What it is for
Under the GDPR, data that shows a person's connection to a church is special category data (Article 9). To process it, the church needs one of the exceptions the law allows. This template uses the clearest one: the person's explicit consent, in writing.
There is another possible exception for not-for-profit religious bodies, regarding their own members (Article 9(2)(d)). Which one applies to your church is a good question for a lawyer.
Each permission has its own box. The register is one thing; receiving messages and appearing in photos on social media are others, and a person can accept one and decline another.
How to fill it in
- Fill in the church's details and the contact for whoever is responsible for the data.
- Adjust the list of data to what the church really keeps. If you don't use a piece of data, take it off the list and out of the register.
- Write where the data is kept and who has access, and set the period for deleting the data of people who leave.
- If the church is not in Portugal, put your own country's data protection authority in the rights section.
- Delete the note at the top, print the form and hand it out with the membership form.
- Keep the signed form, and note in the register the date and the way consent was given.
- If someone withdraws consent, stop using their data and delete what you don't need to keep.
Good practice
- Consent only counts if it is freely given: nobody stops being a member for saying no to photos or messages.
- The boxes start unticked. The person ticks what they agree to.
- For anyone under 18, a parent or guardian signs too.
- Keep the forms somewhere locked, or scanned into a system with restricted access.
To learn more, read the guide GDPR for churches: a practical guide for the church office.
Frequently asked questions
Does a church have to ask for consent?
The church needs a legal basis to keep religious data. Explicit consent is the easiest to prove, and it is the one this template uses. There is another possible basis for the members of religious bodies: check with a lawyer which one applies to your church.
Do people already in the register need to sign?
If the church is going to rely on consent, yes. Use the next members' meeting or the next register update to collect the signatures.
Where can someone complain if their data is misused?
To the data protection authority of the country where the church is: in Portugal, the Comissão Nacional de Proteção de Dados (CNPD); in Spain, the AEPD. In the UK, which has its own version of the GDPR, it is the ICO. The template names the CNPD: change it if your church is elsewhere.