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Privacy Notice

(links on this page take you to external websites)

Last Updated: 25-11-2020

Name                                                Definition


General provisions

Here at Top Church Training (“we”, “our”, “us”, “TCT”), we are committed to maintaining the trust and confidence of our beneficiaries, supporters, volunteers and visitors to this website and our social media webpages. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

​This privacy notice is designed to help you understand what we will do with your personal information when you make contact with us, use this website or our social media webpages. It should be read in conjunction with our Terms of Use  and Copyright Notice.

If you choose to use this website or you contact TCT via another method, then you accept our Privacy Policy and Terms of Use and agree to the collection and use of personal information as outlined herein.


For the purposes of this Privacy Notice, the following terms shall mean:


TCTs website which can be found at


TCTs website and social media accounts with Facebook Twitter and Youtube and any other social media service we may use from time to time. Also includes when you contact us directly using any of the contact information or forms within TCTs website.

Data Subject

an identified or identifiable natural person - an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, , location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

Personal Information

any information which can be used to identify can be relates to a data subject

Non-Personal Information

information that cannot be used to personally identify you, such as anonymous general demographic information, usage data, referring/exit pages and URLs, platform types, the number of clicks, preferences you submit and preferences that are generated based on the data you submit.

Personal Data

collective term for Personal Information and Non-Personal Information


any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties

External Processing

consultants, professional advisers, partners, donors, contractors, agency workers, service providers.

Who are we?

TCT is a registered charity under number 1062241 and a company limited by guarantee, registered in England & Wales under number 03328704.  We are the data controller for the personal information we process.

We are registered with the Information Commissioner’s Office (“ICO”) under number ZA178556

Data protection officer

As part of our commitment to you, we have appointed a Data Protection Officer ("DPO") who is responsible for ensuring our ongoing compliance with this policy.

You can contact our DPO on or by writing to:


            The Data Protection Officer

            Top Church Training

            30-32 High Street

            Brierley Hill



            Telephone:   01384 262114


For our general contact information, please see our website contact page

The type of personal information we collect

When you use our Service, we collect both Personal Information and Non-Personal Information.  We collectively refer to these as “Personal Data”


From website and social media visitors/members, we collect the following Personal Data:

(we have grouped Personal Data of a similar type for ease of reference)

(this is not an exhaustive list)


  • identity information (such as forenames, surname, title, marital status, date of birth)

  • technical information (such as IP address, information about your equipment and the data below)


From those who get in touch with us using contact information and forms within this website, we will also collect:

  • contact information (such as names, addresses, telephone numbers, email addresses, whether you would like to be contacted and how)


From those who use the donation link/form, we will also collect:

  • financial information (such as bank details)


Other information we collect and from where:

  • image information (such as photographs taken of you and posted on our social media pages)

  • sound information (such as sound you post on our social media pages)

  • disclosed information - all information you choose to submit to us by direct exchange whether physical (e.g. ink & paper) or electronic.  includes all communications and information disclosed by you on our social media webpages.


Where we need to request more personal information from you in order to progress the relationship between us, we will send you a new Privacy Notice, appropriate to the nature of the intended relationship between us.

How much data do we collect?

We shall ensure that personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

How we collect personal data.

Some of the Personal Data we collect when you visit this website you provide to us directly for one of the following reasons:

  • you have made an information request to us using the contact form on this website

  • you have made a complaint to us.

  • you have disclosed information to us by email, post or telephone.

  • you have posted or commented on our social media webpages.

We also receive Personal Data indirectly, from the following sources in the following scenarios.

  • Donations
    Within our website we offer the ability to make a donation to TCT via Paypal’s online payment system. When you make a donation Paypal will collect both Personal Information and Non-Personal Information, some of which will be passed to us along with the money you donate.
    Paypal are based in the US and have servers all over the world. Your Personal Data is likely to be stored outside of the EEA area.
    Please read Paypal’s Privacy Notice before using this service, it explains what Personal Data they will share with us.

  • Mobile phones and digital telephones
    Mobile phones and many digital telephones record information such as your telephone number when a call is received from you.  You can choose to opt out of your Personal Information being stored on our phones by blocking your number from your own service.  If you choose to block your number, generally, this means it’s unavailable to all recipients of calls you make.

