An individual can object at any time to you using their personal information for:

  • Direct Marketing (including fundraising). If an individual objects to you using their data to contact them for this purpose then you must cease immediately. There are no exemptions.
  • Scientific, historical, research or statistical purposes. You can have an exemption from this if you have a legitimate need to keep processing it, e.g. you need to send Gift Aid information to HMRC.
  • A ‘legitimate interest’ of the church. This is the most likely objection a church will receive and we have outlined some examples below:
    • A church member has had a bereavement. They are happy for you to record it, but do not want that information used to trigger a pastoral follow-up at a later date.
    • A church member does not want you to record their attendance at home groups and use the information to ask them about it.

You must offer a way for individuals to object online. This could be as simple as providing a dedicated email address for church members to use for all data requests.

The above are just a very few examples of some of the many possible scenarios.  The important thing is that if you record any information about a person, you must ensure that there is a way to prevent that data being used in a way to which they object.  This is not intended to restrict the storing of data, but to allow the subject to specify how the information can be used.

Your church also needs to make it clear who should be contacted if a person wants to exercise this right.

The ICO has more information about the Right to Object here.

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