The Co-Mission Churches Trust, and our churches and ministries, seek to advance the Christian faith throughout London and to love and serve our local communities.  Therefore, we are committed to doing good and to maintaining the trust and confidence of our church members, guests, friends, local communities and, indeed, of all visitors to this website.  In particular, we would never even contemplate selling, renting or trading email lists or other personal information for marketing or any other commercial purpose.  The purpose of this policy is to provide you with information about when and why we collect your personal information and how we use it.  We hope you find this privacy policy helpful.

This policy was last updated on 5th November 2020.

Who we are and what this privacy policy covers

The Co-Mission Churches Trust (“CMCT”) is a registered charity (no. 1139922) and limited company (no. 07496944). Our churches include: The Boathouse Church Putney, Christ Church at All Saints Wandsworth, Christ Church Balham, Cornerstone Church Kingston, Dundonald Church, Grace Church Worcester Park, Hope Church Sutton and King’s Church Walton.

The purpose of this policy is to inform you about when and why we collect your personal data, how we use it, what our responsibilities are and what your rights are. “Personal data” means any information relating to an identifiable living person. It includes their name, physical address, email address, telephone number, health information or any other information about them, whether at home or at work.

Our aim is for you to understand how and why we use your personal data. It is important that you read this privacy policy together with any other privacy notice we provide on specific occasions when collecting or processing your personal data so that you are fully aware of our data processing activities.  If you do have any queries or concerns, please contact the appropriate church’s staff/eldership team in the first instance, or contact the CMCT charity services team by email:

Our responsibilities to you

As an organisation in the UK, we adhere to all UK data protection legislation including the Data Protection Act 2018 and all legislation implementing the General Data Protection Regulation (“GDPR”). We are registered with the UK Information Commissioner’s Office (“ICO”), with the registration number ZA504349.  The GDPR places a responsibility on us to not just to obey the letter of the law, but to build data protection in to everything we do.

In particular, we will:

Below you will find detailed information about how your personal data may be obtained, what it is then used for and what your rights are in respect of that data.

1. How we obtain and use information about you

a. Information which you provide us

You may provide us with personal data in many situations, such as when/if you:

b. Information we receive from other sources

We also collect information about you which you have provided to reputable third parties that we use (other Co-Mission churches or third parties that we choose to use e.g. Eventbrite, Ticket Tailor or Brushfire in relation to event bookings). We ensure that any third parties we use operate in accordance with UK data protection legislation.

c. Children’s data

We will collect and process personal data of children below the age of 16 when they attend Sunday School, a children’s/youth club or an external event. This is to enable us to provide good care at such programmes, know who to contact in case of emergency, and fulfil our safeguarding obligations. If you learn that a child under 16 has provided us with personal information without their parent or guardian’s permission, please contact us.

d. Personal data which you provide on behalf of someone else

If you give us information on behalf of someone else, you must be sure that the other person has appointed you to act on their behalf and has agreed that you can (i) make decisions about the processing of their personal data; and (ii) receive on their behalf any data protection notices.

Parents and legal guardians are responsible for the personal data of their children.

2. The lawful basis for processing personal data and how we use your information

a. Lawful Basis

We will process your data on one of the following bases:

In the majority of cases, we process personal data because it is necessary for our legitimate interests.

b. What we use your data for

Where relevant, we will use your data for the following purposes:

We will only use your information for the purpose it was collected (or for very similar/related purposes), unless an exceptional circumstance arises where we are legally required to disclose data. In all other cases, if we want to use your personal data for anything other than the reason it was collected, we will contact you beforehand.

c. Sensitive personal data

The data we collect may constitute sensitive personal data* (e.g. data concerning health in relation to pastoral care/Sunday School classes/children’s clubs/events) but we will only process such data:

We will always treat sensitive personal data with the greatest care.

* GDPR refers to “sensitive personal data” as ‘special categories of personal data’ (Article 9, GDPR) and includes data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. Personal data relating to criminal convictions and offences are not included within the definition of sensitive personal data under GDPR but similar extra safeguards apply to its processing (Article 10, GDPR).

3. Who your personal data may be shared with

We recognise that your information is valuable and will take all reasonable measures to protect your information. Generally, we will not share your personal data with others outside of CMCT. In most cases, only our employees, workers and volunteers approved by us, will see and process your data.

However, there are situations where your data might be made visible to others, for example, where you are a regular at one of our churches, your contact details might be made available to other regulars at that church in the form or a church address book or directory. This is because it is in the legitimate interests of the church family to be able to contact one another and provide care, support and encouragement to one another. In such circumstances, safeguards will be put in place and you will be given the opportunity to update your information and also to have your details removed from the church address book or directory.

Your personal data may be transferred to:

We do not sell, rent, distribute or otherwise make personal data commercially available to any third party except as described in this policy or with your prior permission.

4. Security and protection of your personal data

We use reasonable technical, administrative and physical controls to safeguard your personal data from unlawful use and unauthorised disclosure. In addition, we limit access to your personal data to those CMCT employees/workers, church volunteers and church elders who need to have access and they will only process your personal data on our instructions.  In all cases we will ensure that any access or transfer of your personal data is compliant with UK data protection law.

Where we use third parties (see above) to provide elements of our service and/or to process data on our behalf they are bound by law or contract to protect your personal data and only use it in accordance with our instructions. We only allow third parties to handle your personal data on the understanding that they will keep the information confidential.

We normally only store your personal data within the European Economic Area (“EEA”).   If one of our service providers (e.g. a payment gateway provider or payment processor such as Eventbrite, an online form builder such as Cognito Forms or an online server/storage provider such as Google/Microsoft Office) needs to transfer your personal data outside of the EEA then we will either ensure a data protection level equal to the one in the EEA or we will obtain your consent to the transfer.  For example, if you book onto one of our training courses through Eventbrite, if you complete our safeguarding application form/self-declaration form or if we store your personal data on Google Drive’s secure servers they may transfer your personal data outside of the EEA as they are US organisations – these third party organisations do however participate in and comply with the EU-US Privacy Shield Framework and accordingly the European Union allows the transfer.

All our staff who have access to personal and/or confidential information are subject to confidentiality obligations and may be subject to discipline including dismissal if they fail to meet these obligations.  Church volunteers who process personal information on our behalf are also required to comply with our Data Protection Policy.

While we will use all reasonable efforts to safeguard your personal data, the use of the internet is not entirely secure and we cannot absolutely guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you would like detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and other online problems you can visit, which is supported by HM Government and leading businesses.

5. Data retention

Ordinarily, we will retain core personal data such as your contact details for as long as you are a regular attendee at the church/ministry. Once you are no longer part of the church/ministry or in contact with it, these details will be deleted within one year.

As mentioned, part of our responsibility to you is to ensure we do not collect large amounts of unnecessary data. Therefore, personal data given for a specific purpose (such as a one-off church event), will only be kept for as long as necessary to carry out that purpose, then deleted within one year.

If you give your personal details for the purposes of NHS Test and Trace, we have a legal obligation to retain this data for 21 days after the service or event that you gave them.

In some circumstances, personal data needs to be retained for long periods of time. Specifically, these circumstances are that:

6. Links to third party sites

This privacy policy only addresses the use and disclosure of personal data by us. Our websites may contain links to other websites which may be of interest to you. In addition, we may provide social sharing and follow buttons, for example to Facebook and Twitter, on our website. If you use or follow these links or buttons to any of these third party sites, please be aware that they have their own cookies and privacy policies which we recommend you read. We do not control these other sites and we cannot be responsible for the content of these sites or for protection of any information you provide to other sites.  You should be cautious when entering personal data online.

7. Your rights

We want to ensure you remain in control of your personal data.  Part of this is making sure you understand your legal rights.  You have a number of legal rights under applicable data protection legislation in relation to the personal data that we hold about you, including:

You can exercise your rights by contacting us. Please note that we usually act on requests and provide information free of charge. We may however be entitled to refuse to act on a request and we may charge a reasonable fee in relation to our administrative costs if the request is baseless, excessive or repeated.

We will respond to you as soon as we can. This will generally be within one month from the date we receive your request but if your request is going to take longer to deal with we will let you know.

8. Making a privacy complaint

If you want to submit a written complaint about how we handle your personal data, please contact us or email us at If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

9. Contact and further information

If you have any questions or concerns about this privacy policy or the information we hold about you please contact us or email us at

10. Changes to our privacy policy

This policy is subject to a review at least every two years and will be updated when the law or best practice changes. You should therefore check this policy regularly to ensure that you are aware of any changes