Introduction
This Privacy Policy (together with the Terms and Conditions found on our website and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy also sets out your rights to control personal information we hold about you. Please read this Privacy Policy carefully in order to understand our practices regarding your personal data and how we will treat it.
Capernwray Missionary Fellowship of Torchbearers, with registered office: Capernwray Hall, Carnforth, Lancashire, LA6 1AG, registered in England as a charitable organisation with number: 1073139 and as a company limited by guarantee with number: 3573958, including its wholly owned subsidiary Capernwray Parkland Farm Limited, registered in England as a company limited by guarantee with number: 03674234 (together “Capernwray”, “we“, “us” or “our”) are committed to protecting and respecting your privacy and will only process personal data you provide to us in accordance with applicable privacy laws. The rules on processing of personal data are set out in the General Data Protection Regulation (“GDPR”).
For all data matters contact our Data Protection Representative at privacy@capernwray.org
Definitions
“Data controller” – determines the purposes and means of processing personal data and means Capernwray in this Privacy Policy;
“Data processor” – is responsible for processing personal data on behalf of a data controller;
“Data subject” – a natural person;
“Personal data” – any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR), for example name, passport number, home address or private email address and online identifiers include IP addresses and cookies;
“Processing” – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“Special categories personal data” – as set out in the GDPR, the special categories specifically including genetic data, and biometric data where processed to uniquely identify an individual and other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs;
“Third party” – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
SECTION 1 – If you are under 13
We do not and will not knowingly collect information from any unsupervised minor under the age of 13. If you are under the age of 13, you may not use our website unless you have the consent of, and are supervised by, a parent or guardian.
SECTION 2 – The purpose of processing your personal data
We use your personal data for the following purposes:
- Communicating with students, guests, alumni, and current and potential supporters with updates and news;
- Providing benefits and services to students, guests, alumni and supporters;
- Furthering our charitable mission (which includes fundraising and securing the support of volunteers);
- Enabling us to achieve our strategic and operational goals including the recruitment of staff.
SECTION 3 – The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data including, without limitation:
• your name, sex and date of birth;
• your postal address;
• your phone and email address;
• dates, times and duration and timings of you visiting Capernwray facilities or events; and
• where relevant, your parent/guardian and their contact details.
In respect of applications to attend Capernwray Bible School as a student or to serve as a volunteer or member of staff with us, in addition to the above:
• your personal image (photo);
• your education records;
• your career and employment history;
• your marital status and details of any children;
• your nationality, passport and social security number.
In respect of applications to attend Capernwray Holidays where identification is required, in addition to the above:
• your personal image (photo).
Where you are a donor to Capernwray:
• your donation and/or pledge details, including Gift Aid status (as required by HMRC).
We process special categories of data including, without limitation:
• your health, including any disability;
• dietary requirements;
In respect of applications to attend Capernwray Bible School as a student or to serve as staff or a volunteer with us, we additionally process the following special categories of data including, without limitation:
• your ethnic origin;
• your race;
• your religion (including place of worship);
• any criminal offences you have committed;
• your physical and mental health history.
The vast majority of the information we hold is obtained directly from our forms that you have filled in (such as contact forms, booking forms, application forms, registration forms and events forms).
SECTION 4 – What is our legal basis for processing your personal data?
We use your personal data for the following purposes:
a) Personal data
We process your personal data in pursuit of our legitimate interest in fulfilling the purposes set out in Section 2 of this Privacy Policy.
Whilst we rely on legitimate interest as the legal basis for processing, where this is not overridden by the interests and rights or freedoms of the data subjects concerned, we recognise that it is not the only lawful ground for processing data. As such, where appropriate, Capernwray will sometimes process your data on an alternative legal basis – for example, because you have given us consent to do so, or to fulfil contractual obligations we may have when you request services from us.
We may also need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies), including for the purposes of investigating a complaint, or if we have your permission to do so.
b) Special categories of personal data
To the extent we process your special categories of personal data, in addition to pursuing our legitimate interest in fulfilling the purposes set out in Section 2 of this Privacy Policy, we have obtained your explicit consent, or it may be necessary for reasons of public interest in the area of public health.
More information on lawful processing can be found on the ICO website.
SECTION 5 – Sharing your personal data
Your personal data will be treated as strictly confidential.
Please note, however, that we may need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies) or where we have your permission to do so.
SECTION 6 – How long do we keep your data?
We keep your personal data only as long as is necessary for the purpose(s) for which it was collected (unless otherwise advised) and in accordance with Capernwray’s records retention schedule. Data will be kept securely and destroyed when no longer required. We may also decide to archive some data.
