When a request arrives
A request doesn’t have to use the right words. “What do you have on me?” in an email, a phone call or a chat after the service is a subject access request. Anyone at the church can receive one, so make sure your team knows who to pass it to.
Write down the date it arrived. You have one month to reply. Only ask for proof of identity if you genuinely need it, and if you do, the month starts when you get it.
Searching your records
Your search needs to be reasonable and proportionate. Check your main records, email, phones and paper files, and any notes kept by your minister or pastoral team.
If the request is unclear or you hold a lot about the person, you can ask them to narrow it down. The clock pauses on the day you ask and starts again the day after they reply.
Other people’s information
Church records often mention other people: a prayer request about a family member, or a note of a conversation. You don’t have to share someone else’s details unless they agree, or it’s reasonable to share them anyway.
Remove or cover what you can’t share, and say in your letter that you have.
What to send
Send a copy of the information itself, not a summary, with a letter explaining it. The ICO calls this supplementary information: why you use it, who you share it with, how long you keep it, where it came from and the person’s rights. The template covers all of it.
If they asked by email, reply by email in a format they can open. Send it securely, and check the address before you press send.
Safeguarding records and refusals
Some information can be held back under exemptions, but only case by case, and with a reason you’ve written down. Safeguarding records need particular care.
If you’re thinking of withholding anything beyond other people’s details, ask your denomination, safeguarding lead or an adviser first.
If you refuse all or part of a request, tell the person why, and that they can complain to you and to the ICO. Our GDPR guide for churches has more on people’s rights.
Questions churches ask
- How long does a church have to answer a subject access request?
- One month from receiving it. You can extend by up to two more months for a complex request, as long as you tell the person why within the first month.
- Can we charge for answering a request?
- Usually not. You can only charge a reasonable fee if a request is manifestly unfounded or excessive, or for extra copies.
- Do we have to include pastoral notes?
- They’re covered by the request, so you must search them. You may need to remove details about other people, and some information can be held back under exemptions. Get advice if you’re unsure.
- What if a parent asks for their child’s information?
- The information belongs to the child. If the child is mature enough to understand their rights, respond to them. Otherwise a parent can usually act for them, as long as it’s in the child’s best interests.
Read next
- Subject access request template letter
- GDPR for churches: a plain-English guide
- Help: when someone asks about their data
- Free Gift Aid Declaration Form Template
- Free Gift Aid Sponsorship Form Template
- Free Church Privacy Notice Template
- Free Data Retention Policy Template for Churches
- Free Church GDPR Consent Form Template
- Free Data Breach Log Template for Churches
- Free Volunteer Agreement Template for Churches
- Free Church Volunteer Application Form Template
- Free Church Welcome Card Template
Sources
This template follows official guidance. It isn’t legal or tax advice, so check anything you’re unsure about with HMRC, the ICO or an adviser.
Answer the next request in one click
Church Member Software tracks each request against its deadline and downloads everything you hold about the person as one file. Private notes, such as pastoral ones, are listed for someone to check by hand first.