Governance Manual

APPENDIX J. Policy documents / statements

The following documents/statements will be found below

Equality, diversity and inclusion policy
Public access to justice policy
Complaints policy (Complaints about the Faculty Office)
Appointment of board and committee members policy
Removal procedure for board and committee members
Transparency policy
Whistleblowing policy
Anti-corruption and bribery policy
Gifts and hospitality policy
Expenses policy
Publishing policy
Policy on staff with responsibilities to both the Faculty Office and to LBMW
Consultations policy – outcomes and impact
Climate issues policy
Operating reserves policy
Conflicts of interest policy
Procurement Policy
Data Protections Complaints Policy
Data Security Policy
Privacy Policy
Data Retention Policy

Equality, diversity and inclusion policy

The Faculty Office is committed to encouraging equality, diversity and inclusion amongst our team, and to eliminating unlawful discrimination.

We aim for our staff to be representative of society, and for each of our colleagues to be and feel respected and able to give their best.

The Faculty Office in providing services is committed against unlawful discrimination.

This policy’s purpose is to:

provide equality, fairness and respect for all our employees, whether temporary, part-time or full-time
not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation
oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

The Faculty Office commits to:

Encourage equality, diversity and inclusion in the workplace
Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all
Take seriously any complaints of bullying, harassment, victimisation and unlawful discrimination by fellow staff members and any others in the course of the organisation’s work activities
Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential
Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act)
Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law
Monitor the make-up of the staff team regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability, encouraging equality, diversity and inclusion

The Registrar keeps the effectiveness of this policy under review and advises the Master accordingly.

Public access to justice policy

What we mean by ‘access to justice’

‘Access to justice’ is the acting out of the rule of law in particular or individual circumstances. The tools to achieve that outcome range from informing the public about their rights, through routine transactional legal services and personalized advice, through to action before tribunals and courts. The agents of delivery are wide and, of course, legal professionals are at the heart of this along with many other actors in legal services and the wider justice sector.” (LSB Regulatory Objectives 2010)

Improving access to justice is one of the Regulatory Objectives set out in the Section 1 of Legal Services Act 2007 which the Faculty Office with the other approved regulators have a duty to promote.
In this context the Faculty Office understands “access” to encompass services delivered through any channel such as face-to-face, telephone or internet and both individually tailored and those tailored to groups or more generally provided to potential consumers. Similarly, “justice” means more than a traditional sense of access to legal services. Justice is more than the resolution of disputes: it includes just relationships underpinned by law; justice is under-pinned by legal knowledge, legislative frameworks, dispute resolution and the infrastructure of the legal services market.
The Faculty Office aims to ensure that consumers can easily access the services they need and, where possible, have a meaningful choice of notary who is appropriately qualified and has the requisite legal knowledge to provide those services; by whom they are are treated fairly, including in particular where they are vulnerable, in terms and conditions, during disputes and complaints, and in being protected against any conflicts of interest and also to have their needs met by a diverse profession which reflects the community it serves.
We will aim to achieve this by:
1. Seeking to remove unnecessary barriers to entry to the profession;
2. Ensuring that notaries are adequately qualified both at the point of entry and remain competent through ongoing education;
3. Ensuring that notaries comply with the information transparency obligations on price, service, redress, complaints and regulatory status;
4. Seeking to promote the equality, diversity and inclusivity of the profession.

We recognise that in a small profession it will not always be possible to ensure that every consumer has immediate access to the services of a notary (or choice of notaries) in a location which is convenient or at a price that is ‘acceptable’ to them and we acknowledge that notarial services by their nature specialised and are normally only required when a consumer is dealing with assets, doing business, seeking employment or intending to travel overseas; they are rarely ‘distress purchases’.

Complaints policy (Complaints Against the Faculty Office)

The Faculty Office is responsible principally for the appointment and regulation of approximately 750 public notaries in England and Wales and for the grant of the Archbishop’s Special Marriage Licence. The Faculty Office consists of a small team which is committed to operating in a trustworthy, sensible and correct manner. In its dealings with the public it is committed to being helpful, polite, effective and efficient. The Faculty Office commits to not discriminating against members of the public on the basis of age, disability, gender identification, marriage and civil partnership, pregnancy and maternity/paternity, race, religion or belief or sexual orientation. Where it does not perform in this way, it welcomes expressions of concern so that failings can be addressed, and complaints resolved.

