Balancing Test Summary

A Balancing test assesses the legitimate interest of an employer to process employee data and is a requirement whenan employer's legal basis for processing employee data is defined as 'legitimate interest' (under GDPR Article 6(1)(f)).

The purpose of a balancing test is to weigh the organisation’s interest in processing the data against the data subject’s rights and freedoms. It takes into consideration:

• What is the employer's legitimate interest? (e.g. fraud prevention, network security, management of staff, )
• Is the processing necessary to achieve that interest?
• Do the individual's rights override the employer's interest?

Balancing Test - Ministry Development Portal (MD)

This balancing test is conducted in accordance with Article 6(1)(f) of the General Data Protection Regulation (GDPR) to determine whether the legitimate interests pursued by the Seventh-day Adventist Church through the Ministry Development Portal (MD)/ MDLite app are not overridden by the rights and freedoms of the data subjects, namely employees and volunteers.

1. Identify the Legitimate Interest

The Ministry Development Portal (MD) is designed to support the development and administration of ministry personnel across the Seventh-day Adventist Church. The legitimate interests pursued include:

- Supporting pastoral employees and volunteers in their ministry development
- Ensuring accurate and updated records for human resource and administrative purposes
- Facilitating training, feedback, and collaboration among ministry personnel
- Meeting compliance obligations related to employment and church governance

- observing ministry activity within the MD portal in the fulfilment of role expectations

2. Assess the Necessity of Processing

The processing of personal data is necessary to achieve the above purposes. Without collecting and managing data such as contact details, ministry experience, uploaded qualifications, and role preferences, the Church would not be able to effectively support or coordinate ministry activities and personnel development. The platform provides a central, secure location for these interactions and avoids the risks and inefficiencies associated with fragmented data systems.

3. Assess the Impact on Data Subjects

The personal data processed includes names, contact details, education and ministry background, and documents such as CVs or certificates. This data is not particularly intrusive and is typical of what is required in employment and volunteer coordination contexts.

Potential risks include:
- Unauthorised access or disclosure of personal data
- Misuse of sensitive data related to religious affiliation
- Loss of trust if transparency is not maintained

Mitigation measures include role-based access control, multi-factor authentication, encryption, and the right for users to access, correct, or delete their data.

4. Weigh the Legitimate Interests Against Data Subject Rights

The legitimate interests pursued by the Church are strong and necessary for the development and operational coordination of its personnel. The data subjects are adults engaged in professional or voluntary roles within a religious organisation, and are provided with clear information about the data processing. Data minimisation and security measures are in place to ensure that the processing does not unduly impact individual rights.

Conclusion

On balance, the legitimate interests of the Seventh-day Adventist Church in operating the Ministry Development Portal outweigh the potential impact on the rights and freedoms of the data subjects. The processing is necessary, proportionate, and includes appropriate safeguards. This assessment will be reviewed periodically or if the nature of the processing changes.

This document was last updated 24th April 2025