This notice explains how the information you supply in your Confidential Declaration is used and your rights with
respect to that data as required by the General Data Protection Regulation 2016/679 (GDPR) and the Data
Protection Act 2018, (DPA 2018).
- Who we are
Trustees of Triple C (Liverpool) are the data controller, this means we decide how your personal data is
processed and for what purposes. - The data we collect about you
We collect your name and address as provided by you in the Confidential Declaration Form, and where
applicable, relevant conduct data and/or criminal offence data (including allegations); barring data; court findings
or orders.
We also collect the following information about other individuals living or employed in your household who are
over 16 years old, where applicable (see section 3, headed “Purposes and lawful bases for using your personal
data” paragraph 3):
• criminal offence data (including allegations); barring data; court findings or orders.
It is our expectation that you will inform these individuals that you have put their details on the CD form, and
that you explain the reason for this. - Purposes and lawful bases for using your personal data
The overall purpose of the confidential declaration is to ensure that I/we take all reasonable steps to prevent
those who might harm children or adults from taking up positions of respect, responsibility or authority where
they are trusted by others in accordance with the Safer Recruitment: Practice Guidance (2016).
We use your data for the following purposes and lawful bases:
• Appointing individuals to positions of respect, responsibility or authority where they are trusted by others.
• For the Diocesan Safeguarding Adviser to conduct a risk assessment where applicant discloses information
on the form.
• Collect information about members of your household for the purpose of undertaking a Disclosure and
Barring Service check on them if you have applied for a role where you work from home with children.
It is the legitimate interest of the Trustees of Triple C (Liverpool) to ensure that only appropriate individuals
are appointed to certain positions, as established by the Promoting a Safer Church – House of Bishops Policy
Statement (2017). We also need to be assured that no member of your household poses any risk.
It is also necessary for reasons of substantial public interest in order to prevent or detect unlawful act and
protect members of the public from harm, including dishonesty, malpractice and other seriously improper
conduct or for the purposes of safeguarding children and adults at risk. (Safer Recruitment Practice Guidance
(2016)).
Legitimate Interest Assessment
We have a specific purpose with a
defined benefit
The processing is an essential part of safer recruitment, to ensure
that individuals appointed to positions of respect, responsibility or
authority where they are trusted by others are properly vetted and
pose no risk to children, vulnerable adults or the wider public.
The processing is necessary to
achieve the defined benefit.
Without processing this data, there would be no assurance that
suitable individuals are being appointed.
The purpose is balanced against,
and does not override, the
interests, rights and freedoms of
data subjects.
The risk of significant harm to others if inappropriate appointments
are made outweighs the low risk to individuals of disclosing the data
to us.
For a copy of the full Legitimate Interest Assessment, please contact us on the details included in section 7
headed “Complaints”. - Sharing your data
Your personal data will be treated as strictly confidential and will only be shared with those involved in the
recruitment/appointment process and, where appropriate, the Safeguarding Adviser. It may be shared outside
the organisation for the prevention or detection of an unlawful act; to protect members of the public from harm
or safeguarding purposes, or as required by law, under Schedule 1, Part 1, Part 2 or Part 3 (as appropriate) of
the Data Protection Act 2018, with the following:
• Police
• Children’s or Adults Social services in Local Authorities
• Statutory or regulatory agencies, (e.g. the DBS) - Data Retention
We keep your personal data, if your application is successful, for no longer than reasonably necessary for the
periods and purposes as set out in the retention table below at the following link:
https://www.churchofengland.org/sites/default/files/2017-10/Safeguarding%20Records-
%20Retention%20Tool%20kit%20-Dec%2015.pdf
If your application isn’t successful, your data will be held for 6 months after the recruitment process ends, and
then destroyed. - Your Legal Rights and Complaints
Unless subject to an exemption under the GDPR or DPA 2018, you have the following rights with respect to
your personal data: –
• The right to be informed about any data we hold about you;
• The right to request a copy of your personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for us to retain such
data;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to
request a restriction is placed on further processing;
• The right to object to the processing of your personal data
• The right to obtain and reuse your personal data to move, copy or transfer it from one IT system to
another. [only applicable for data held online] - Complaints
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please
contact us using the details set out below.
Rev Helen Edwards, Chair of Trustees, Triple C (Liverpool) Sedgemoor Road, Norris Green, Liverpool L11 3BR
If you do not feel that your complaint has been dealt with appropriately, please contact Data Protection Officer,
Liverpool Diocese, St James House, 20 St James Road, Liverpool L1 7BY
You also have the right to lodge a complaint with the Information Commissioners Office. You can contact the
Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at
the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.