Privacy Notice


BOWDEN AND MELROSE CHURCH, Charity Number SC006480 (the “Congregation”)


Purpose of this Notice


This Privacy Notice outlines the way in which the Congregation will use personal information provided to us. Personalinformation includes any information that identifies you personally, such as your name, address, email address or telephone number.


The Congregation recognises the importance of your privacy and personal information and we have therefore outlined below how we use, disclose and protect this information. The Congregation, jointly with the Presbytery of Lothian and Borders is the data controller, because we decide how your data are processed and for what purpose. Contact details for us are provided below.


How we use information


We use the information you give to us:


  • to administer membership records, including a Communion Roll and Supplementary Roll;
  • for pastoral care purposes;
  • in relation to participation in Congregational activities;
  • to provide you with information about news, events, and activities within the Congregation or the wider Church of Scotland;
  • to provide the services of a parish church to the local community;
  • to fulfill contractual or other legal obligations;
  • to manage our employees;
  • to further our charitable aims, for example through fundraising activities;
  • to maintain our accounts and records (including the processing of Gift Aid applications);


Disclosure of information


The Congregation will only share your personal information where this is necessary for the purposes set out above. Information will not be shared with any third party outwith the Church of Scotland without your consent unless we are obliged or permitted to do so by law.


Basis for processing personal information


The Congregation processes your information in the course of its legitimate activities, with appropriate safeguards in place, as a not-for-profit body with a religious aim and on the basis that our processing relates solely to members, former members or people who have regular contact with us, and that this information is not disclosed to any third party without your consent.


We also process information where this is necessary for compliance with our legal obligations; where processing isnecessary for the purposes of our legitimate interests and such interests are not overridden by your interests orfundamental rights and freedoms; and where you have given consent to the processing of your information for a particular purpose.


Storage and security of personal information


The Congregation will strive to ensure that personal information is accurate and held in a secure and confidential environment. We will keep your personal information for as long as you are a member or adherent or have regular contact with us or so long as we are obliged to keep it by law or may need it in order to respond to any questions or complaints or to show that we treated you fairly. We may also keep it for statistical purposes but if so we will only use it for that purpose. When the information is no longer needed it will be securely destroyed or permanently rendered anonymous. A copy of our data retention policy is attached to this Notice.


Getting a copy of your personal information


You can request details of the personal information which the Congregation holds about you by contacting us usingthe contact details given below.


Inaccuracies and Objections


If you believe that any information the Congregation holds about you is incorrect or incomplete or if you do not wish your personal information to be held or used by us please let us know. Any information found to be incorrect will be corrected as quickly as possible.


You have the right to object to our use of your personal information, or to ask us to remove or stop using yourpersonal information if there is no need for us to keep it. There may be legal or other reasons why we need to keep oruse your data, but please tell us if you think that we should not be using it.


If we are processing your data on the basis of your explicit consent, you can withdraw your consent at any time. Please contact us if you want to do so.


Contact us


You can contact us by getting in touch with our Church Secretary, Tracey Glover, on 01896 823339 or


How to complain


You have the right to complain to the Information Commissioner’s Office about anything relating to the processing of your personal information by the Congregation. You can contact the IC0 via its website at or at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 SAF.





  1. Introduction
    • Church of Scotland congregations gather personal information from individuals and external organisations as well as generating a wide range of personal data, all of which is recorded in documents and records, both in hard copy and electronic form.
    • Examples of the types of information accumulated and generated are set out in Appendix 1 of this policy and include but are not limited to minutes of Kirk Session meetings; membership rolls; baptismal information; employment records; newsletters and other communications such as letters and emails.


  • In certain circumstances it will be necessary to retain documents to meet legal requirements and for operational needs. Document retention is also required to evidence agreements or events and to preserve information.


  • It is however not practical or appropriate for congregations to retain all records. Additionally, data protection principles require information to be as up to date and accurate as possible. It is therefore important that congregations have in place systems for the timely and secure disposal of documents that are no longer required.


  • This Data Retention Policy was adopted by the Congregation on 31 May 2018 and will be implemented on a day to day basis.
  1. Roles and Responsibilities


  • Congregational office bearers and those involved with safeguarding will adopt the retention and disposal guidance at Appendix 1 of this policy and strive to keep records up to date.


  • Advice will be obtained from the Law Department or Safeguarding Department of the Church Office at 121 George Street if there is uncertainty about retention periods.


