- 1. Introduction
At Bet Knesset Chochmat Shlomo (BKCS) Synagogue we recognize the importance of keeping personal information secure and confidential. We take care to comply with the requirements of US data protection law, in the way that we handle information relating to members, staff, visitors and anyone else with whom we interact (“you”). We are required to provide you with certain information about this, which is the purpose of this notice.
For the purposes of the law the “controller” (meaning the party legally responsible for complying with data protection law) is BKCS. If you have a query or concern about this topic or if you wish to exercise any of your rights over your personal data (see section 4 below), please contact us as follows:
Address: 2387 South Green Rd. Beachwood, Ohio 44122
Telephone: 216-202-5366
Email: gabai@bkcscle.com
Please also get in touch promptly to let us know if your contact details change. This will help us maintain the accuracy and security of your information.
- Your Personal Data
2.1 What types of information might BKCS hold about you and where does it get it?
The types of information BKCS will hold about you will naturally depend on the nature of your relationship with the Synagogue. In general this information comes directly from you or is created by the Synagogue in the course of your involvement with its activities. (Note that there is no legal obligation on you to provide the Synagogue with your personal data. There will be some situations, however, where if you choose to withhold relevant information about yourself the Synagogue may be restricted in assisting you, such as in the context of its pastoral work or if you are a job applicant with unexplained gaps in your CV.)
BKCS may also hold information about you which it obtains in other ways, such as from recruitment agencies or referees (for job applicants and employees), other BKCS members, relatives, carers, community organisations, your employer (if you are providing services to BKCS) or occasionally from the internet (such as information about visiting speakers).
Commonly held types of data include name and contact details and, depending on your situation, information regarding (for employees) your employment and education history, related references and all HR administration matters, and (for members) subscription and other payments and Gift Aid-related tax status; details of family members; social circumstances; health-related information; religious beliefs and Jewish status; participation in Synagogue and broader community activities; and photographs and videos (e.g. of your involvement in Synagogue activities, or CCTV images from security cameras on BKCS premises).
2.2 What are the various purposes for which BKCS uses your personal data?
BKCS uses personal data for administrative and operational purposes as a company, an employer and a charity, particularly in connection with its religious, pastoral, educational, cultural, social and community activities and services, including associated security arrangements.
These general purposes include, for example, notifying members about community news, events, and other information that may be of interest, whether relating to the Synagogue or communal life more broadly. From time to time such communications may include requests for fundraising support, such as at the time of requesting annual membership renewals. The Synagogue may contact you by post, email or telephone, as may be appropriate to the circumstances. Members are welcome to contact BKCS if they wish to be removed from particular circulation lists.
2.3 Who might BKCS share your personal data with?
BKCS will only disclose information about you to others insofar as is appropriate for the above purposes. Depending on your circumstances, such recipients may include, for example: Synagogue management, members, volunteers and visitors; Religion School (Cheder) staff; healthcare, social and welfare organisations; professional advisers and companies providing services to BKCS.
membership information is also shared with them.
2.4 What is the lawful basis for BKCS to use data in the ways described?
The law specifies limited grounds on which it is permissible for an organisation to collect, use and disclose personal data, and it requires organisations to indicate which are relevant to their activities. Mostly, the following legal grounds justify the Synagogue’s handling of personal data:
- it is necessary for the performance of a contract (i.e. the membership or employment contract with you), e.g.:
- recording members’ contact information and subscription payment records;
- providing member data to providers like the burial society;
- it is necessary for compliance with a legal obligation, e.g.:
- providing names of Trustees or board members;
- it is necessary for a legitimate interest of the Synagogue (such as managing its activities) or a third party, as long as these interests are not outweighed by considerations of your privacy, e.g.:
- for the staff to have access to a yahrzeit list and to telephone members to ask if they would like to participate in a service at the relevant period;
- to circulate a security duty rota with names and email addresses so that people on it can arrange swaps;
- to publish newsletters containing news of members at Synagogue events;
- consent, e.g.:
- BKCS will endeavor to obtain your consent where appropriate and practicable, for example before publishing a photograph of you on its website or social media pages;
- where members provide their email or telephone contact details to BKCS, this amounts to consent for BKCS to communicate with them by email, telephone or text message regarding Synagogue news and events or broader communal matters;
- becoming a member of the Synagogue incorporates consent for it to share members’ details with its umbrella organisation, Reform Judaism.