This policy covers complaints made against the Faculty Office as a whole or members of its staff. It is not intended to cover complaints about individuals notaries, for which there are separate rules – see our guidance

Complaints Policy – Complaints About the Faculty Office

Last revised: June 2026

The Registrar keeps the effectiveness of this policy under review and advises the Master accordingly.

Appointment of board and committee members policy

Members of the Faculty Office committees and boards are selected giving due regard to the principles set out by Lord Nolan while chairing the Committee on Standards in Public Life: selflessness, integrity, objectivity, accountability, openness, honesty and leadership. The Nolan Principles are laid out in appendices for reference.

The policy on Equality, diversity and inclusion (see 5.1 above) is a central principle in recruiting board and committee members.

Support for, and appropriate understanding of, the work of the Faculty Office is important, as is expertise and professional reputation, all of which are considered when considering the composition of the board.

Each board or committee keeps under review a skills audit, which highlights the needs of each group. The needs of each group can change over time, and the audit is used by the Registrar in identifying the right mix of nominations for vacancies as they arise.

Nominations for membership of a board or committee are formally presented to the Master by the Registrar. In arriving at appropriate nominations, the Registrar will liaise with each board or committee, in order that members of each group are able to submit nominations.

Vacancies for roles on boards and committees are also advertised openly, via the Faculty Office web site and other open channels appropriate to the vacancy concerned.

Interviews for all vacancies are conducted openly, with regard to the skills audits and policies in place at the time, also having appropriate regard for expertise and professional reputation. Appropriate records of interviews, along with any decisions, are retained for a reasonable period.

There are cases where established Rules require that there is representation from specific external groups (the presence of the Secretary of each of the two notarial societies on the Advisory Board being an example).

When there is a vacancy amongst those representational places, the Registrar will liaise with the holders of those roles to ensure that the Faculty Office’s expectation that the holders of these representational places do not expect or exert undue influence is understood.

The Registrar keeps the effectiveness on this policy under review and advises the Master accordingly.

Removal procedure for board and committee members

The performance the various boards and committees, and members thereof, is kept under review by the Registrar, to ensure they are effective in meeting their terms of reference (in some cases Rules).

Should the Registrar have any concerns as to the performance of any board or committee member, this is brought in the first instance to the attention of the chair of the board or committee concerned for consideration and action as required.

Should the issue go unresolved, the Registrar will bring the issue to the Master for review.

The Master will, as appropriate, arrange for any investigations to be carried out and will consider the outcome of these investigations.

The removal of any board or committee member is a decision solely for the Master, other than in the case of members whose presence is representational.

Should the Master have serious concerns regarding an individual holding a representational position, the matter will be reviewed with the organisation being represented and an agreed position sought between the Master and the organisation concerned.

The Registrar keeps the effectiveness on this procedure under review and advises the Master accordingly.

Transparency policy

The aim of this policy is to confirm the Faculty Office’s intention to be transparent and open in our activities with stakeholders, and how this is put into practice.

Within the Faculty Office there are three main categories of information:

Public information – this information is made available to all stakeholders on the Faculty Office website, in public documents and via other forums as appropriate

Internal information – this information made available to stakeholders within the Faculty Office via normal internal business systems

Confidential information – this information is in some way sensitive and/or personal, and is only available to appropriate stakeholders. This information may in some cases be made more widely available, with sensitive and/or personal information redacted as appropriate.

The Registrar keeps the effectiveness on this policy under review and advises the Master accordingly.

Whistleblowing policy

Introduction

The Faculty Office appoints and regulates public notaries in England and Wales. It is responsible for taking action when a notary has been found out to have committed misconduct. It is also the supervisor for anti-money laundering within the notarial profession.

Concerns about notaries

If you wish to make a complaint against a notary please refer to the Service and Conduct Complaints information on this website. In the first instance, a complaint will normally be made to the notary in question, but if that is not appropriate for some reason please contact the Faculty Office where advice can be given about how to further pursue your complaint.

