Stafford Muslim Prayer Hall is committed to the privacy and confidentiality of all visitors and attendees at the Mosque.
Stafford Muslim Prayer Hall is a registered place of worship and is run and operated by SMPHC Ltd. It is the “Data Controller” for any personal data it collects.
we do not collect any data on visitors or regular attendees at the Mosque unless
• they wish to engage in two-way communication with the Mosque or
• they make a donation in which case we request their details to enable us to issue receipts and subject to the donor(s) granting consent In either case, there is no compulsion and visitors and/or donors may choose to remain anonymous.
Mosque’s Madrasah Students.
In the case of children attending the Mosque’s Madrasah, then in order to administer our services, we collect the minimum amount of personal data necessary (name, age, address, gender, parent’s or guardian’s name, whether a child has any allergies (e.g. allergy to medication in the event that a teacher has to summon urgent medical assistance in an emergency), and emergency contact information (telephone, email address) for use in the event of an emergency.
This data is only retained whilst the child is a registered attendee at the Madrasah. No photographic records of individual children are kept. Group photos of a class may be kept subject to parental agreement, but no child is obliged to participate in such a group photograph.
Personal data will be held securely in electronic format or hard copy or both. All information held is carefully controlled and processed in accordance with current legal requirements in line with the UK Data Protection Act and the EU General Data Protection Regulation (‘GDPR’) guidelines. It is only shared on a “need to know” basis.
While GDPR is not designed to stop recording religious services or taking pictures of events in places of worship, it does require care on what is done with the images, whether moving or still.
In general it is not necessary to obtain consent to take a picture or video of someone inside a place of worship or at an event as most of the time this will count as a public place. UK law allows the taking of photos in a public place. However, if the person could have a reasonable expectation of privacy (for example, a support group, pastoral meeting or other more intimate setting) then their consent would be needed.
At Stafford Muslim Prayer Hall we take extra care with images or video which could identify people and their faith as this comes under “special category data”.
GDPR allows places of worship to process special category data under the ‘legitimate interest’ lawful basis, so long as they do not share the data outside the place of worship. As a general rule, we do not display photographs in the Mosque but in the unlikely event that we choose to do so, then we would always obtain prior consent to display pictures which contain special category data.
A picture of someone inside the mosque does not necessarily identify them as a Muslim. Neither does a video of someone attending a wedding or other social event held on mosque premises.
However, pictures or video of someone actively engaging in worship would do so.
So, if we intend to put the pictures on our website (hence we would be broadcasting the images outside the mosque) then we would always seek prior consent from anyone who is identifiable. Note that this is only necessary for pictures which contain special category or other sensitive data.
The same restrictions apply to moving images as to still. If the video is going to identify the people in it through special category or other data then we would obtain consent before broadcasting the video.
This does not apply to people in the worship team who are working on behalf of the mosque, and are therefore representing the “Data Controller”. It applies to Data Subjects, i.e. individuals whose data the mosque holds, in this case, in the form of a video of them worshipping or participating at a religious event. Because religion comes under special category data, consent must be obtained before sharing that video outside the mosque “body”.
However, consent is not required for display of still or moving images on a closed (private) circuit or private members group.
The mosque does not video special services such as weddings as this is left to the family to arrange and therefore, the mosque has no control or responsibility for the data collected in this manner. The family can show the video to whomever they like; the mosque is only responsible for what happens to data within its own control.
Large-scale faith-based events such as conferences or festivals.
The ICO recognise that it is not always feasible to get individual consent from everyone attending a large faith-based event. In addition, attending such an event does not necessarily identify someone’s faith or other special category statistic, and it will almost certainly count as a public place, in which case UK law allows photography and videography.
In this case, the ICO advise that the following steps are taken:
• At the point of booking, make attendees aware that photos/videos will be taken
• At the event, have signs reminding people that photos/videos may be taken
• If possible, have some areas in which photography is not allowed
• Get consent before photographing or videoing any situation in which the subject could have a reasonable expectation of privacy
• Consider the special category data content of photos and videos before you display or stream them and get consent at that point, if you need it
• Let attendees know who they should contact if they have any concerns
CCTV imagery has always been covered under the UK Data Protection Act 1998 and GDPR guidelines do not discourage the use of CCTV but instead encourage a balance regarding its usage.
At Stafford Muslim Prayer Hall CCTV recording is in operation in most “public areas” (except in areas where personal privacy is necessary) for security and health and safety purposes.
Signage indicating “CCTV Recording in progress” is displayed in most areas of the Mosque. CCTV footage is not retained permanently and is automatically overwritten periodically.
Access to current footage is strictly controlled on a need to know basis and may be shared only with law enforcement agencies in the event that they need assistance in an investigation into breaches of the law in or around the Mosque.