The Archbishops’ Council
Clewer Initiative
Mobile App Privacy Policy
- version dated 25 May 2018
The Archbishops’ Council (we) are committed to protecting and respecting your privacy.
The Archbishops’ Council is the data controller and responsible for your personal data. We are a legal body pursuant to section 1 (1) of the National Institutions Measure 1998 whose objects are to co-ordinate, promote, aid and further the work and mission of the Church of England. Pursuant to section 1(2) of the National Institutions Measure 1998 the Archbishops’ Council is established for charitable purposes, charity number 1074857. We are registered with the Information Commissioner, registration number Z6034304.
SCOPE OF POLICY
This policy (together with our terms and conditions) applies to your use of the Safe Car Wash version 1.0 mobile application (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. INFORMATION WE COLLECT FROM YOU AND HOW
We will collect and process the following data about you:
Information you give us (Submitted information):
This is information you give us when you download or register an App, and when you report a problem with an Apps. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, e-mail address, and location (where GPS enabled).
Location information.
We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time.
We use different methods to collect data from and about you, including:-
Direct Interactions.
You will give us your name and email address when you initial sign up to the App on the one time log in screen
Automated technologies or interactions.
We may collect your location data where you have enabled GPS.
2. USES MADE OF THE INFORMATION AND PURPOSE
We use your personal information in very limited circumstances such as:
- 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.
Use of your data, and the basis of that use are:
Purpose/Activity: To Register you as a user of the app
Type of data: (a) Identity (name) / (b) Contact (email)
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/Activity: To manage our relationship with you including (a) user updates / (b) provide news from the Clewer Initiative about Modern Slavery
Type of data: (a) Identity (name) / (b) Contact (email)
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our services and grow awareness of modern slavery matters)
We will only use your data for the purposes it is collected. If we need to use your personal data for any unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. DISCLOSURE OF YOUR INFORMATION
We will not disclose any personal data we collect from you to any third parties unless required by law.
4. WHERE WE STORE YOUR PERSONAL DATA
The personal data that we collect from you will not be transferred outside the European Economic Area (EEA).
All information you provide through this mobile App is encrypted and stored on our secure CMS private servers only accessed by us.
5. YOUR 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.
You can also exercise any of the above rights by contacting us as below.
6. ACCESS TO INFORMATION
Data protection legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the legislation Act. 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.
7. CHANGES TO PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be notified to you when you next start the app. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App.
8. COMPLAINTS AND CONTACT
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 below 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.
Questions, comments and requests regarding this privacy policy are warmly welcomed and should be addressed to clewerinitiative@churchofengland.org