Privacy Policy

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 as 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 billing address, delivery address, email address and telephone numbers.

· Financial Data includes bank account and payment card details.

· Transaction Data includes details about payments to and from you and other details of events, products or services you have purchased from us or gifts you have donated to us.

· 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data includes information about how you use our website, events, products and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic 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.

As a faith-based charity providing Christian teaching and training, the information we collect may be considered to come within the definition of Special Categories of Personal Data. Special Categories or Personal Data 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. We will always make it clear to you when we collect this

information and why. For some of our events and services we may also collect information about criminal convictions and offences.

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. In this case, we may have to prevent your attendance at a course, or cancel your tickets to an event or service you have with us but we will notify you if this is the case at the time.

We collect and use information about our students, suppliers, contractors, the Church of England’s national and diocesan staff, and personnel working for relevant public bodies. This information is used to manage and administer the charity and to carry out our charitable purposes. 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 we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of SMC or HTBG) and your interests and fundamental rights do not override those interests.

Generally we do not rely on consent as a legal basis for processing your personal data other than when we collect Special categories of Data or in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on an unsubscribe link in one of our emails to you or by emailing GDPR@sptc.org.

Purposes for which we will use your personal data

We have set out below a description of the ways we plan to use your personal data. SPTC collects and processes information so that we can:

· Manage, administer and promote SPTC and SMC

· Administer financial transactions and donations

· Administer our courses and events

· Manage our websites and social media accounts

· Manage our volunteers and HR function

· Prevent and detect crime

· Comply with a legal or regulatory obligation

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 email GDPR@sptc.org if you need details about the specific legal ground we are relying on to process your personal data.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us, attended an event or course with us and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside the HTB group of companies or SMCT for marketing purposes. You can ask us or third parties to stop sending you marketing messages by emailing GDPR@sptc.org at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a course or event registration or other financial transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. You can read more about how we use cookies by reading our Cookies Policy.

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 email GDPR@sptc.org.

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.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

· Where we use certain service providers, we may use specific contracts approved for use in the UK which gives personal data the same protection it has in the UK.

· Where we use providers based in the US, we check if the provider can host the data within the UK. If this is not possible, we ensure Standard Contractual Clauses are in place before transferring any data. Please email GDPR@sptc.org if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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 emailing GDPR@htb.org.

LAWFUL BASIS

Legitimate Interest means the interest of our charities in conducting and managing our charitable activities to enable us to give you the highest quality courses, events, products and services 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 emailing GDPR@sptc.org.

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. SMCT and the other companies in the HTBG acting as joint controllers or processors and providing IT and stystem administration services.

THIRD PARTIES

SMCT and the other companies in the HTBG acting as joint controllers or processors and providing IT and stystem administration services.

External Third Parties 

.     Service providers acting as processors based in the UK who provide IT and system adminstration services.

·       Course and event management systems including Eventsforce, Eventbrite, Sardius and Brushfire.

·       Electronic marketing and survey services such as Mailerlite and SurveyMonkey

·       CRMs such as ChurchSuite and Raiser’s Edge.

·       Professional advisers including lawyers, bankers, auditors, pension advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

·       HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

·       Zoom, who provide an online video conferencing service that we use for meetings, courses, events and training.

·       Bristol Online Survey System

·       HESA

·       Office for Students

·       Ministry Division

·       Student Loans Company

·       Common Awards – Durham

·       Moodle

·       Turnitin

·       SAGE

·       Middlesex University

·       The Diocese that are partnering in training a particular ordinand

·       Residential Venues

·       Placement organisations

·       National Student Survey

·       Heritage Library System

·       Prevent

External Third Parties Privacy Policies (for online services only):

·       Blackbaud’s Privacy Policy and Privacy Shield Notice.

·       Brushfire’s Privacy Policy and Privacy Shield Notice.

·       Eventbrite’s Privacy Policy and Privacy Shield Notice.

·       Eventsforce’s Privacy Policy.

·       MailChimp’s Privacy Policy and Privacy Shield Notice.

·       Mailerlite’s Privacy Policy.

·       Sardius’s Privacy Policy.

·       SurveyMonkey’s Privacy Policy and Privacy Shield Notice.

.    Squarespace Privacy Policy and Privacy Shield Notice.

·       Zoom’s Privacy Policy and Privacy Shield Notice.

YOUR LEGAL RIGHTS

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.