  1. Retention and Disposal Policy


  • Decisions relating to the retention and disposal of data should be guided by:-


  • Appendix 1 – Document Retention Schedule – Guidance on the recommended and statutory minimum retention periods for specific types of documents and records.


  • Appendix 2 – Quick Guide to document retention.


  • In circumstances where the retention period for a specific document or category of documents has expired, a review should be carried out prior to disposal and consideration should be given to the method of disposal.
  1. Disposal


  • Documents containing confidential or personal information should be disposed of either by shredding or by using confidential waste bins or sacks. Such documentation is likely to include financial details, contact lists with names and addresses and pastoral information.


  • Documents other than those containing confidential or personal information may be disposed of by recycling or binning.


  • Electronic communications including email, Facebook pages, twitter accounts etc and all information stored digitally should also be reviewed and if no longer required, closed and/or deleted so as to be put beyond use. This should not be done simply by archiving, which is not the same as deletion. It will often be sufficient simply to delete the information, with no intention of ever using or accessing it again, despite the fact that it may still exist in the electronic ether. Information will be deemed to be put beyond use if the Congregation is not able, or will not attempt, to use it to inform any decision in respect of any individual or in a manner that affects the individual in any way and does not give any other organisation access to it.


  • Deletion can also be effected by using one of the following methods of disposal:-
  • Using secure deletion software which can overwrite data;
  • Using the function of “restore to factory settings” (where information is not stored in a removeable format);
  • Sending the device to a specialist who will securely delete the data.


Appendix 1

Data Retention Schedule


NOTE: There may be an historic interest in the Congregation’s records. Kirk Session minutes are archived after 50 years.


Minutes of meetings6 years
Kirk Session meetings

50 years – permanent. After 50 years pass the minutes to the principal clerk’s office, who then liaise with the National Records of Scotland for archiving.


Pre-employment enquiries/applications/notes/letters/references

6 months after completion of recruitment (unless data to be retained for a future similar opportunity, in which case 1 year)


Safeguarding – Service confirmation of advice, emails, letters100 years
Safeguarding – Confidentiality Agreements100 years
Safeguarding – Covenants of Responsibility (managing those who pose a risk)100 years
Safeguarding – Risk Assessments100 years
Safeguarding – Complaints concerning people100 years
Safeguarding – Audit for Congregations and Presbyteries100 years
Congregational Roll100 years
Certificates of Transference/Lines100 years
Employee/appointments records including: contracts, time records etcDuration of employment + 7 years
Volunteer recordsDuration of placement + 7 years
Databases for mailing lists/distributionReviewed annually, delete out of date information
Miscellaneous contact informationDelete once there is no longer a requirement to hold such information
Arranged accommodation/placements (e.g. overseas visitors)3 years following end of event/placement
Documents relating to litigation or potential litigationUntil matter is concluded plus 7 years
Hazardous material exposures30 years
Injury and Illness Incident Reports (RIDDOR)5 years
Pension plans and retirement recordsPermanent
Salary schedules; ranges for each job description2 years
Payroll RecordsMinimum, 7 years. No maximum
Contracts7 years following expiration
Construction documentsPermanent
Fixed Asset RecordsPermanent
Application for charitable and/or tax-exempt statusPermanent
Sales and purchase records5 years
Audit and review workpapers5 years from the end of the period in which the audit or review was concluded
OSCR filings5 years from date of filing
Records of financial donations7 years
Accounts Payable and Receivables ledgers and schedules7 years
Annual audit reports and financial statementsPermanent
Annual plans and budgets2 years
Bank statements, cancelled cheques, deposit slipsMinimum of 7 years
Business expense records7 years
Cash/cheque receipts7 years
Electronic fund transfer documents7 years
Employee expense reports7 years
General ledgersPermanent
Journal entries7 years
Invoices7 years
Petty cash vouchers7 years
Tax recordsMinimum 7 years
Filings of fees paid to professionals7 years
Environmental studiesPermanent
Insurance claims/ applicationsPermanent
Insurance disbursements and denialsPermanent
Insurance contracts and policies (Directors and Officers, General Liability, Property, Workers’ Compensation)Permanent
Leases7 years after expiration
Property/buildings documentation (including loan and mortgage contracts, title deeds)Permanent
WarrantiesDuration of warranty + 7 years
Records relating to potential, or actual, legal proceedingsConclusion of any tribunal or litigation proceedings + 7 years



Appendix 2

General guidance for documents NOT included in the retention schedule.

On-going business use is subjective, but generally refers to documents still required for on-going projects, or documents that may still need to be referred to for on-going activities.