Some concerns about notaries are difficult to raise openly, particularly when it is a member of staff of the notary who is concerned. If you have a concern about the activity of a notary or someone working for or with a notary about serious misconduct or recklessness which you cannot raise directly with the notary, the Faculty Office may be able to help you. We strongly encourage responsible and lawful reports to us of serious misconduct and serious risks at the earliest possible stage. Your prompt report could be vital in protecting the public from reckless or dishonest behaviour.

You may contact us by letter, phone on 020 7960 7126 or emailing the contact details listed on the Faculty Office website here. Write to or ask to speak to the Chief Clerk, the Registrar or the Deputy Registrar.

If your concern relates to the proceeds of crime, terrorist financing or breach of the antimoney laundering regulations you can report this directly to the National Crime Agency and about any criminal matter more generally, to the police. You can also raise your concerns with the Faculty Office. We would want to hear from you. The Faculty Office will then refer your concerns to the National Crime Agency or to the police, in which case it will seek to respect your wish for (but cannot guarantee) anonymity insofar as it is legally allowed or it is possible to do so.

Disclosure reporting process

To assist individuals in making a report, the following step-by-step process may be followed:

Identify the concern – Consider whether the matter involves serious misconduct, recklessness, or a breach of legal or regulatory obligations, including anti-money laundering requirements.
Consider internal reporting – Where appropriate, raise the matter with the notary or within the organisation, unless this is not possible or appropriate.
Prepare the information – Gather relevant details, including dates, individuals involved, and any supporting evidence. Reports should be factual and made in good faith.
Make the report – Contact the Faculty Office using the details above and address your report to the Chief Clerk, Registrar or Deputy Registrar. Reports may be made openly or, if necessary, on a confidential basis.
Consider external reporting obligations – Where the concern relates to criminal activity, including money laundering or terrorist financing, you may also report directly to the National Crime Agency or the police.
Co-operate if contacted – You may be asked to provide further information. In some cases, it may be necessary to discuss whether you are willing to be identified to support further action.

How we will deal with your report

We will deal with your report sensitively and if information is provided to us on a confidential basis we will take appropriate steps to protect your identity. It would be our expectation that information normally be provided to us openly as to withhold the source of the information or something about it can hinder a transparent and thorough investigation. However, if you wish your report to remain confidential please tell us. Normally this will be because you are an employee of a notary and would be fearful of being dismissed or otherwise disadvantaged by raising a concern openly. Protections against dismissal and other detriment are also available under the Public Interest Disclosure Act 1998 for employees who raise certain concerns with their employer.

In some cases we will need to discuss with you whether you are prepared to be identified at some stage. For example, depending upon the facts of the case, we may have difficulty in taking enforcement or disciplinary action without formally and openly relying upon evidence from you.

Notaries who we regulate are required to report such matters to us in any event. However, if you are a notary and are concerned about whether you may be investigated for your own part in any wrongdoing, reporting the issues and co-operating with us could constitute significant mitigation. This is particularly so where issues are reported to us at an early stage. Late reports could, however, also constitute mitigation. We would rather see notaries and those working in notarial practices providing information late than not at all. Although we cannot guarantee that we will not take any action against you, bringing the information to us is likely to help your position considerably.

Where information is clearly untrue, or is being disclosed for personal gain rather than to address a genuinely held concern which requires the help and intervention of the regulator we reserve the right to take no further action. We may also not be able to tell those who bring forward concerns and information what action we will be taking, where an investigation is ongoing and would be prejudiced by telling the person who provided the information what is happening. Otherwise we shall seek to keep the person informed either from time to time or at the end of the investigation.

Last reviewed June 2026

Anti-corruption and bribery policy

The Faculty Offices is committed to conducting business in an honest and ethical manner. We act professionally and with integrity in all of our activities.

This policy applies to everyone who works for the Faculty Office or on its behalf in any role, including those who give their time on a voluntary basis.

Bribe means a financial or other inducement or reward for action, which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit that is intended to influence a decision or action.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

Corruption means any form of abuse of power for business and/or personal gain and may include, but is not limited to, bribery.

All forms of bribery are illegal. If anyone who works for us or on our behalf in any role is unsure about whether a particular act constitutes bribery, they should raise it with the Registrar.

