- The Confraternity of Pilgrims to Rome (CPR) is a membership organization whose purpose is to inform, encourage and assist those making a journey to Rome on foot, bicycle or horseback along the Via Francigena or other pilgrim routes. CPR sends out regular newsletters in printed form or via email and issues pilgrim passports and specially made pilgrim badges. We also compile a list of those who have walked, cycled or ridden to Rome.
- When you provide us with personal data to engage with us and/or benefit from our activities, we will keep a record of the data you give to us to enable us to comply with our statutory obligations.
- For the purpose of the General Data Protection Regulation 2016/279 (GDPR), CPR [through its Board of Trustees] will be a data controller in respect of your Personal Data.
- Everyone has rights regarding how their personal data is handled by organisations. CPR is committed to ensuring that personal data is properly and securely managed in accordance with the relevant data protection laws and believes this is an important part of achieving trust and confidence between the CPR and those with whom it interacts. Please read this notice to understand how we use and protect the information that you provide to us or that we obtain or hold about you, and to understand what your rights are in relation to information that we hold. This notice applies to information about living identifiable individuals only.
What personal data do we hold about you?
We may hold the following types of personal data:
- name and contact details;
- gender, and nationality;
- information about your current involvement in CPR activities and events;
- information about previous subscriptions and donations you have made to us in the past;
- information we collect through your use of our website(s) [such as IP addresses and other information collected using cookies];
- any other information which you choose to provide to us or that is provided by others.
How and why do we process your personal data?
The Personal Data which we hold about you, whether it is collected directly from you or whether we receive it from a third party, may be processed in several ways, for example:
- to communicate with you in relation to news about or activities and events including seeking feedback and informing you of any changes to our activities;
- to improve our activities and the way we communicate with you including our website and newsletters
- to process subscriptions and donations that you may make to us
- to administer, support, improve and develop the administration of CPR’s work and operations and to keep accounts and records up-to-date;
Any information gathered through cookies and similar technologies via the CPR website is used to measure and analyse information on visits to the website, to tailor the website to make it better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.
On what grounds do we process your personal data?
- We must have a lawful basis for processing your information; this will vary according to the circumstances of how and why we have your information, but typical examples include:
- the activities are within our legitimate interests in informing, encouraging and assisting those making a journey to Rome on foot, bicycle or horseback along the Via Francigena or other pilgrim routes; in providing information about the activities of CPR;
- you have given consent (which can be withdrawn at any time by contacting us using the details below) for us to process your information (e.g. to send you communications by email or post);
- If we process any special categories of personal data, we must have a further lawful basis for the processing. This may include:
- where you have given us your explicit consent to do so (e.g. to cater for your medical or dietary needs at an event);
- where the processing is necessary to protect your vital interests or someone else’s vital interests (e.g. passing on information to the police);
- where the processing is carried out in the course of our legitimate interests
- you have made the information public (e.g. reports in the media which have had your consent.)
- where the processing is necessary for the establishment, exercise or defence of legal claims;
- where the processing is necessary for carrying out any future employment and social security obligations; or
- the processing being necessary for reasons of substantial public interest (e.g. where steps are taken to prevent fraud or other dishonest activity);
- where you have given us your explicit consent to do so (e.g. to cater for your medical or dietary needs at an event);
provided that the legal basis is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your rights, or as part of our legitimate interests.
Who will we share your information with?
- We will only use your personal data within the organization for the purposes for which it was obtained, unless you have explicitly agreed that we may share your personal data with another organisation or unless we are otherwise permitted or required to under the Data Protection Rules or order of a court or other competent regulatory body or as set out in this notice.
- We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal data that we hold.
- The CPR uses the following third parties:
How long will we keep your information for?
- We will endeavour to only keep personal data for as long as is necessary and to delete it when it is no longer so.
- We maintain physical, technical, and organizational security measures to protect the personal data against accidental, unlawful, or unauthorised destruction, loss, alteration, disclosure, or access, whether it is processed in your local jurisdiction, the United Kingdom, or elsewhere.
- You have rights in respect of the personal data you provide to us. In particular:
- the right to request a copy of some or all of the personal data that we hold about you (including, in some cases, in a commonly used, machine readable, format so that it can be transferred to other data controllers) . We do not make a charge for this service;
- if we process your personal data on the basis that we have your consent, the right to withdraw that consent;
- the right to ask that any inaccuracies in your personal data are corrected;
- the right to have us restrict the processing of all or part of your personal data;
- the right to ask that we delete your personal data where there is no compelling reason for us to continue to process it;
- the right to object to us processing your personal data for direct marketing purposes e.g. in relation to fundraising carried out by CPR;
- the right not to be subject to legal or other significant decisions being taken about you on the basis of an automated process (i.e. without human intervention).
- Please note that the above rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal data. Also, we may need you to provide us with proof of identity for verification and data security purposes before you can exercise your rights.
- Rights may only be exercised by the individual whose information is being held by CPR or with that individual’s express permission.
- We may make changes to this notice from time to time as our organisational practices and/or applicable laws change. We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by data protection laws.
- If you have any questions, require further information about how we protect your personal data, if you wish to exercise any of the above rights or if you would like to provide feedback or make a complaint about the use of your information, please contact firstname.lastname@example.org or by post to:
The Confraternity of Pilgrims to Rome, Unit 80226, PO Box 6945, London, W1A 6US
- We hope that we can satisfy any queries you may have about the way in which we process your personal data. However, if you have unresolved concerns you also have the right to complain to the Information Commissioner (https://ico.org.uk)
Visitors to our Website
- When someone visits pilgrimstorome.org we use a third-party service, WordPress Statistics and Jetpack, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow WordPress to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
- Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions e.g. to know who you are if you log into a restricted part of a website, for shopping carts, and for tracking purposes.
- CPR uses the following cookies:
- WordPress statistics We use WordPress cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website for example number of visitors and length of time on site. This process does collect data, but in an anonymous form, to help us make improvements, develop the website and enhance the user experience.]
- Managing Cookies
- Please note that you cannot opt-out of the deployment of cookies that are necessary for delivery of our website or services to visitors.]
- The Confraternity of Pilgrims to Rome takes our data handling responsibility seriously, so your contact details will be used solely for the purpose of keeping you informed in the way you have requested, and we will never share your information with a third party. To be removed from our mailing list contact email@example.com or use the unsubscribe option in the footer of all our newsletters.
“Data Controller” means a person, organisation or body that determines the purposes for which, and the manner in which, any personal data is processed. A data controller is responsible for complying with the data protection laws including the GDPR and establishing practices and policies in line with them.
“Data Processor” means any person, organisation or body that processes personal data on behalf of and on the instruction of CPR. Data processors have a duty to protect the information they process by following data protection laws.
“Data Subject” means a living individual about whom CPR processes personal data and who can be identified from the personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal data and the information that CPR holds about them.
“Personal Data” means any information relating to a living individual who can be identified from that information or in conjunction with other information which is in, or is likely to come into, CPR’s possession. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (e.g. a performance appraisal). It can even include a simple email address. A mere mention of someone’s name in a document does not necessarily constitute personal data, but personal details such as someone’s contact details (if it enabled an individual to be identified) would fall within the definition.
“Processing” means any activity that involves use of personal data. It includes obtaining, recording or holding the information or carrying out any operation or set of operations on it, including organising, amending, retrieving, using, disclosing, erasing or destroying it.
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