Data Protection Policy.
Version 1.2 February 2023
The Church is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we may hold on you. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to current and former employees, workers and contractors and those who engage with the activities of the Larnaka Community Church, including members and attendees.
Data controller details
The Church is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:
Pastor David Bailey, info@lcc-cyprus.org Larnaka Community Church, 36 Riga Feraiou, Eva Maria Court 8, Apt 11, Larnaca, 6013.
Data protection principles
In relation to your personal data, we will:
– process it fairly, lawfully and in a clear, transparent way
– collect your data only for reasons that we find proper for the course of your
employment in ways that have been explained to you or whilst engaging with the
activities of the Larnaka Community Church.
– only use it in the way that we have told you about
– ensure it is correct and up to date
– keep your data for only as long as we need it
– process it in a way that ensures it will not be used for anything that you are not
aware of or have consented to (as appropriate), lost or destroyed
Types of data we process
We hold many types of data about you, which could include:
– your personal details including your name, address, date of birth, email address,
phone numbers
– your photograph
– gender
– marital status
– dependants, next of kin and their contact numbers
– medical or health information including whether or not you have a disability
– information used for equal opportunities monitoring about your sexual
orientation, religion or belief and ethnic origin
– information included on your CV including references, education history and
employment history (employees and former employees only)
– documentation relating to your right to work in Cyprus (employees and former
employees only)
– driving licence (employees, former employees or those authorised and insured
to drive Larnaka Community Church owned vehicles only)
– bank details
– tax codes (employees and former employees only)
– social Insurance number (employees and former employees only)
– current and previous job titles, job descriptions, pay grades, pension entitlement,
hours of work and other terms and conditions relating to your employment with
us (employees and former employees only)
– letters of concern, formal warnings and other documentation with regard to any
disciplinary proceedings (employees and former employees only)
– internal performance information including measurements against targets,
formal warnings and related documentation with regard to capability
procedures, appraisal forms (employees and former employees only)
– leave records including annual leave, family leave, sickness absence etc
(employees and former employees only)
– details of your criminal record (employees, former employees or those that fall
under our safeguarding policy only)
– training details
– Cyprus police records
– Passport & ID data, and travel insurance (Ministry trips only)
– Signing in register
– Pastoral and sensitive information
How we collect your data
We collect data about you in a variety of ways and this will usually start when we undertake a recruitment exercise or when you make contact with the Church through one of our activities/events, where we will collect the data from you directly, or via a contact card, or by a form submitted online.
a) For employees and past employees. This includes the information you would normally include in a CV or a recruitment cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
b) For those accessing the Church and its activities and events. We will collect and store your data through a number of databases and apps including our church database ‘Church Suite’ and ‘Planning Centre Online’ and information submitted through our website.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Employee and former employee’s personal data is kept in personnel files or within the Church’s HR and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
– in order to perform the employment contract that we are party to (employees
and former employees only)
– in order to carry out legally required duties
– in order for us to carry out our legitimate interests
– to protect your interests and
– where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. For example, for employees and former employees, we need to collect your personal data in order to:
– carry out the employment contract that we have entered into with you and
– ensure you are paid
We also need to collect your data to ensure we are complying with legal requirements such as:
– ensuring tax and National Insurance is paid
– carrying out checks in relation to your right to work in the Cyprus and
– making reasonable adjustments for disabled employees
We also collect data so that we can carry out activities which are in the legitimate interests of the Church. We have set these out below:
a) Employees and former employees
– making decisions about who to offer initial employment to, and subsequent
internal
– appointments, promotions etc making decisions about salary and other benefits
providing contractual benefits to you
– maintaining comprehensive up to date personnel records about you to ensure,
amongst other things, effective correspondence can be achieved and
appropriate contact points in the event of an emergency are maintained
– effectively monitoring both your conduct and your performance and to undertake
procedures with regard to both of these if the need arises offering a method of
recourse for you against decisions made about you via a grievance procedure
assessing training needs
– implementing an effective sickness absence management system including
monitoring the amount of leave and subsequent actions to be taken including the
making of reasonable adjustments
– gaining expert medical opinion when making decisions about your fitness for
work
– managing statutory leave and pay systems such as maternity leave and pay etc business planning and restructuring exercises
– dealing with legal claims made against us
– preventing fraud
– ensuring our administrative and IT systems are secure and robust against
unauthorised access
– inform the registrar of associations in Cyprus of LCC’s employees
b) For those accessing the Church and its activities and events
– To inform you of news, events, activities, groups and services running in Larnaka
Community Church
– To enable us to provide a voluntary service for the benefit of the public
– To provide pastoral care to our attendees and to safeguard the well-being of
individuals and 3rd parties
– To administer attendance/membership records
– To inform the registrar of associations in Cyprus of LCC’s members & meetings
– To provide an interactive website where email is used to communicate with
users;
– To raise funds and promote the interests of the church
– To manage our employees and volunteers
– To maintain our own accounts and records
– Statistical analysis
– To remain consistent with our values and beliefs as an organisation
Special categories of data
Special categories of data are data relating to your:
– health
– sex life
– sexual orientation
– race
– ethnic origin
– political opinion
– religion
– trade union membership
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
– you have given explicit consent to the processing
– we must process the data in order to carry out our legal obligations
– we must process data for reasons of substantial public interest
– you have already made the data public.
