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Privacy Notice for Issuing Permission to Officiate or Overseas Permission to Officiate in the Diocese of Peterborough

September 2026

This privacy notice is provided by the Bishop of Peterborough to explain what to expect when we collect and process your personal information to issue you with Permission to Officiate (PTO) in accordance with the UK GDPR [and the EU General Data Protection Regulation (GDPR)

Data controller(s)

The data controller is the Bishop of Peterborough:

This means the bishop decides how your personal data is processed and for what purposes.

For further information on the Bishop of Peterborough please go to: www.peterborough-diocese.org.uk

1. Why we collect and use your personal data

Personal information is collected for the following purpose/s:

  • To assess suitability for ministry under Canon C8(3) and the Safer Recruitment Policy (Code of Practice).
  • To issue clergy with written PTO.
  • To manage the processes for granting, reviewing, renewing, refusing, not renewing, and withdrawing PTO and to correspond with clergy about these matters.
  • To provide effective arrangements for the oversight of clergy on PTO
  • To provide details of clergy with PTO to the Archbishops’ Council for inclusion in, or removal from, the National Register of Clergy.
  • To keep a record of the skills and experiences of clergy with PTO to enable these to be used to contribute to the mission and ministry of the Church
  • To review information from the Designated Responsible Person about the ministry of clergy with PTO.
  • To enable the bishop to make decisions about the deployment of clergy with PTO in the diocese.
  • To provide pastoral support.
  • To enable the bishop to assess training needs and record training completion.

2. Personal and special category data collected

We collect from you:

Data included as part of the following processes:

  • Application for PTO/OPTO, e.g. name, contact details, experience, training etc.
  • Safer Recruitment e.g. Confidential Declaration Form
  • Statement of expectations agreed with the Designated Responsible Person

Special category data

  • Religious belief as revealed by ordination
  • Health

We collect from 3rd parties:

  • Data provided by a bishop as part of the CCSL process.
  • DBS Enhanced Plus Check of the Barred List

3. The lawful basis for using your information

We collect and use your personal data under the following lawful bases3:

Personal data

  • Public task – (Canon C8); Safeguarding Policies (Safer Recruitment); PTO Policy
  • Legal obligation – National Register, OPTO

Special categories & criminal offence information

  • Legitimate activity – religious belief and health
  • DBS or overseas criminal checks – Schedule 1, Part2, Para 11 – protecting the public, Substantial Public Interest – DBS and criminal records checks

4. Who we share your information with:

The bishop will not share your data with any other third parties except where specified here. We will be sharing your information with:

  • The Archbishops’ Council – for the purposes of the National Register
  • The Designated Responsible Person
  • Bishops’ chaplains or other members of the bishops’ staff
  • Area deans or archdeacons
  • Diocesan Safeguarding Advisor/Officer
  • DBS or relevant overseas regulatory or statutory authority – for purpose of criminal records checks.  Currently Thirtyone:eight – an independent Christian safeguarding charity, who conduct Disclosure and Barring Service (DBS) checks on my behalf, as well as offering other safeguarding support services
  • Church of England Safeguarding Training Portal
  • Third-party system providers:
    • Optimity the Managed Service Provider for the office IT
    • Amperative Limited, who provide an online contact management system.Microsoft Online Services, through use of Microsoft 365, Office 365, and SharepointPathways
    • Oracle (which updates the National Register)
  • Legal or other internal/external advisors including:
    • Anna Spriggs, a partner of Howes Percival LLP, fulfils the Diocesan Registry function and provide legal advice to the Bishop and James Stewart the Deputy Registrar (Hunt & Coombs LLP).
    • The Diocesan Chancellor David Pittaway KC and the Deputy Chancellor Sir Martin Griffiths KC  
    • Legal advisers who provide specialist, non ecclesiastical, legal advice to the Bishop.
  • With your consent we will share details with our Chaplains to Retired Clergy and Clergy Widow(er)s.

5. Your personal data will/will not be sent to countries outside the UK/EEA

I will not transfer your personal information relating to your PTO to countries outside the United Kingdom, except: 

  • where I or my office use the services of a third party (listed above) who host data outside the UK.  I and my office will only use third parties who ensure that data hosted outside the UK is held in accordance with UK GDPR.   
  • In response to a confidential reference from an employer or appointment authority based outside the UK/EEA 
  • to judicial, statutory, regulatory bodies, law enforcement and prosecution agencies pursuing security or criminal investigations based outside of the UK/EEA where there is a substantial public interest in doing so. 
  • Where data transfer is required in relation to our international link diocese, or a confidential reference, separate consent will be sought.  

6. How long do we keep your information?

We will keep your information in accordance with the retention section of the Clergy File Policy and Guidance, and the Church of England retention schedule.

 Church of England Retention Schedule

Your rights

You have the following rights regarding 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 (data that is processed under Public Task).

To exercise these rights, please use the contact information provided below.  

Complaints or concerns 

If you have any queries or concerns regarding the processing of your personal data, please contact: 

The Bishops’ Office, The Palace, Peterborough PE1 1YA, bishop@peterborough-diocese.org.uk

You have the right to make a complaint at any time to [the Information Commissioner online at: Make a complaint about how an organisation has used your personal information | ICO or by phone on 0303 123 1113 (local rate). 

Under current arrangements, the ICO will generally expect you to have approached the data controller first, before making a complaint to them. 

This Privacy Notice will be reviewed and amended from time to time to align with changes to Church or UK legislation, codes of practice, policy or guidance.