Privacy Notice

This is the Privacy Notice for this website www.nwepolicy.net (‘the, this, our website’) published by the North-West Europe Region of the Prelature of Opus Dei (‘we’, ‘our’, or ‘us’). The regional Information Office of Opus Dei is at 6 Orme Court, London W2 4RL (Tel. +44 20 7221 9176, email info.uk@opusdei.org)

Third Parties

The website is hosted by Google Sites and related Google resources, such as Google Drive. We refer you to the Privacy Policy of Google for notice of their privacy policies. We have no access to, knowledge of, or responsibility for any technical, personal or marketing information which may be gathered or used by Google in consequence of your availing of their products, including visiting this website or following the links it provides to other websites on the internet. 

If you follow an Irish police vetting guide on this website, download a form and submit personal data on a signed printed form to our vetting officer for the purposes of a vetting application, that information will subsequently be transmitted by our vetting officer to a registered 'umbrella' organisation through which we process applications to the National Vetting Bureau or AccessNI. We refer you to the privacy policy of the Dublin City Volunteer Centre and the Central Northern Dioceses Vetting Office.

The vetting process also involves these agencies submitting your special personal data directly to the application portal of the National Vetting Bureau or AccessNI and not to us. We refer you to the privacy policy of the National Vetting Bureau and AccessNI.

Introduction

This notice describes how we collect, store, transfer and use ('process') personal data on this website. It tells you about your privacy rights and how the law protects you.

In the context of the applicable law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website (if you complete an online form), by email (if you send us an email to an address - @nwepolicy.net -  linked to this website) or through WhatsApp (if you contact us by WhatsApp from this website or provide a mobile number to be contacted).

Except as set out below, we do not collect, share, or disclose to a third party, any information used on our website.

Data Protection Officer

The processing of personal data is not a 'core activity' of the Prelature of Opus Dei. The instances in which sensitive personal data may have to be processed on this website are few and far between. Accordingly, the North-West Europe Region of the Prelature of Opus Dei has not made a formal appointment of a Data Protection Officer in respect of this website.

The Safeguarding Coordinator of the NWE Region will supervise the compliance of the Prelature with our privacy policy on this website. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact the Safeguarding Policy Administrator at data@nwepolicy.net. For other queries, the Safeguarding Coordinator may also be contacted at coordinator@nwepolicy.net. 

Personal data we process

1.          How we obtain personal data

Reading and browsing the information pages of this website does not involve any processing of personal information by us.

The only personal information from you that we may process includes information:

•  you have directly provided to us (if you complete an online form),

• you have provided by email to the dedicated email addresses linked to the website,

• you have provided by downloading and signing a vetting application form and submitting it (with personal identification documents) to our vetting officer,

• you have provided through WhatsApp (if you contact us by WhatsApp or provide a mobile number).

2.          Types of personal data we collect directly

When you request some service on our website (e.g. submit a safeguarding query or concern, apply for police vetting, request access permission to the personnel resource area), we ask you to provide personal data. This can be categorised into the following groups:

• personal identifiers, such as your first and last names, your title and your date of birth

• contact information, such as your email address, your telephone number and your postal addresses for communication,

• records of communication between us including messages sent through our website, email messages, WhatsApp and telephone conversations.

We may also process and retain for as long as necessary:

•  documentation that confirms your identity, such as an image of your passport or driver’s licence, for the purpose of a police vetting application

•  an image that shows your face, such as a passport photograph

• documentation that confirms your address, such as a utility bill or rental contract

• if you submit a report of a safeguarding concern, whatever additional details might be necessary to complete a report to the relevant civil and Church authorities.

When you submit personal data for vetting application purposes or in the context of a safeguarding concern, the data will be stored by us in a personal encrypted folder on Google Drive, accessible to us and shared exclusively with you.

3.          Types of personal data we collect from third parties

Additional information we may collect from other sources may include:

• information that confirms your identity

• information that confirms your contact information, e.g. postal codes

• ancillary information that confirms details of your reports.

4.          Types of personal data we collect (and don’t collect) from your use of our services

When you visit our website and use our safeguarding service:

• We retain your email address and telephone number (when provided by you) for correspondence and communication

• We process the personal data you intentionally submit to us (see no. 2 above)

• We do NOT receive or process personal data when you browse and scroll information pages on our website

• We do NOT receive or process technical information about the hardware or the software you use to access our website

• We do NOT receive or process usage information, e.g. the frequency you use our services, or the pages of our website that you visit.

5.          Our use of aggregated information

We may aggregate anonymous information such as statistical data for auditing or other reporting purposes. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

6.          Special personal data

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, personal life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also includes information about criminal convictions and offences.

Some elements of special personal data may form part of a police vetting application process you might initiate through this website. We do not normally collect or retain any special personal data about you. If you choose to disclose such information to us in the context of reporting a safeguarding concern or to obtain advice on a vetting application, it is treated as strictly confidential. It is seen only by those authorised to act on it in accordance with the law and/or the canonical processes of the Catholic Church.

7.          The lawful bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the legal basis changes then, where required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. All 6 of the bases are described here. 

Relevant lawful bases in the context of this website are:

• Information we process with your consent

Through certain actions, such as when you browse our website or ask us to provide you with more information, you provide your consent to us to process information that may be personal data.