Specifically, anyone who works for the Faculty Office or on its behalf in any role must not:
give or offer any payment, gift, hospitality or other benefit in the expectation or hope that a business advantage will be received in return, or to reward any business received
accept any offer which is made with the expectation that the Faculty Office will provide a business advantage for them or anyone else
give or offer any payment to a government official in any country to facilitate or speed up a routine or necessary procedure
engage in any other activity that might amount to bribery or corruption or otherwise lead to a breach of this policy
Anyone who works for the Faculty Office or on its behalf must not threaten another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
If anyone who works for the Faculty Office or on its behalf is offered a bribe, or is asked to make one, or if they suspect that any bribery, corruptio or other breach of this policy has occurred or may occur, they must notify the Registrar or report it in accordance with the Whistleblowing

Gifts and hospitality policy

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes.

A gift or hospitality will not be appropriate if it could be seen as an inducement or reward for any preferential treatment.
Gifts must be of an appropriate type and value depending on the circumstances. Gifts must not include cash, or be given in secret.
Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

Anyone who works for the Faculty Office or on its behalf in any role must declare and keep a written record of all hospitality or gifts given or received.

Expenses policy

This policy applies to all officers and employees of the Faculty Office. It is a framework that covers how reasonable and authorised expenses that are incurred can be claimed and reimbursed.

All officers and employees are expected to behave honestly, responsibly and within the guidelines of this policy; to submit expenses as soon as possible and with enough details to explain why they have made the purchase; and to keep all receipts and provide VAT receipts.

The Faculty Office has a zero tolerance approach to bribery and fraud (see Anti-corruption and bribery policy at 5.9 above)

Travel related expenses:

Mobile phones and internet connectivity – use free wi-fi whenever possible. Reasonable internet connectivity charges can be added to a hotel bill unless already included as part of the negotiated rate

Air, rail and road-travel – all bookings should be made in economy/standard class (unless the economy/standard price can be beaten by booking early, in which case higher classes are acceptable).

Mileage – you can claim up to 45p/mile. You must also be insured for using your car for business purposes.

Taxis – always try to use public transport instead of taxis (unless you are in an unsafe area or travelling late at night). Always keep a receipt that includes the date. You cannot claim trips from home to work.

Car hire – you can rent cars if it is more cost-effective than taking public transport (or if it is not practical or public transport is not available to reach your destination)

Accommodation – if you are required to stay away from home (either in the UK or abroad) or if it is not possible/unreasonable to get home after a business related event, you can book an appropriate and reasonable hotel.

Duty of care: This is important! Always inform others of your overnight location so we can comply with duty of care requirements. Tell your line manager (or another member of staff if they are away).

Per diems – these cover costs for meals when away from the office on business.

Additional travel related expenses – the following travel related expenses are acceptable and will be reimbursed: baggage (no more than 2 bags) and advanced seat bookings; parking; foreign currency charges; Visas; Tips (up to 15% – unless already included in the bill).

Remote working expenses – the following expenses are acceptable to claim where officers or staff of the Faculty Office are working from home (and restrictions or conditions will be stipulated next to each item:

Laptops, computers, screens, keyboards, printers and other necessary computer equipment (unless provided direct by the Faculty Office and prior approval must be obtained from the Registrar before purchases are made)
Office furniture including chairs, standing desks and other ergonomic equipment (prior approval must be obtained from the Registrar before purchases are made)
Broadband internet connection (unless already acquired for personal use)
Mobile and landline telephone bills (if not already provided by the Faculty Office and the business proportion only)
Stationery and resources (eg printer cartridges) necessary to conduct business (if these cannot reasonably be collected from the office when in attendance)

Other expense types – the following expenses are acceptable and Faculty Office officers and employees will be reimbursed for them:

Professional/Society/Club membership fees (where relevant to your employment and agreed with the Registrar in advance)
Postage for business purposes
Magazine/Periodical Subscriptions (where relevant to your employment and agreed with the Registrar in advance)
Annual eye-testing charges
Visas

Exceptions – the following travel and remote working expenses will not be reimbursed:

Any items for personal, non-business use
Bar bills*
Birthday cakes or cards for employees
Childcare or pet care
Clothing (except legal attire for use as part of your duties)
Damage to personal vehicles
Flowers, sweets, confectionery
Food/drink outside of travel subsistence unless agreed by the Registrar
Laundry service/dry-cleaning (unless trip is longer than 4 nights)
Mini-bar contents
Parking fines
Spa and health/fitness clubs or subscription services
The loss/theft of goods (except where covered by insurance taken out by the Faculty Office or LBMW LLP as appropriate)
Tourist attractions*
Travel to/from home and the office (except as stated above)

*you can claim these if the event is part of an approved entertainment/hospitality event

There may be other things that will not be reimbursed, so make sure you explain the business reason for each claim. The Registrar and the Finance Officer keep the effectiveness of this policy under review and advise the Master’s Audit Committee accordingly.

Publishing policy

The Faculty Office is committed to acting in a way that is open and honest about what we do, how we work and how decisions are made.

We do this through our overarching publishing principle that all Faculty Office documentation should be published openly, unless there is a compelling reason not to publish.

Published documentation is made available in a timely manner, to enable stakeholders to consider documentation in the context to which it relates

Compelling reasons are normally to protect the personal details of individuals, for business confidentiality or due to complex ecclesiological issues.

In some cases, it is possible to overcome such concerns by publishing some documentation with redactions.

That commitment extends, but is not limited, to the following:

Business plan/Master’s Priorities
The Master’s Annual Address
The Registrar’s Annual Report
The agenda, minutes and papers for each of the four Faculty Office boards and committees (The Master’s Council, The Master’s Audit Committee, the Advisory Board and the Qualifications Board)
The membership of each of the four committees and boards
Policy documents
The status of each key performance indicator (listed in appendices)
The outcomes and impact of any consultations undertaken with the profession
Engagement strategy with consumers
Financial statements
Decisions of the Court of Faculties following disciplinary hearings
Register of practising notaries

Policy on staff with responsibilities to both the Faculty Office and LBMW

(Conflicts of interest policy)

Overview

All staff of the Faculty Office are jointly employed by the Faculty Office and Lee Bolton Monier-Williams LLP (“the Firm”) with which the Faculty Office has a shared services agreement. For staff to avoid, declare and manage conflicts of interest between these respective organisations the following policy has been devised.

Principles

Staff to act in the best interests of the Faculty Office and the Firm
For the division of time and effort between the two bodies to be understood so that neither body lose out financially or in human resource
For conflicts of interest to be identified and resolved

Practicalities

The following practical points are designed to further the principles. The detailed agreement between the Faculty Office and the Firm is set out in the common services agreement between the two entities.

2.1. The Firm at the reasonable request of the Faculty Office jointly employs such persons who are required to discharge work for the Faculty Office.

2.2 The two bodies jointly determine the job specification and contract of employment of each jointly employed member of staff including the estimated proportion of time which may be spent devoted to work for the Faculty Office (which may be as much as 100%).

2.3 Staff members are expected to discharge their responsibilities when working on Faculty Office or Firm work to the best of their ability and efforts.

2.4 Staff members must notify their line manager if they consider that their ability to discharge their responsibilities for one of the employers is being impaired by demands placed upon them by the other, or their loyalty to one is being tested by the loyalty to the other.

2.5 The split in responsibilities and the question of conflicts will be explored at every appraisal and end of probationary period.

2.6 If a member of staff wishes to raise a whistleblowing concern about the operation of this policy they may speak to the Master of the Faculties, the chair of the Master’s Advisory Board, a trade union representative or the Legal Services Board. (see also the Whistleblowing policy)

2.7 The employee handbook and other policies and procedures of the Firm as regards human resource matters including such matters as holidays, sickness, grievances and discipline apply to all jointly employed staff and the Firm shall not make changes to the handbook and other policies and procedures without reasonable consultation with the Faculty Office.

2.8 Jointly employed staff are line managed by the Registrar of the Faculty Office when engaged on Faculty Office work and by the relevant Head of Department or Practice Manager when engaged on work for the Firm (although normally the relevant Head of Department will be the head of the Ecclesiastical, Education and Charities Department who is also the Registrar of the Faculty Office).

2.9 All jointly employed staff aside than secretarial, administrative or general office staff record their time on the centralised system operated by the Firm so that it is known what the split is between Firm and Faculty Office work and the sub-categories of work listed for each party.