  • Website and social media
    Like any other internet site, TCTs website tracks information provided to it by your browser.  We track this information by using log files, cookies, or small text files which include an anonymous unique identifier. All hosting companies do this as part of hosting services' analytics; our social media webpages also collect information.
    We use External Processors to host elements of the Services covered by this Privacy Policy. Many of these are hosted in countries outside the EEA and the Personal Data collected by External Processors will be stored by them and made accessible to TCTs Data Processors.  The External Processor won’t use your Personal Data for their own purposes.
    Before you use our Services we strongly recommend that you read the Privacy Notices of our External Service Providers, Facebook, Twitter and Youtube.


  • Log files
    The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. This information is generally Non-Personal Information, but in some circumstances (e.g. a fixed IP address which can be used to identify you) it will be Personal Information.
    The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

  • Cookies
    Cookies are sent to your browser from the External Processor hosting our Services and then stored on your hard drive.
    We use a cookies tool on our website to gain consent for the cookies we use. Cookies that are necessary for functionality, security and accessibility are set and are not deleted by the tool.
    Learn more about cookies used by our website host Wix and for our Facebook pages, Youtube channel and Twitter.
    For more general information on cookies, please read ’What are Cookies
    You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites. If you choose to refuse our cookies, you may not be able to use some portions of our service.

How we use personal data
TCT will only hold and process personal data on bases which are lawful. We use Personal Data to: ​

  • provide and operate our website and social media webpages​.

  • enable us to contact you, should you wish us to.

  • facilitate the processing of online donations.

  • comply with any applicable laws and regulations.


We may also use software tools to measure and collect session information, including page response times, length of visits to certain software/pages, page/software interaction information, and methods used to browse away from the page/software.

What lawful basis do we have for processing your information?

The lawful basis we rely on to process the Personal Data we receive through the Service outlined in this Privacy Notice is either:

Consent (“C”)

Article 6(1)(a) of the GDPR.  For example, when:

  • we require your consent for the optional cookies we use.

You may withdraw your consent at any time by contacting our data protection officer on This will not prevent processing where the law allows us to process for a different reason in addition to consent.

Legal obligation (“LO”)

Article 6(1)(c) of the GDPR.  For example, when:

  • you disclose information by telephone or in an email to us which we are legally obliged to process.

Vital interests (“VI”)

Article 6(1)(d) of the GDPR.  For example, when:

  • you disclose information by telephone or in an email to us and we must process that information to protect someone’s life.

Legitimate interests (“LI”)

Article 6(1)(f) of the GDPR.  For example, when:

  • it’s necessary in order to maintain the integrity of our IT systems and the continuity of providing our website and social media webpages.


The same personal information may be held and processed for different purposes and, therefore, under different lawful bases, as identified on the form used to collect the information from the subject.

(Please see the ICO Guidance for more information on the lawful basis for processing information)

Change of processing purpose

We will only use your personal information for the purposes for which we collected it.  If we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose then we will do so.

  • If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer on

  • If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

  • Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Automated processing

TCT doesn’t use any automated decision-making software in the processing of your personal information.  Nor will TCT make your personal information available to any other organisation for such purposes

When do we share personal information?

We will not share your information with other organisations for the purposes of direct marketing. TCT will only share your personal data other individuals, groups or organisations for processing purposes directly related to the Services of TCT.

We use External Processors who provide the means through which we provide elements of our Service.  We have contracts in place with all our External Processors which means they cannot do anything with your Personal Data unless we instruct them to.  They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

TCT will share your Personal Data where it is necessary for reasons such as:

  • the operation of this website and our social media webpages.

  • to meet our statutory obligations

  • to manage TCTs relationship with you

  • to help you locate the services you need and then only when we have obtained your consent.


There may be circumstances when we are legally obliged to share your Personal Data, for example:

  • necessary for law enforcement purposes

  • in the public interest to do so


We may also share your Personal Data where we have your explicit consent to do so.

We shall make every reasonable effort to ensure that External Processors will hold your Personal Data securely and will only process it in accordance with the law, our instructions and to fulfil the service for which they are contracted. We do not allow third-parties to use your personal information for their own purposes.

