Privacy Notice for Unincorporated Entities (UE) Register of Declaration of Interests
Church of Scotland Office of the Assembly Trustees is providing you with this information to comply with data protection laws and to ensure that you are fully informed and we are transparent in how we collect and use your personal data.
Who is collecting the information?
Church of Scotland Office of the Assembly Trustees is the Data Controller. We have an appointed Data Protection Officer (DPO), Alice Wilson, who can be contacted by emailing: Privacy@churchofscotland.org.uk
Why are we collecting it and what are we doing with it (Purpose)?
Potential and new General Assembly/Assembly Trustees appointees will be informed before they are appointed that they will be expected to adhere to the UE Conflict of Interest Policy and a copy of the policy will be provided to them. Any potential conflict of interest should be discussed with the relevant Secretary prior to taking up position.
Appointees will be required to complete and submit a Declaration of Interests form annually. In addition, a declaration form must be submitted when a material change occurs. A Register of Interests will be maintained by the Office of the Assembly Trustees. The Register of Interests shall be reviewed on an annual basis.
Any declarations made will be bought to the attention of the Convener of the group upon which you serve by the Administrative Trustee/Office of Assembly Trustees.
What personal data do we collect?
The online declaration form will collect name and email address for the person completing the form along with confirmation of which committees they serve upon. Details of any declarations of interests may result in additional data being collected: details of immediate family member; details of employment held including name of employer, post held and nature of business; details of self-employment held including name and nature of business; details of office held including the organisation; details of directorships held including name of undertaking and nature of business; details of partnership held including name of partnership and nature of business; details of consultancy or other fee paid work including nature of work, for whom undertaken and frequency; details of hospitality or gifts received by external bodies including nature of hospitality or gift received and financial value; details of non-financial interests, including property interests.
How are we collecting this information? What is the source?
Information is collected from the individual completing the online Declaration of Interests Form using Microsoft Forms.
The lawful basis for the processing
Under UK GDPR Article 6(1)(c) "processing is necessary for compliance with a legal obligation to which the controller is subject" As the Trust is required to comply with the requirements under charity and accounting legislation.
Who we share the information with:
Information is collected from the individual completing the online Declaration of Interests Form using Microsoft Forms. The Register will be a Microsoft Excel spreadsheet which is run as a report from Microsoft Forms. Microsoft only process data as instructed by the Church. There is an appropriate contract in place with Microsoft and all data is held within the UK.
The Register of Interests will be held and accessed by the Office of Assembly Trustees (OAT) on behalf of the Administrative Trustee. The Office of Assembly Trustees will ensure that the register is held securely and only accessed by individuals who require access for their job. The Register can be accessed by the Head of HR, Solicitor of the Church and by request from the Governance or Audit Committees or as part of the internal or external audit regime.
Details of data transfers to any third countries or international organisations
Where an Assembly Trustee is based outside the UK, their data will be transferred to the UK following completion of the form. Currently the Administrative Trustee lives in Scotland and will manage and compile the data, ensuring appropriate safeguards are in place..
How long do we hold the personal data?
A new Declaration of Interests Form shall be submitted annually, in June, and therefore the register will hold this data for up to 12 months. After this period has passed the data will be destroyed securely following Church procedures.
Do we use automated decision making processes, including profiling?
The Church does not process data in this way
Individuals' rights in relation to this processing
Individuals have a number of rights under data protection laws. These are detailed here. Not all rights are absolute and some only apply in relation to the lawful basis for processing the data. For this purpose, the only rights that do not apply are the right to erasure, the right of data portability and the right to object. All other rights apply. If you want to exercise any of your rights please contact the DPO at Privacy@churchofscotland.org.uk