GDPR – Registering with the ICO
As churches prepare for the new Data Protection Regulations, several have asked us whether they need to register with the Information Commissioner’s Office (ICO).
Our reply comes from the Baptists Together ‘Frequently Asked Questions’ document on Data Protection, and it is almost an unequivocal YES.
The reply also gives details of how to register:
Do we need to register with the ICO?
YES – unless you are confident you meet the exempt conditions for not-for-profit organisations as outlined below. As the Annual Fee for churches is only £40 (£35 if you pay by Direct Debit) you should register if you think you may be processing information which falls outside this exemption.
If you are not currently registered you may want to wait until after 25 May to register as the new registration process should be easier than the current notification process.
The quickest way to register with the ICO is online at www.ico.org.uk/for-organisations/register. Alternatively, you can ring 0303 1123 1113
‘Not-for profit’ organisations (including churches) are exempt from registration if they meet all of the following conditions:
- You are only processing data for the purposes of establishing or maintaining membership or support for a body or association not established or conducted for profit, or providing or administering activities for individuals who are members of the body or association or have regular contact with it −
- You only hold information about individuals whose data you need to process for this exempt purpose − the personal data you process is restricted to personal information that is necessary for this exempt purpose.
This FAQ document, and other resources including a template policy and the Baptists Together Guideline leaflet are all available at https://www.baptist.org.uk/Groups/304642/Data_protection_documents.aspx
There’s also an excellent webinar by Rachel Tole (Baptists Together Data Protection Officer) and Caroline Sanderson (Baptists Together Legal Services Manager). It’s 2 hours long, but much more tailored to our situation as Baptist churches than most of the available training, especially as Rachel approaches the subject as a church secretary herself.