2.10 Where employment issues concern both the Firm and the Faculty Office, for example through performance management and disciplinary concerns, the Firm and Faculty Office liaise to ensure that the interests of both employers are taken into account whether by forming a committee of two or more representatives of both parties or by appointing a single agreed representative of both employers.

2.11 Where the actual time incurred by a staff member on their respective responsibilities differs from the agreed proportion, there is an adjustment in the level of the management charge paid by the Faculty Office to the Firm at the end of each period.

2.12 The Firm will not employ or take on a client who is a practising notary.

Date: 13^th January 2022

Consultations policy – outcomes and impact

Our approach to consultation

Purpose

This policy sets out the Faculty Office’s approach to consultation in relation to policy development and changes to our regulatory framework. By consultation we mean early and informal discussion (this includes pre-consultation – the phase of engagement before proposals are fully formed) as well as formal written consultations on proposals for change or reform.

It is intended to provide stakeholders with an understanding of how they can expect to engage with us when we make any change to our regulatory arrangements.

Why we consult

We are committed to developing policy in a clear and transparent way and in accordance with best practice principles. The Legal Services Act 2007 requires us to ensure that our regulatory interventions are transparent, accountable, proportionate, consistent and targeted; and to ensure that best regulatory practice is adopted.

Open and effective consultation is a critical part of policy development. That includes early consultation through informal discussion as well as formal written consultations. Our work impacts on a number of individuals and organisations, including the regulated community, consumers and and, sometimes, other regulatory bodies. Effective consultation offers the best means of identifying any potential unintended effects and of hearing alternative suggestions and perspectives on our proposals. By inviting a broad range of views, we are able to test and develop our ideas to reach the best possible policy outcome.

Our approach

We believe a flexible approach to consultation is needed whereby we consider which approach will yield the best response in each set of circumstances. Formal written consultation is just one tool for inviting stakeholder views and while extremely valuable, may not necessarily always be the most appropriate or only method of consultation. Stakeholders can therefore expect us to take a broad view of what constitutes consultation and for it to become part of our ongoing policy development. For instance, other forms of consultation such as face-to-face discussions or correspondence with key stakeholders may provide an effective way to gather views and collect evidence. We expect this to be particularly likely at the earlier stages of policy development or as we refine the final details in discussion with those directly affected. Early discussion with stakeholders might include consumer groups, representative bodies and those most directly affected by change.

A flexible approach whereby the nature and format of consultation can be tailored to each set of circumstances is likely to take account of a range of factors:

a. The nature and scale of the proposed change

How much of a change will it be for the regulated community and/or consumers of regulated legal services? Is new regulation being imposed or are regulatory burdens being removed?

b. Who will be affected by the proposed change

Will all of the regulated community be affected? What will be the impact on consumers? Are there any impacts in relation to other professions or regulatory frameworks?

c. Timing

What is the timetable for the changes as there may be external drivers beyond our control that we need to be in a position to respond to? How long will those affected have to prepare for the change? Will it be a single consultation or multiple? What else might we be consulting on at the same time?

d. Nature and extent of any previous consultation

Is this the first time we have consulted on the issue? Have we undertaken ‘informal’ consultation by meeting with those affected or setting out the direction for future changes in speeches or other public documents?

e. Recognition of major holiday periods

Does our proposed consultation fall over a major holiday period and does the length of the consultation still allow for proper consideration?

While we consider that formal written consultation in itself may not always necessarily be the best way of generating meaningful responses or gathering evidence, it will continue to play a very important role. Publication of written consultation documents is familiar, transparent and easily shareable across the wider stakeholder community. This is particularly important where there may be unintended or unforeseen impacts.

We therefore consider that formal written consultation will continue to be a central element of our approach in the majority of areas. However, to ensure the most effective engagement, we will consider whether to undertake more targeted forms of consultation alongside and ahead of this. In assessing the right length of consultation we will consider the whole approach rather than a narrow focus on the written consultation period.

In considering the length of the consultation period, we will take account of the criteria set out above. This takes account of Cabinet Office guidance requiring timeframes for consultation to be “proportionate and realistic” and dependent on the “nature and impact of the proposal”. We note that the guidance anticipates the length of time for written consultation to typically vary between 2 and 12 weeks. We are required by the Legal Services Act to follow best regulatory practice.

