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The Electoral Roll and GDPR 

Guidance to Parishes- issued by the Ely Diocesan Office 15th February 2019
 
Purposes of data processing
The lawful bases for processing the personal data contained in the church electoral roll come from the purposes for that processing, i.e. what we do with the personal data and why we are asking for it.   In very broad terms, the key purposes are:

  1. To determine eligibility for attendance at the Annual Parochial Church Council Meeting, for various elections and for other church related matters, and;
  2. To create the electoral roll and administer the elections; and 
  3. To publish the electoral roll.

All of the relevant purposes are set out in the CRR and PCCs must comply with these statutory requirements.   Anyone who then applies to be put on the electoral roll should be made aware of all relevant requirements.   This should be done by providing them with a privacy notice, (see paragraph headed “Privacy Notice” below). 

No Consent
There is no need to amend the relevant forms under the CRR, and the forms will not be changed to include consent.  Consent is not necessary for the processing of personal data in relation to the church electoral roll, and the PCC will not be seeking consent in this respect because other lawful bases apply.

Lawful basis (Article 6)
The lawful basis for processing church electoral roll data can be found in Article 6(1)(c) – i.e. “processing is necessary for compliance with a legal obligation to which the controller is subject”.  In other words, processing of personal data on the church electoral roll is required by law because the CRR (or other legislation) are statutory and impose legal obligations.
This also means that unless individuals provide the relevant data required by the form, they can’t participate in the processes/functions governed by the church electoral roll.

The CRR form and special category data (Article 9)
The personal data on the church electoral roll reveals a person’s religious belief and is therefore considered to be “special category” personal data, (i.e. sensitive).  This means we also have to satisfy one of the conditions of processing set out in Article 9 GDPR, (as well as the Article 6 condition outlined above).   
We can rely on Article 9(2)(d) GDPR, because the processing is a legitimate activity of a not-for-profit religious body, i.e. the Church of England, and only relates to members or former members.

Publication of the electoral roll
Under the CRR it is also a requirement to publish the roll for certain purposes. This is separate from the other two purposes, and so a different lawful basis is required for this processing.
As we have stated, the fact that an individual appears on the electoral roll means that these individuals are members of the Church of England, i.e. it reveals their religious belief. This means we have to have one lawful basis from Article 6 and one from Article 9.
The Article 6 lawful basis is that same as before – i.e. it is a legal obligation/requirement.
The Article 9 basis in relation to the publication of the roll is that the “processing relates to personal data which are manifestly made public by the data subject”, (Article 9(2)(e)).   
Article 9(2)(e) is the lawful basis because where an individual applies to have his or her name enrolled on a church electoral roll, the automatic legal consequence of that is that certain data about that individual will be published.  The individual is, therefore, by submitting his/her application form, manifestly making that data public; i.e. if a person takes an action, the consequence of which is that information relating to that action will become public, that person is deliberately making that information public.
 The CRRs are clear.  The roll will be published (see Part I Formation of Roll 1(8); Revision of Roll and Preparation of New Roll 2(1), 2(3) and 2(7)), and individuals should be aware of this.  It may be necessary to draw their attention to the relevant paragraphs.
However, if an individual doesn’t want his/her address details to be made public, there are only two options:

  1. He/she can choose not to apply to be on the church electoral roll; or
  2. He/she can ask for his/her address details to be excluded due to specific and/or exceptional circumstances which might mean that the person might be at risk of harm if his/her address details were published.  In such a case, the individual concerned should discuss his/her situation with the electoral officer or the diocesan office and it may be necessary to publish only his/her name.  This is allowed for in the CRR Part I, 1(11) which states: - “…The roll shall where practicable contain a record of the address of every person whose name is entered on the roll, but failure to comply with this requirement shall not prejudice the validity of any entry on the roll...”


Privacy Notice
A Privacy notice explaining these issues for those individuals applying to the electoral roll is available here.

Contact
If you need any further guidance, or have queries or concerns, please contact the data controllers who are the incumbent Revd Paul Seaton-Burn, the PCC or the Information Commissioners Office.

Hello
Hello and welcome to our church. If you are a new visitor, we have a page for you to get to know us and learn more about planning a visit.
Click here to see more.

Planning your Visit

Welcome to St Mary's, Linton


Where and When

Our main service is 10am every Sunday, after an early said Holy Communion in traditional language at 8am, but there are a number of other ways we meet, both in church (details here) and in homes and other venues across our community. There is some parking on Church Lane, or on the High St, or Medical Centre car park, just a few minutes walk away. If you're new or visiting us, do say hello to one of our welcomers on the door.

The 10am is usually an hour long, sometimes less, and we serve tea, coffee and biscuits after the 10am service, apart from Cafe Church - every fourth Sunday morning - where coffee, etc is served before we begin. All refreshments are free, but donations to keeping our ancient church open for everyone are always appreciated. Thanks.

Other types of worship offer contemplative space (The Well, every second Sunday evening at 6pm), Taize worship, as well as prayer for healing (Services of Hope and Healing) where blessing with anointing is available. Evensong (BCP) takes place in Bartlow, 5 minutes drive from Linton, every third Sunday at 6pm. We are very active in our community and host school worship - our Infant School meet here every Friday in term time - and a range of special events (such as a recent Vigil for Ukraine).

St M's is open every day of the year (c9.30am-4pm), for locals and visitors alike. Many people drop by to light a candle, or to find some quiet, or to read or draw with their child or grandchild. Dogs are most welcome, too.

Celebrating life events

If you're visiting our website because you would like to arrange a wedding, funeral or Christening, do contact us. We'd love to help you mark these precious times in your life and the lives of your loved ones. It doesn't matter if you are not a churchgoer - all are welcome here.

Accessibility: There is wheelchair access, and a sound loop for anyone who needs it. Please let one of the Welcome Team know on your arrival and they will help you to get set up. There is a loo in the Pavilion (which has wheelchair access) at the back of the church.

Young people

We really value worshipping God all together as a family. There is an area in the south aisle dedicated to children and their carers, which allows them to take part in the service, while also having books, drawing materials, toys and other resources to hand. We really don't mind if your child makes a noise - they are as welcome as anyone else!

There are other activities, like Messy Church and Tots in Tow, that nurture young people's faith in positive and caring ways. More info can be found on this site.

Children


Root & Branch (RnB) Groups

Being part of one of our small groups is a great way to make new friends, share questions of life and faith and explore the Bible. No previous experience necessary. Four groups meet across the Linton Parishes; three in homes across Linton. Usually, we meet fortnightly, in 'terms' of around four or five dates. Check out our Small Groups and see if there’s a time that works for you, and let us know if you'd like to come along.

Get in touch with us to plan your visit
If you would like to come and visit the church beforehand you are more than welcome! Get in touch and we can arrange a time that suits you.
 
Name:
Telephone:
Email Address:
Comments / Questions or anything you would like to say?

Next, we will contact you by email to say hello and help arrange anything necessary for your visit.
 

PSB website 

 
Peace and blessings,

Revd Paul