When you submit personal data in the context of a vetting application, you express your explicit consent to the processing of that information by others in accordance with the law.

If you submit a safeguarding report, you give you consent to the processing of the information you provide by others in accordance with the law and in the best interests of the victim.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it, if there is another basis on which we may do so, e.g. if we have a legal obligation to do so in the best interests of a victim or person at risk.

• Information we process for the purposes of legitimate interests

We may process information on the basis that there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

• whether the same objective could be achieved through other means

• whether processing (or not processing) might cause you harm

• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• improving our services,

• record-keeping for the proper and necessary administration of our safeguarding responsibilities,

• preventing fraudulent or vexatious use of our services,

• obtaining professional advice that is required to fulfil our vetting or other safeguarding responsibilities,

• fulfilling our responsibilities in Canon Law to Church authorities who have a legitimate interest in fostering and regulating good safeguarding practice and discipline in the Catholic Church,

• protecting your interests where we believe we have a duty to do so.

• Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a civil statutory obligation, or to fulfil a canonical responsibility of the Prelature as a jurisdiction of the Catholic Church.

For example, we may on our own responsibility provide, or be required to communicate, safeguarding information to civil or ecclesiastical authorities if they so request and if they have the requisite authorisation. This may include your personal data.

• Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life or well-being, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

How and when we process personal data

8.          Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website, except to meet our obligations to authorised civil and ecclesiastical bodies in the context of a vetting application or a safeguarding concern.

9.      Information you provide

Our website allows you to submit confidential safeguarding reports with a view to that information being read, copied, downloaded, or used by authorised persons.

Once your information has been lawfully communicated by us to others, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal data that you have submitted to us. You can make a request by contacting the Safeguarding Coordinator or the vetting officer as appropriate.

10.      Service providers

We may share your personal data when strictly necessary with the relevant safeguarding and welfare agencies, such as (in Ireland) Tusla - the Child and Family Agency, the Gardaí, and (in Northern Ireland) the PSNI, Health and Social Care Trusts, and with organisations such as the Dublin City Volunteer Centre and the Central Northern Dioceses Vetting Office that provide essential services to us.

We may share anonymized versions of information you provide in a safeguarding context with relevant local supervisory bodies such as the National Board for Safeguarding Children in the Catholic Church in Ireland.

Use of information collected through automated systems

11.      Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered. They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them. Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

The use of cookies on our website is not controlled or determined by us but by Google Sites who host the website. They obtain your consent when you first visit. We refer you to Google policies for further details of their cookie policy.

12.      Personal identifiers from your browsing activity

Requests by your web browser to Google servers for web pages and other content on our website are not recorded by us, nor do we access such information for any purpose. We do not provide your personal data to advertisers or to third-party re-marketing service providers.

Other matters

13.      Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read this independent summary information.

14.      Use of our services by children

The information provided on our website is open to all. The online safeguarding report form may also be used by anyone, regardless of age.

We do not process vetting applications for minors (e.g. as summer camp leaders) except in accordance with the law and with the cooperation and consent of their parents or guardians.

15.      Encryption of data sent between us

Google Sites uses Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

16.      Delivery of services using third party communication software

With your consent and in an appropriate context (e.g. to provide online training in safeguarding), we may communicate using software provided by a third party such as Google (Meet), Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR. If you have any concerns about using a particular software for communication, please tell us.

17.      Data may be processed outside the European Union

Our website is hosted by Google Sites. We do not decide or control where the corresponding data will be hosted by Google.

Some safeguarding data originally provided by a user on our website might, in a rare case, be communicated by us to the offices of the Holy See located (outside the EU) in Vatican State, in the context of a canonical process or safeguarding referral.

We use the following safeguards with respect to data transferred outside the European Union or the United Kingdom:

• the processor is within the same corporate entity (the Catholic Church) as the Prelature and abides by the same binding corporate rules regarding data processing.

• both our organisation and the processor are public authorities between whom there are administrative arrangements approved by a supervisory authority relating to protection of your information.

18.      Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes. At any time, you may contact us to request that we provide you with the personal data we hold about you. For the most part, you will have direct access to that data in a personal encrypted folder shared on Google Drive with your personal Google account.

At any time you may review or ask us to update personally identifiable information that we hold about you. To obtain a copy of any information that is not provided on Google Drive you should contact us to make that request. When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. Please be aware that we are not obliged by law to provide you with all personal data we hold about you. After receiving your request, we will tell you when we expect to provide you with the information.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may or ought to process it, we may decide to do so on that basis.

19.      Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a better service.

20.      Complaints

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us, by sending an email to the website administrator. When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint. If you are in any way dissatisfied about how we process your personal data, you also have a right to lodge a complaint with the Data Protection Commission (DPC). We would, however, appreciate the opportunity to talk to you about your concern before you approach the DPC.

21.      Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• to provide you with the services you have requested,

• to comply with safeguarding and other laws,

• to support a claim or defence in legal or canonical proceedings.

22.      Compliance with the law

Our privacy policy complies with EU data protection law (GDPR) - i.e. the EU General Data Protection Regulation and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011  - and the equivalent UK laws (UK GDPR).

23.      Review of this privacy policy

We shall update this privacy notice from time to time as necessary.