All written consultations will be made available on our website, they are also likely to be featured on our Twitter feed and circulated formally by email to relevant stakeholders including, but not limited to, our regulated community. We will also make clear the length of the consultation period and any other means by which stakeholders can engage with us.

Equality Diversity and Inclusion

As part of our commitment to equality, diversity and inclusion we will consider the impacts of proposals as they are developed. We are also conscious that the equality, diversity and inclusion agenda has even more significant impacts on consumers. By consulting we can consider all views and opinions in producing high quality regulatory arrangements. We can ensure that there are no unintended consequences and that no individuals or parties are adversely impacted by our rules and regulations.

Faculty Office response

The Faculty Office will publish a response to the consultation responses which may include publishing in full or in part the responses received (save where confidentiality has been requested or is otherwise appropriate) in a timely manner following conclusion of the consultation period.

There may be instances where the approach we adopt is not welcomed by the regulated community but by consulting and then responding all parties can understand the issues and concerns.

Reviewed June 2026

2030 Net Zero carbon target policy

The Faculty Office supports as a matter of policy the Net Zero carbon target approved by General Synod in February 2020, and will work alongside other parts of the Church of England to deliver that target.The Synod recognises that the global climate emergency is a crisis for God’s creation, and a fundamental injustice.

The Faculty Office accepts its responsibility in this regard and will work, as the Synod expects, from 2022 to achieve year-on-year reductions in emissions. As suggested by the Synod, the Faculty Office will address progress towards net zero emissions every three years.

The Faculty Office will give appropriate consideration to the work of the Synod’s Environment Working Group as it develops new insights and recommendations in this important area.

Operating reserves policy

THE FACULTY OFFICE OF THE ARCHBISHOP OF CANTERBURY RESERVES POLICY: Operating Reserve (Regulatory)

Background

The Faculty Office of the Archbishop of Canterbury (the Faculty Office) is a Company Limited by Guarantee registered in England & Wales (company no. 12221896). The Board of Directors is comprised of The Master of the Faculties (Morag Ellis QC), the Registrar (Howard Dellar), the Deputy Registrar (Ian Blaney) and the Chief Clerk (Neil Turpin). The Master of the Faculties is the sole Member of the company and the ultimate controlling party. The Master has appointed an Audit Committee comprising independent members to review the governance of the Faculty Office and in particular the financial oversight.

Purpose

The Faculty Office has various functions which need resourcing, but this policy covers its regulatory role in relation to public notaries only and the income and expenditure attributable to that which are separately accounted for. The purpose of the Operating Reserve Policy for the Faculty Office is to ensure the stability of the mission, initiatives, employment, and ongoing operations of the organisation as it relates to public notaries within the Permitted Purposes pursuant to Section 51(2) of the Legal Services Act 2007. The Operating Reserve is intended to provide an internal source of funds for situations such as a sudden increase in expenses, one-time unbudgeted expenses, unanticipated loss in funding, or uninsured losses. The Reserve may also be used for one-time, nonrecurring expenses that will build long-term capacity, such as staff development, research and development, or investment in infrastructure. Operating Reserves are not intended to replace a permanent loss of funds or eliminate an ongoing budget gap. It is the intention of the Faculty Office for Operating Reserves to be used and replenished within a reasonably short period of time. The Operating Reserve Policy will be implemented in concert with the other governance and financial arrangements of Faculty Office and is intended to support the goals and strategies contained in these related policies and in strategic and operational plans.

Definitions and Goals

The Operating Reserve Fund is defined as a designated fund set aside by action of the Board of Directors at the Direction of the Master of the Faculties. The minimum amount to be designated as Operating Reserve will be established in an amount sufficient to maintain ongoing operations and programs for a set period of time, measured in months. The Operating Reserve serves a dynamic role and will be reviewed and adjusted in response to internal and external changes.

