This policy is effective from 25 May 2018
Welcome to the Archbishop of York's official website. The Archbishop of York takes your privacy seriously and is committed to protecting your personal data.
Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
We are registered with the Information Commissioner, registration number Z4888418.
- Contact us form on this website.
- Postal address: Bishopthorpe Palace, Bishopthorpe, York, YO23 2GE.
If you have any complaints or queries about matters affecting your privacy, or any other general data protection matters, then please do let us know by contacting us as set out above and we will endeavour to resolve the problem. In any event you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. The ICO can be contacted on their helpline number which is 0303 123 1113 between 9am and 5pm Monday to Friday, or by other contact methods as set out on their website. Please go to their website at www.ico.org.uk for more information.
Changes to this policy and your obligation to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please do let us know if your personal data changes.
This version was last updated on 25 May 2018, historic versions can be obtained by contacting us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Please do ensure you are familiar with any privacy notice or policy of any website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Communications Data includes your preferences in receiving information from us and your communication preferences.
Generally we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, on occasions, for example through a direct interaction we may receive Special Categories of Personal Data such as:-
· Race or ethnic origin;
· Religious or philosophical beliefs;
· Sex life or sexual orientation;
Processing these types of Special Categories of Personal Data is permitted under data protection law where data subjects have given explicit consent and, or, where it is carried out by a religious entity in the course of its legitimate activity.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This may include personal data you provide when you:
- create an account on our website;
- subscribe to one of our publications;
- request information to be sent to you;
- enter a competition; or
- replying to a survey; or
- give us some feedback.
- Third parties sources. We may receive personal data about you from other bodies within the Church of England, including the Archbishops of Canterbury (in his corporate capacity), The Church Commissioners for England, The Church of England Pensions Board, Lambeth Palace Library, The National Society (Church of England and Church of Wales) for Promoting Education and the Church of England Central Services (collectively referred to as the “National Church Institutions” or “NCIs”).
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you consent to us using your personal data, for example when you correspond with us or request a newsletter (your consent can be withdrawn by you at any time as set out in this policy).
- 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.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you to receive our latest news or where you ask questions through our contact us form.
(a) Your consent.
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) General Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how our users utilise our products/services)
To enable you to partake in a competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how users utilise our products/services, to develop them and grow the Church)
To administer and protect us and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running the Church, provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, and experiences
Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant, to develop the Church)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow the Church)
To manage questions you may have, or issues relating to certain Special Categories of Data, such as race or ethnic origin; religious or philosophical beliefs; sex life or sexual orientation; or health.
(a) Your consent.
(a) Necessary for our legitimate interests (as a religious body these may be issues you ask us about)
We do not share your personal data with any External Third Parties. Where we need to share your personal data we will obtain your express opt-in consent before we share it.
You can ask us or third parties to stop sending you messages at any time by contacting us or where provided by logging into the website and checking or unchecking relevant boxes to adjust your preferences, or by following the opt-out links on any communication or marketing message sent to you.
Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of litigation or complaints and only as long as the information is required.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
- Cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you, where provided, to log onto the secure area of our websites.
- Analytical/performance cookies. These allow us to recognise and count the number of users and to see how the users move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name Domain Description of purpose
Google Analytics Google.com Analytics
Crazy Egg CrazyEgg.com Heatmapping analytics
Facebook Pixel Facebook.com Use of the Facebook Pixel tool
Session Cookie churchofengland.org Improve site user experience
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA) save that we occasionally use certain third party communications and marketing platforms such as MailChimp. MailChimp’s servers are based in the USA. MailChimp is certified under the EU-US Privacy Shield program and we will ensure that any other transfers meet all legal requirements.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data 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, 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data 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 data. This enables you to ask us to delete or remove personal data 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 data where you have successfully 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 of 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 data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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 require it as you need it to establish, 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 data to you or to a third 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 that 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 your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties – Other Church of England bodies
Other bodies within the Church of England include us and the Archbishop of Canterbury in his corporate capacity, The Archbishops’ Council, The Church Commissioners For England, The Church of England Pensions Board, Lambeth Palace Library, The National Society (Church of England and Church of Wales) for Promoting Education and the Church of England Central Services and who are based in the UK (collectively referred to as the “National Church Institutions” or “NCIs”).
External Third Parties
- Professional advisers including where necessary lawyers, and insurers based in the UK who provide legal and insurance services.
- MailChimp whose servers are based in the USA and provide a platform for electronic communications. MailChimp are certified under the EU-US Privacy Shield program.
Last modified by office of Archbishop of York on 25/05/18