SECTION 7 – Providing us with your personal data
We require you to provide us with your personal data in order for us to fulfil the purposes set out in Section 2 of this Privacy Policy.
SECTION 8 – Your rights and your personal data
We require you to provide us with your personal data in order for us to fulfil the purposes set out in Section 2 of this Privacy Policy.
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing of your special
categories of personal data at any time, where consent was the lawful
basis for processing such data;
• The right to request that we provide you with your personal data and
where possible, to transmit that data directly to another data
controller, (known as the right to data portability), (where applicable
i.e. where the processing is based on consent or is necessary for the
performance of a contract with the data subject and where the data
controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or
processing of your personal data, to request a restriction is placed on
further processing;
• The right to object to the processing of personal data, (where
applicable i.e. where processing is based on legitimate interests (or
the performance of a task in the public interest/exercise of official
authority); direct marketing and processing for the purposes of
scientific/historical research and statistics).
SECTION 9 – Transfer of data abroad
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
We do not transfer personal data outside the EEA.
Please note, however, that to the extent you submit personal information to us via the website we use for Bible School applications: https://applytobibleschool.com , it is sent to, processed by and stored by a third party data processor outside of the EEA on a secure server located in New Zealand. Your personal information may also be sent to, processed by and stored by other centres that form part of Torchbearers International, in connection with the purposes set out in Section 2 of this Privacy Policy. A list of Torchbearers International centres can be found at: https://torchbearers.org/centres-overview/.
Please be aware that not all countries offer the same level of data protection as your home country, although our collection, storage and use of your personal data will continue to be governed by this Privacy Policy.
SECTION 10 – Links
Our website contains links to other websites operated by third parties. Please note that this Privacy Policy applies only to the personal information that we collect and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the Privacy Policy of each website you visit carefully.
SECTION 11 – Cookies
Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site by placing small text files on your computer when you visit the website.
On this website, we only set essential cookies to remember when you have responded to a cookie or other prompt, so we don’t bother you again.
On some pages there are embedded videos or other content whose providers (Google, YouTube, Vimeo, etc) may set their own tracking cookies. Before these are displayed you will be asked for consent on the providers’ behalf. If you grant it, the consent will be recorded against your IP address for one year, and the content will be displayed. You can always delete cookies to revoke this.
You will also be asked if you consent to Google Analytics and Facebook Pixel tracking cookies. If you agree, we will include code from Google and Facebook which will track your visit using simple personal information like your IP address, browser details, pages visited, buttons clicked, and some form field names (but not form contents). This information will be stored and sent to these providers, allowing them and us to see which pages are visited and which adverts are working, helping us spend our money efficiently and effectively and make the website work best for you. The companies will each place and read cookies which could link your visit with the personal data you have already given them. For more details, see Facebook’s privacy policy and Google’s privacy policy. You will not be tracked unless you agree, and if you have agreed, a message will be shown at the very bottom of the footer allowing you to withdraw this consent later.
For further information about cookies, please visit allaboutcookies.org.
SECTION 12 – Online Application Forms
Third-party providers: Formstack, CubeMedia, PayPal and MailBigFile (MBF)
We use third-party providers to collect data on our behalf, including if you are attending Capernwray as a guest, or as a Bible School student, or if you wish to make a donation to us. These third-party providers are data processors for us and only process personal information in accordance with our instructions.
SECTION 13 – Electronic Newsletter
Third-party provider: MailChimp
We use a third-party provider to deliver our e-newsletters. We use industry standard technologies to gather statistics around email opening and clicks, to help us monitor and improve our e-newsletter.
SECTION 14 – Social Media
Third-party providers, including: Facebook, Instagram, Twitter, Vimeo and YouTube
If you send us a private or direct message via social media, the message will be stored by a third-party provider for three months. However, it will not be shared with any other organisations.
SECTION 15 – Emails
We monitor any emails sent to us for viruses or malicious software, including file attachments. Please be aware that you have a responsibility to ensure that any email you send is within the confines of the law.
SECTION 16 – Security and Performance
We use a third-party service to assist in maintaining the security and performance of our website, which requires the processing of website user’s IP addresses to do so. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
SECTION 17 – Automated Decision Making
We do not use any form of automated decision making.
SECTION 18 – Further Processing
If we wish to use your personal data for a new purpose not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
SECTION 19 – Changes to our Privacy Policy
Please check back regularly to keep informed of updates to this Privacy Policy as you will be deemed to have accepted any changes if you continue to use our website after an update has been posted.
SECTION 20 – How to make a complaint
We endeavour to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously and encourage individuals to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate, and welcome any suggestions for improving our procedures.
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Representative at privacy@capernwray.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office on 03031231113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.