Annual Parochial Church Meetings, GDPR and trustee disqualification

In last Sunday’s Round-up, we mentioned the issue of Church of England parishes expressing concerns about data protection issues and the renewal of the Electoral Roll.  The C of E’s Parish Resources has now issued a note clarifying the issue, together with a reminder on the disqualification rules for charity trustees, as follows:


Many PCCs have raised concerns about the legal bases under GDPR for the processing of personal data required by the church electoral roll in accordance with the requirements set out in the Church Representation Rules (the “CRR”).

In response, the Church of England’s GDPR Team have produced guidance to clarify these issues. They have also produced an Electoral Roll Privacy Notice which explains the GDPR issues for those individuals applying to the electoral roll.  You should publish this on your website and/or give it to people who request an application form.

You can view the APCM GDPR Guidance and Electoral Roll Privacy Notice on our website.

APCM – Charity Trustees

The widening of the disqualification rules for charity trustees in s.178 Charities Act 2011 came into force in August 2018, therefore the upcoming APCMs is an important opportunity to check that all PCC members (existing and newly elected) are:

a. ‘Eligible to serve as Trustees’ (i.e. not disqualified under charity law), and that

b. HMRC would regard them as ‘Fit and Proper Persons’.

All PCC members should sign a Trustee Eligibility and Fit and Proper Persons Declaration. Click here to download.”

For further and better particulars, see:


Although the guidance is aimed at Church of England PCCs, the principles probably apply equally to any denomination in which congregations elect councils whose members act as the congregation’s trustees. HMRC’s guidance on the “Fit and Proper Person” test is here. The Charity Commission’s guidance on disqualification starts here.

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