Privacy Policy – Mull Another Way (Data Controller)
What is Personal Data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the ‘GDPR’.
How do I process your personal data?
I comply with my obligations under the General Data Protection Regulation (GDPR) by keeping personal data up to date; by storing and destroying data securely using password protection and locked physical storage; by not collecting or retaining excessive amounts of data; by reviewing data I hold regularly; by protecting personal data from loss, misuse, unauthorised access and disclosure. I use your personal data for the following purposes:
• To enable me to reply to your enquiries by phone, email or Zoom.
• To provide you with a service of spiritual direction
• To maintain manual records – stored anonymously and securely – for the purposes of best practice in working with spiritual directees.
• To send you email notice of events, activities and projects which may be of interest to you, if you sign up to this
• To maintain my own accounts and records
What is the legal basis for processing your personal data?
A. Consent – for mailing lists, gathered via online sign-up forms
B. Contract – for providing you with spiritual direction
Special Categories: With Contract as the lawful basis I also operate a separate condition of explicit consent for processing special categories of data, such as religion or health etc, for the purpose of providing you with best practice in spiritual direction, pastoral supervision and training whilst protecting your privacy.
Sharing your personal data
Your personal data will be treated as strictly confidential. I will only share your data with third parties with your consent – apart from two conditions, as outlined in ‘Confidentiality ’overleaf.
How long do I keep your personal data?
If you are on my email list I keep your name and email data for as long as you are signed up; you may unsubscribe at any time. If you are a directee or supervisee your paper and electronic records are held for 7 years after your final appointment and are then securely destroyed. Zoom ID is deleted after 2 years.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• To request a copy of your personal data which I hold about you
• To request that I correct any personal data if it is found to be inaccurate or out of date
• To request your personal data is erased where it is no longer necessary for me to retain such data
• To withdraw your consent to the processing of data at any time
• Where there is a dispute in relation to the accuracy of data, to request a restriction is placed on further processing
• To object to the processing of personal data •
• To lodge a complaint with the Information Commissioners Office
Further processing
If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, I 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. Where and whenever necessary, I will seek your prior consent to the new processing.
To exercise all relevant rights, queries or complaints please in the first instance contact Wendy Lloyd at contact@mullanotherway.co.uk
