Church of England parishes are required to prepare a new electoral roll before this year’s Annual Parochial Church Meetings. The CofE’s Parish Resources website has published the following advice on the effect of the GDPR on the electoral roll.
GDPR and Preparation of Electoral Roll 2019
We are aware that GDPR has raised some concerns regarding the renewal of the Electoral Roll. As the law currently stands, there is no need to amend the electoral roll forms, consent is not required. An informative note explaining the legal bases will be added to the forms in due course but the legal position is not dependent on this note.
The Church of England’s GDPR Team have produced guidance to clarify these issues (link below). They have also produced an electoral roll Privacy Notice which explains the GDPR issues for those individuals applying to the electoral roll. You should publish this on your website and/or give it to people who request an application form.
Download Guidance on the Electoral Roll and GDPR
Download the electoral roll Privacy Notice
[H/T to Law and Religion UK for bringing this to my attention.]
This guidance is helpful, if rather later than would be ideal. Given that Easter is so late this year, many parishes will be holding their APCMs in early April, and that means publishing the statutory notice and having application forms available in early Feb. As of yesterday morning, the only advice we had, via the diocesan office, was that the central GDPR unit was considering the matter! Better late than never!
Indeed. If a parish is holding its APCM in early March (which some do), the statutory process for compiling the new roll would need to have been commenced in early January: see Church Representation Rules, rule 2(4) and (5). Given that clergy (and others) are likely to be pre-occupied with other matters in December, this advice ought to have been available to (and e-mailed to all dioceses for them to publicise to parishes and publish on their websites) no later than November 2018.
The Privacy Notice seems erroneous. Under the section “What is the lawful basis for processing your data?” it contains in paragraph 2 “Processing … is carried out in the course of our legitimate activities, as this relates solely to members the Church of England in connection with its purposes.” But the electoral roll is open to people who are: members of the Church of England or of any Church in communion with the Church of England being resident in the parish or (not being resident … blah blah etc. Members of other Churches not in Communion may declare themselves also… Read more »
I am struggling to understand the proportionality aspect of publication to ‘the general public’ of electoral roll personal data. If carried to its logical conclusion with online publication of service times coupled with a detailed list of all likely attendees and their home addresses must represent a security and safety risk? Apologies if I have missed something here.