior notice.