Special category data
The law deems some types of personal data as inherently sensitive and puts more restrictions around its handling. Religious beliefs, ethnic origin and health information all fall into this “special category” of data. However, there are various bases which permit BKCS to handle such information, including:
- where this is necessary in connection with employment or to obtain legal advice;
- where this is necessary for substantial public interest reasons;
- where the information has been made public by the individual;
- where the information relates to current or former members or other key contacts, is being used for the legitimate activities of BKCS (being a not-for-profit body with a religious aim), is protected by appropriate safeguards, and the data is not disclosed to other bodies without consent; or
- where the individual has given explicit consent.
Please note that where the Synagogue collects, uses or discloses your data on the basis of your consent you have the right to notify it at any time that you withdraw that consent. This will not make the Synagogue’s previous use of your data unlawful. Also, BKCS may have other legal grounds on the basis of which it can nevertheless lawfully continue to process the relevant data.
- How Long Do We Keep Information About You?
BKCS retains personal data for as long as such information is needed for the purposes for which it is used. This will include any mandatory or appropriate record-keeping period that might be necessary for legal or accounting purposes.
Most membership data is retained for a period of two years after their membership expires. However, as a communal institution, the Synagogue also maintains a historic archive of its activities, including a register of past members. Council and board agendas and minutes are also retained permanently.
- Your Rights Regarding Personal Data
Subject to certain limitations, by law you have the right to ask BKCS to:
- give you a copy of your personal data (subject to the privacy rights of other people);
- correct or complete any personal data it holds that is incorrect or incomplete;
- stop using your details for direct marketing;
- stop using your personal data in a particular respect where BKCS does so in reliance on its legitimate interests or on the public interest or on your consent (see section 2 above);
- stop handling your data in a particular way pending the outcome of an objection you have raised to its doing so;
- delete your personal data where there is no lawful justification for BKCS to retain it; and
- transfer your personal data to you or another organisation (e.g. another synagogue) in a commonly used electronic format (this is known as the “right to data portability”).
Where you make one of the above requests, the response will generally be provided without charge and within one month if not sooner. Should an extension of up to two months be required to deal with complex cases we will inform you within the first month. A charge can be made, or the request refused, if it is clearly unfounded or excessive.
- Internet Websites: Cookies, etc.
5.1 Cookies
We may use “cookies” on our website and social media pages to give you a better experience and to monitor how visitors use the website, as this will help us make improvements for the future. These cookies do not enable us to identify website visitors by name, however, and simply provide us with anonymous statistics.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies, but if you do so, parts of the website may not work correctly.
5.2 Security and Links
The BKCS website uses security processes that protect your information from unauthorized use and we have procedures and security features in place to keep your data secure once we receive it. However, as no data transmissions over the Internet can be guaranteed to be 100% secure, we cannot take responsibility for any unauthorized access or loss of personal information that is beyond our control, e.g. whilst in transit.
We may provide links on our website to other websites. Before you supply any personal information to any other website, we recommend that you check the website’s Privacy Policy. We do not accept responsibility for the protection of any data supplied to other sites
- What if your data is affected by a security breach?
BKCS has technical and administrative measures in place that ensure an appropriate level of security for your information and protect it against unauthorized or unlawful processing and against accidental loss, destruction or damage.
In the unfortunate event of an incident occurring, such as hacking, which resulted in the confidentiality of information held by BKCS potentially being compromised, rest assured that we would promptly investigate and take action to limit any adverse consequences and have the source of the problem fixed. We would also comply with the legal requirements to notify the Information Commissioner and those affected, which depend on the type of information in question and the level of risk to individuals’ privacy.
- Changes to this Privacy Notice
Our Privacy Notice may change from time to time to reflect changes in our practices or in the law. In this case, the amended version will be published on the BKCS website. Where appropriate we will draw members’ attention to any material changes.
Last Updated: 02 Aug 2022