Linking to other websites/external content

Our website and social media pages contain links to other sites. If you click on an external link, you will be directed to that site.   Like our website, these External Processors use technologies like cookies, which are sent directly to users’ browsers. They automatically receive your IP address when this occurs.

Note that these external sites are not operated by us and we strongly recommend that you read the Privacy Notice of the linked websites:

  • this Privacy Notice doesn’t cover how that organisation processes personal information.

  • we have no control over, and assume no responsibility for the content or data protection practices of any linked websites.

Transfer of personal data outside of the European Economic area (“EEA”)

Some of TCTs External Processors host the elements of service they provide on servers and other equipment which are located outside of the EEA; and emails generally pass through servers based at various locations, some of which may also be located outside of the EEA.

TCT make all reasonable checks that these organisations who use servers based outside of the EEA comply with the data protection laws, GDPR principles and the requirements outlined in this policy.

Where do we hold your personal data?

This website is hosted by a website platform service provider who enable us to provide services to you. When you visit or interact with this website, your personal information will be stored through their data storage, databases and the general applications.

If you contact us through one of the forms on the website, your information will be stored on the servers of our email host and their software.

How long do we keep your personal data?

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Notice. There are some legal and statutory requirements which determine if we must retain your personal information for a longer period.

  • technical information is kept for a period in line with the retention policy of the External Processor.

  • any other personal information you provide us under this Privacy Notice will be kept for a period of 6 months from the date of last contact.

  • social media posts will be kept indefinitely.

Information provided to other organisations

When there is no longer a processing need, we will, in line with our own retention requirements (above) ask the other organisation to delete your personal information from their records, whether held in paper or electronic form.

How we dispose of your data

We will usually delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

How do we secure personal data?

We use reasonable and appropriate physical, electronic, and administrative safeguards to protect personal information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the nature of the Personal information and risks involved in processing that information.

  • TCT shall ensure that personal information is stored securely using modern software that is kept-up-to-date.

  • access to personal information shall be limited to those who will need to process the information in order to execute their duties.

Security of information passed to other organisations.

Our primary goal is to ensure that your personal information is protected, please remember that no method of transmission over the internet, or method of electronic storage is 100% secure or reliable, we cannot guarantee its absolute security.

In the event of a breach of personal information security

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information, TCT shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Other important information 

Your rights in relation to personal information

Under data protection law, you have the following rights.

Your right to:

  • access - to the personal information we hold about you and to copies of it.

  • rectification - of any inaccurate information or to ask us to complete personal information you feel is incomplete. ​

  • erasure - of your personal information by asking us to delete or remove it from our systems.

  • restriction - of how we process your personal information or suppress the processing of it. ​

  • portability - of personal information by way of transfer to another organisation, or to you, in certain circumstances.

  • object - to your personal information being processed in certain circumstances.

You can find out more about your rights here: ​ICO - Your data matters

If you would like to access, correct, amend,  or delete any personal information we have about you, or if you would like us to stop processing it, you are invited to contact our data protection officer on If you make a request, we have one month to respond to you.

What we may need from you

You are not required to pay any charge for exercising your rights. However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee or we may refuse to comply with your request.

To help us comply with your request, we may need to request information from which enables us to confirm your identity. We do this to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Children’s information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. 

TCT does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

By using our website, you are confirming to us that you are over the age of 13.

Updates to this policy

We may update our Privacy Policy at any time, so we advise you to periodically review this page from time to time.  Usually when changes are made to our privacy policy, we will ask you to review the policy and accept website cookies again when you visit the website, but this cannot be guaranteed.  Changes are effective immediately they are posted on this page, the 'last updated' date at the top of this page confirms the date the most recent changes were made. 

Your continued use of this website signifies your continuing consent to be bound by our Privacy Policy.

Contact us

If you have additional questions or require more information about this Privacy Notice, please contact using the following email address:


If you have any concerns about our use of your personal information, you can make a complaint to us at

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:  


Information Commissioner’s Office

Wycliffe House

Water Lane





Helpline number: 0303 123 1113

ICO website:

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