Data Protection and Privacy Policy

Data Controller details

Data Controller: Reach Ministries UK

Charity number: 1209421

Church address: Office 232, 238 Merton High Street, London, SW19 1AU, UK

Data Protection Lead: Operations Manager

Email: reach@reachministries.uk

Phone: 03301332012

This policy first adopted / last reviewed: 1 September 2024

This policy due for review: 31 August 2025

This is the privacy statement and data protection policy for Reach Ministries UK. It covers how we will process (use and store) your data, what data we hold, your individual rights and how you can interact with us about your data.

This policy covers our use of personal data, which is any information about a living individual which allows them to be identified from that data (for example a name, photograph, video, email address, or postal address). Identification can be by the information alone or in conjunction with any other information.

Our processing of personal data is governed by the Data Protection Bill/Act 2017-2019 and the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998).

How is your data used and processed?

Reach Ministries UK processes data including:

• Names, titles, and aliases.
• Contact information including telephone numbers, postal/residential addresses, and email addresses.
• Where there is a legitimate interest to facilitate our charitable aims and activities, or where you have added them to our database or provided them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, and dependants.
• Where you give financially in support of Reach Ministries UK or pay for Reach Ministries UK services or events.
• Contact information and personal data regarding other leaders and members in your church – particularly those leading ministries – especially for the purpose of consultancy.
• As a religious organisation, the data we process is likely to constitute sensitive personal data because the very fact that we process your data at all may be suggestive of your religious beliefs.

As a Data Controller, our staff and volunteers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data. If you have any concerns about how your data is being used, please speak with our Data Protection Lead.

What are we doing with your data?

We only hold data that either we are legally obliged to or that helps us fulfil our charitable aims. We are seeking to serve churches in the UK and good communication with and understanding of these churches is essential to this service.

Therefore, we will hold and process data to:

• Receive and process enquires from potential clients for mentoring and consultancy.
• On-board clients for mentoring and consultancy.
• Register participants for events (including conference, clinics and training).
• Perform consultations based on analysis of church data.
• Communicate with our mailing list regarding relevant events and providing relevant short-form training input.
• Maintain our own accounts and records.
• Maintain our account, process payments, invoices and donations (including Gift Aid information).
• Enable us to meet all legal and statutory obligations.
• Comply with and facilitate safeguarding and complaints handling.

What is our legal basis for processing your personal data?

Our legal basis is as follows:

• Most of our data is processed because it is necessary for our legitimate interests to enable our charitable and missional aims.
• On some occasions the data subject may have explicitly consented to the processing – for example signing up to a mailing list.
• Some of our processing is necessary for compliance with a legal obligation. Gift aid declarations are examples of this.
• We may also process data if it is necessary for the performance of a contract with you, or to provide a direct service to you.
• As a religious organisation, we are permitted to process information about your religious beliefs where this is relevant to our activities and aims.

Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.

Will we share your data?

You can be reassured that we will treat your personal data as strictly confidential.

The main data documents are only accessible by the Director, Assistant Director and Operations Manager of Reach Ministries UK.

Data will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):

• Our technical agents, servants and contractors. For example, MailChimp the provider of our mailing list.
• The (non-staff) Reach Ministries consultant with whom you are engaging.

Our main data documents and email accounts are hosted by Google Workspace and our financial records are stored on Xero.

How long will we keep your personal data?

Our general rule is to keep data no longer than necessary. Where you continue to actively engage with our services, activities and events, we will retain the appropriate data for you so that we can best serve you. If at any time you ask to be removed from our records we will remove you from our mailing list and all our main record documents (on Google Workspace). In addition, all mailing provide the option to unsubscribe.

However:

• We will keep some records permanently if we are legally required to do so. For example, this covers some safeguarding records.
• We may keep some other records for an extended period. For example, it is current best practice to keep financial records for a minimum period of seven years to support HMRC audits.

What are your rights regarding your personal data?

You have the following rights with respect to your personal data: When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.

• The right to access information we hold on you. At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request, we will respond within one month. There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
• The right to correct and update the information we hold on you. If the data we hold about you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
• The right to have your information erased. If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted.
• The right to object to processing of your data. You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
• The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought. You can withdraw your consent easily by telephone, email, or by post.
• The right to lodge a complaint with the Information Commissioner’s Office. You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/ or at the Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF.

Transfer of data abroad

Any electronic personal data transferred to countries or territories outside the UK will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the UK. Our website is accessible from overseas, however it is our general practice not to publish any personal data on our website.

Further processing

If we wish to use your personal data for a new purpose not covered by this policy, then we will provide you with a new policy prior to commencing the processing to explain this new use and set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

You are very welcome to get in contact with us…

If you have any queries or concerns about how we use your data, please do get in contact with us.

Our Data Protection Lead and their contact details are given on the first page of this document.

Appendix 1: Definitions and appointed persons