HGSS Sephardi Minyan — Privacy Notice

Contents

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain

Contact details

Email: sephardicommunity@gmail.com

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery and third party referrals:

• Names and contact details
• Gender
• Addresses
• Date of birth
• Payment details (including card or bank information for transfers and direct debits)
• Website user information (including user journeys and cookie tracking)
• Family details (names, Hebrew names, dates of birth, anniversaries of death (‘Yahrzeits’))

We also collect or use the following special category information to provide services and goods, including delivery and third party referrals. This information is subject to additional protection due to its sensitive nature:

• Religious or philosophical beliefs

We collect or use the following information to receive donations or funding and organise fundraising activities:

• Names and contact details
• Addresses
• Payment or banking details
• Donation history
• Tax payer information (for Gift Aid purposes)

We also collect or use the following special category information to receive donations or funding and organise fundraising activities. This information is subject to additional protection due to its sensitive nature:

• Religious or philosophical beliefs

Some of the personal information we process, such as Hebrew names, Hebrew dates, yahrtzeit information and participation in our religious activities, may reveal an individual's religious beliefs. As a not-for-profit religious organisation, we process this information in accordance with UK data protection law and apply appropriate safeguards to protect it.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

• Your right of access — You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification — You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure — You have the right to ask us to delete your personal information.
• Your right to restriction of processing — You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing — You have the right to object to the processing of your personal data.
• Your right to data portability — You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent — When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third party referrals are:

Legitimate interests— we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

We collect and use personal information relating to attendees, participants and regular contacts of the minyan so that we can organise and administer our religious services, events and community activities. This includes maintaining community records, communicating about services and events, recording Hebrew names and dates needed for religious purposes (such as yahrtzeits and birthdays), allocating honours where appropriate, and responding to enquiries. This processing is necessary for the effective operation of the minyan and benefits both the organisation and those who participate in its activities. We only collect information that is relevant to these purposes, limit access to authorised volunteers and committee members, and use appropriate technical and organisational measures to protect personal information. We have considered the impact on individuals and believe these legitimate interests are not overridden by the rights and freedoms of those whose information we process.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are:

• Legal obligation — we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests— we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

We collect and use personal information to administer donations, maintain records of contributions, communicate with donors where appropriate, and organise fundraising activities in support of the synagogue's religious and charitable purposes. This processing enables us to manage our finances effectively, acknowledge donations where appropriate, and maintain accurate donor records. We only collect information necessary for these purposes, restrict access to authorised officers and volunteers, and apply appropriate security measures. We have considered the impact on individuals and are satisfied that these legitimate interests are not overridden by their rights and freedoms.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

• Directly from you
• Family members or carers
• Third parties:
  • Hampstead Garden Suburb Synagogue
  • United Synagogue

How long we keep information

We keep personal information only for as long as it is needed for the purposes for which it was collected.

Personal information relating to attendees, participants and contacts of the minyan is retained while it is needed to administer and support our religious services, events, communications and community activities. When an individual is no longer involved with the minyan, we will review the information we hold and delete or anonymise it when it is no longer required, unless there is a legitimate reason or legal obligation to retain it.

Financial and donation records are retained for at least six years after the end of the relevant financial year to comply with legal, accounting and tax requirements.

Some limited historical and religious records may be retained where there is a legitimate interest in preserving the community's history and supporting ongoing religious practice. This may include information such as yahrtzeit records where families have requested continued remembrance, or records of significant community events and past office holders. Access to such records is restricted to authorised committee members and volunteers.

Who we share information with

Data processors

Kehilla.io (CRM and synagogue management software provider)

This data processor does the following activities for us: Kehilla.io provides a secure online platform for managing attendee and community records, religious service administration, events and communications. It stores and processes personal information on our behalf in accordance with our instructions and appropriate contractual safeguards.

Others we share personal information with

• Relevant regulatory authorities
• Organisations we're legally obliged to share personal information with

Sharing information outside the UK

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

• Organisation name: Kehilla.io / Keila GmbH
• Category of recipient: Synagogue management software provider / cloud-based CRM provider
• Country the personal information is sent to: Germany (European Union)
• How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: sephardicommunity@gmail.com

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint