WS Privacy Notice

Westminster Synagogue Privacy Notice

1. Introduction  

1. At Westminster Synagogue we are committed to protecting your personal information.  We take reasonable care to ensuring we use your personal data in accordance with all applicable laws, notably the General Data Protection Regulations (GDPR).

2. We believe in being transparent regarding what we do with your data and will never utilise or process it in a way that we believe you would not reasonably expect.  This Privacy Notice informs you of how we will process your Personal Data. 

3. The person responsible for Data Control on behalf of Westminster Synagogue (Kent House, Rutland Gardens, London, SW7 1BX) is Gary Sakol, the Executive Director.

4. Kent House Knightsbridge (KHK) is a trading name of Westminster Synagogue, primarily used in relation to building rental as a venue.  This privacy notice relates to Westminster Synagogue activity under the name of Kent House Knightsbridge. 

5. Your information may be used by Kent House Knightsbridge, especially in relation to building rental as a venue.  This privacy notice also relates to Kent House Knightsbridge. 

6. If you have any questions, or for more information regarding how your data is used, you can contact the office time on 020 7584 3953 or admin@westminstersynagogue.org

2. The information we collect and how we use it

1. The legal basis for processing your personal data is that we have a legitimate interest in doing so.   The legitimate interest being pursued is that as a Synagogue and community organisation we need to hold a certain amount of personal data relating to our members and visitors so that we can communicate with them and manage their membership. 

2. In using and attending our events or services you consent to the collection and use of your Personal Data as set out in this Privacy Notice. 

3. We collect information about you directly from you and your family.  This is primarily done via application forms (for example membership application forms, event booking forms and education booking forms) and emails. 

4. On occasion, we may add information about you when received from another visitor/member of the Synagogue, a family member, or a third party where it is relevant and we have confidence it is accurate.   This typically happens when someone else is registering another guest for an event, or using a third-party website and you have given your consent to them.  We may combine information that we already have about you with information available publicly from external sources in order to gain a better understanding of you.  This may include social media sites. 

5. If you provide information for another person, you need to first ensure they agree for you to do so and be clear about what information you will provide.  You must inform them of where they can find our Privacy Notice. 

6. A full list of data we may hold about a person can be found in our Personal Data Audit document, which can be provided upon request.  A top-level overview of the data we may hold for each person includes;
   1. Personal information including name, gender, contact details, date of birth, family members, next of kin details, employment details, education details, car registration details, events attended, DBS information
   2. Medical information including allergies, medication details, medical history, learning difficulties
   3. Religious information including Hebrew name, yahrzeit dates, Bar Mitzvah details, marriage details, conversion details, family member details
   4. Membership details including date of joining, rate of membership, burial scheme information
   5. Financial information including bank details, all monies paid/donated, direct debit mandates, gift aid declarations, legacy commitments
   6. Visitor security form information including current and previous home addresses, ID documents (deleted after verification), job information

7. We use the information to provide you with information about products and services in keeping with our operation as a Synagogue.  This includes;
   1. Information regarding our religious services
   2. Information regarding upcoming events, both run by us and by third parties that we deem may be of interest
   3. To provide you with religious information in line with our principles:
      1. ‘Our aim is to create a synagogue which will be an instrument for the pursuit of religious truth. We would seek for knowledge and charity and piety. We want a congregation that will be a source of encouragement to human progress and of comfort and inspiration to individual men and women. We would be a congregation of interested active members, personally committed to our Synagogue, accepting the responsibility of membership as a challenge to the best in each of us. We regard our membership as a high privilege, and we will not be content with a synagogue which is less than a vehicle of truth.'
   4. To ask you to take part in community activities, for example helping to prepare Kiddush, security rotas, mitzvot.
   5. To meet pastoral and welfare needs
   6. For fundraising purposes and/or to collect Gift Aid
   7. For general promotional and marketing materials and activities
   8. For market research purposes and to monitor and improve our service to you
   9. To provide services and opportunities fitting for a Synagogue
   10. As otherwise permitted or required by any applicable law or regulation