We will use your special category data:
– for the purposes of equal opportunities monitoring
– in our sickness absence management procedures
– to determine reasonable adjustments
– Provide suitable pastoral care if you wish to access it
– To enable us to provide a voluntary service for the benefit of the public
– To provide pastoral care to our attendees and to safeguard the well-being of
individuals and 3rd parties
– To remain consistent with our values and beliefs as an organisation
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role (paid or voluntary) and where the law permits us. This data will usually be collected at the recruitment stage or for those wanting to volunteer in activities concerning vulnerable adults or children (safeguarding policy), however, may also be collected during your employment. We use criminal conviction data in the following way:
– Through Cyprus Police
We process this data because of our legal obligation to safeguard children and vulnerable adults who attend our events or use our services.
If you do not provide your data to us (employees & former employees only)
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of employment. If you do not provide us with the data needed to do this, we will unable to perform those duties e.g. ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your employment with us in relation to our legal obligations if you do not provide us with this information e.g. confirming your right to work in the Cyprus or, where appropriate, confirming your legal status for carrying out your work via a criminal records check.
Sharing your data
Employees and former employees only:
Your data will be shared with colleagues within the Church where it is necessary for them to undertake their duties. This includes, for example, your line manager for their management of you, the HR department for maintaining personnel records and the payroll department for administering payment under your contract of employment.
We share your data with third parties in order to obtain references as part of the recruitment process.
We may also share your data with third parties as part of a Church sale or restructure, or for other reasons to comply with a legal obligation upon us.
Those engaging with the activities of the Church:
Your data will be shared with employees within the Church where it is necessary for them to undertake their duties in providing you information on the areas of the Church you are interested in and providing you with the services you have requested.
We do not sell or pass any of your personal information to any other organisations and/or individuals without your express consent, with the following exception – by providing us with your details you are giving the Church your express permission to transfer your data to our service providers including mailing houses, such as ChurchSuite and Planning Centre Online, and Cyprus association registrar to enable fulfilment of the purpose for collection.
Where such details are shared, we restrict the use of your information to the purpose for which it is provided and ensure it is stored securely and kept no longer than necessary.
We may provide third parties with general information about users of our site, but this information is both aggregate and anonymous. However, we may use IP address information to identify a user if we feel that there are or may be safety and/or security issues or to comply with legal requirements.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such as password protected computers.
Where we share your data with third parties, they must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended.
Retention periods can vary depending on why we need your data, as set out below:
– Employment and accounting records (including giving information)
6 complete financial years for Audit purposes.
– Those engaging with the activities of the Church
We will keep your personal information only for as long as we consider it necessary to carry out each activity unless required to keep for Cypriot law and will be deleted within 24 months of your last activity with us, unless you request to be forgotten or remove the information yourself. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned. Pastoral and sensitive personal information will only be kept whilst you are accessing our Pastoral Care from the Larnaka Community Church and will be deleted within 6 months of either your pastoral situation being resolved, or you no longer wish to access pastoral care from our organisation.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
– the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
– the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. Please do so by contacting Pastor David Bailey info@lcc-cyprus.org
– the right for any inaccuracies to be corrected. If any data that we hold about
you is incomplete or inaccurate, you are able to require us to correct it
– the right to have information deleted. If you would like us to stop processing your
data, you have the right to ask us to delete it from our systems where you
believe there is no reason for us to continue processing it
– the right to restrict the processing of the data. For example, if you believe the
data, we hold is incorrect, we will stop processing the data (whilst still holding it)
until we have ensured that the data is correct
– the right to portability. You may transfer the data that we hold on you for your
own purposes
– the right to object to the inclusion of any information. You have the right to object
to the way we use your data where we are using it for our legitimate interests
– the right to regulate any automated decision-making and profiling of personal
data. You have a right not to be subject to automated decision making in way
that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact
Pastor David Bailey info@lcc-cyprus.org
Making a complaint
The Commissioner for personal data protection is an independent public authority responsible for monitoring the implementation of Regulation (EU) 2016/679 (GDPR) and other laws aiming at the protection of individuals with regards to the processing of their personal data. (ICO).
If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Office address: Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O.Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456 Fax: +357 22304565
Email: commissionerdataprotection.gov.cy
Contact details of the Data Protection Officer (DPO) of the Commissioner’s Office
Email dpodataprotection.gov.cy