8. We may contact you be email, letter, via social media, phone, text message or WhatsApp.
9. If there are any changes to your Personal Data, or if you become aware that we have inaccurate Personal Data relating to you, please contact us immediately.  We cannot be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you have provided us. 
10. We may occasionally use profiling techniques in order to target our communications effectively – e.g. To advertise information to someone of a particular age group, or within a certain location, or to assess the level of donation you may be able to give. 
11. A limited number of members of Westminster Synagogue, who have responsibility for an event or activity, may have access to your data and may contact you.  They will only use your data for the limited purpose of their volunteering role. 
12. With the exception of those on the Burial Scheme, we will never give, sell, share or trade your information to a third party unless we have your explicit consent to do so or are required to do so by a court of competent jurisdiction or an official regulator or if they are authorised to act on our behalf.  For those on the Burial Scheme, we share limited information with West London Synagogue, with whom we run the Burial Scheme with. 
13. The length of which we will hold on to your data will be in line with our policies set out in our Personal Data Audit document, which can be provided upon request.  We typically hold most information (but not all) indefinitely, unless requested otherwise. This includes information of over 18 year olds that do not join the Synagogue on reaching the age of 18, unless requested otherwise.  This is so as we can continue to offer you services that may be of interest to you and so we can help you in the future if you choose to re-join, or request a specific part of information from us. 
14. In order to help us communicate with you and to store data cost-effectively we use various third party solutions, including ShulSuite (as our primary database), Carbonite (as cloud storage), Dropbox (file sharing) and Quickbooks (accounting software).  As such, your information may be transferred and stored in countries outside the European Economic Area (EEA), including some that may not have the same level of protection of Personal Data as are enjoyed within the EEA. 

3. Internet and CCTV

1. No data transmission over the internet is 100% secure.  As a result, whilst we try to protect your personal information, we cannot guarantee the security of any information you transmit to us. 
2. Our website uses cookies (small software programmes that sit on your browser to improve the speed with which information can appear on your screen).  This may provide us with information as to how users use our online services.  If you do not wish to receive cookies, you can block them on your browser. 
3. When you receive emails from us, such emails may contain technologies to track, for market research purposes, whether you opened those emails and whether you accessed internet links contained within those emails. 
4. Our website may include links to other sites, not owned or managed by us.  We cannot be held responsible for the privacy of information collected by these websites. 
5. We do not place personal data on our website or materials other than names of members. 
6. We may upload photographs of our events and members to our website and social media profiles.  These can be removed upon request. 
7. We do not accept responsibility for the protection of any data publicly included on our website and on social media sites
8. The synagogue has a CCTV system which records activity on our grounds and in the Synagogue building.  The purpose of the CCTV is for security and to help with accidents and crime prevention.  The CCTV is primarily accessed by the security, house, management and reception teams to aid their ability to carry out their daily tasks.  The CCTV archive footage is overwritten after forty days.  The Police, Community Security Trust (CST) and other security organisations may access our CCTV archives. 

4. Your rights

1. You have a number of rights relating to your information, including;
   1. access to rectification of your personal data
   2. asking us to share your data with another party
   3. asking us to delete some or all of your information
   4. withdrawing consent regarding us holding and processing your data
   5. restricting or stopping us from using any of the Personal Data which we hold on you, including by withdrawing any consent you have previously given to the processing of such data

2. Please use the contact information at the top of the document if you wish to make any requests.  Such information will generally be provided within one month of the request. 
3. Westminster Synagogue has the right to make a reasonable charge to you for processing any unfounded, repeated, duplicate or excessive requests and to ask you to prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
4. Your provision of personal data to us is not a contractual or legal requirement.  However, in certain circumstances, without the data we may unable to fulfil the requirements you ask to us to do, for example relating to Burial Scheme, Marriage or Conversion. 
5. You have the right to complain to the Information Commissioner’s Office about the manner in which we process your personal data. 

5. Complaints

1. When we receive a complaint, we will make up a file containing the details of the complaint.  This normally contains the identity of the complainant and any other individuals involved in the complaint.
2. We will only use the personal information we collect to process the complaint and to check on the level of service we provide.  We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute.  If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that.  However, it may not be possible to handle a complaint on an anonymous basis.
3. We will keep personal information contained in complaint files. 

6. Updating this Privacy Notice

1. We may change or update parts of this Privacy Notice in order to maintain our compliance with application law and regulation or following an update to internal practices.  You will not necessarily be directly notified of such a change.  Therefore, please ensure that you regularly check this Privacy Notice so you are fully aware of any changes or updates. 
2. You can see the when this Privacy Notice was last updated at the start of this document.
3. Our latest Privacy Notice will be posted on our website – www.westminstersynagogue.org