The target minimum Operating Reserve Fund is equal to six months of average operating costs. The calculation of average monthly operating costs includes all recurring, predictable expenses such as salaries and benefits, occupancy, office, travel, initiatives, and ongoing professional services. Depreciation, in-kind, and other non-cash expenses are not included in the calculation. The calculation of average monthly expenses also excludes some expenses one-time or unusual expenses and capital purchases. The amount of the Operating Reserve Fund target minimum will be calculated each year after approval of the annual budget, reported to the Master’s Audit Committee and the Board of Directors, and included in the regular financial reports. Accounting for Reserves The Operating Reserve Fund will be recorded in the financial records as the Faculty Office Operating Reserve. The Fund will be funded and available in cash or cash equivalent funds. Operating Reserves will be commingled with the general cash and investment accounts of the Faculty Office.

Funding of Reserves

The Operating Reserve Fund will be funded with surplus unrestricted operating funds. The Board of Directors may from time to time direct that a specific source of revenue be set aside for Operating Reserves.

Use of Reserves Use of the Operating Reserves requires three steps:

Identification of appropriate use of reserve funds.

The Registrar and staff will identify the need for access to reserve funds and confirm that the use is consistent with the purpose of the reserves as described in this Policy. This step requires analysis of the reason for the shortfall, the availability of any other sources of funds before using reserves, and evaluation of the time period that the funds will be required and replenished.

Authority to use operating reserves

The Registrar will submit a request to use Operating Reserves to the Board of Directors. The request will include the analysis and determination of the use of funds and plans for replenishment. The Faculty Office’s goal is to replenish the funds used within twelve months to restore the Operating Reserve Fund to the target minimum amount. If the use of Operating Reserves will take longer than 12 months to replenish, the request will be scrutinized more carefully. The Board of Directors will approve or modify the request and authorize transfer from the fund.

Reporting and monitoring.

The Registrar is responsible for ensuring that the Operating Reserve Fund is maintained and used only as described in this Policy. Upon approval for the use of Operating Reserve funds, the Finance Officer will maintain records of the use of funds and plan for replenishment. He/she will provide regular reports to the Board of Directors and the Audit Committee of progress to restore the Fund to the target minimum amount.

Review of Policy. This Policy will be reviewed every other year, at minimum, by the Master’s Audit Committee, or sooner if warranted by internal or external events or changes. Changes to the Policy will be recommended by the Master’s Audit Committee to the Board of Directors.

Conflicts of interest policy

Overview

All staff of the Faculty Office are jointly employed by the Faculty Office and Lee Bolton Monier-Williams LLP (“the Firm”) with which the Faculty Office has a shared services agreement. Potentially there could be a conflict between the duty that staff members have to the Faculty Office and that which they owe to the Firm. Conflicts of interest (or loyalty) may also arise in other ways, where other interests or loyalties of staff members could interfere with their duty to act in the best interests of the Faculty Office. For staff to avoid, declare and manage conflicts of interest between these respective organisations and outside interests the following policy has been devised.

Such conflicts may create problems including:

inhibiting free discussion
staff being taken away from a single-minded pursuit of the objectives and work of the Faculty Office or the Firm or both
making decisions or actions that are not in the interests of either the Faculty Office or the Firm or both
risking the impression that the Faculty Office has acted improperly.

Principles

Staff to act in the best interests of the Faculty Office and the Firm

For the division of time and effort between the two bodies to be understood so that neither body lose out financially or in human resource
For conflicts of interest to be identified and resolved

Practicalities

The following practical points are designed to further the principles.

Avoiding conflicts of interest between the Faculty Office and the Firm

The detailed agreement between the Faculty Office and the Firm is set out in the common services agreement between the two entities.
The following table should be used by the Faculty Office annually as part of the review envisaged by the common services agreement.
When making decisions about procurement of a service that could be provided externally, the procurement policy should be used.

	Questions	Yes/No
1.	Are we receiving the service set out in the Agreement to Provide Services
2.	Are the Faculty Office Team delivering the quality of expertise we would expect?
3.	Do the office facilities meet our requirements?
4.	Do we feel the cost is reflective of the service being provided?
5.	Is the management charge calculated without errors?
6.	Has the audit identified control issues that should have been addressed?
7.	Are the accounting records accurate and kept up to date?
9.	Do we believe potential conflicts of interest are managed effectively?
10.	Are we getting value for money?

Staff with joint responsibilities

2.1. The Firm at the reasonable request of the Faculty Office jointly employs such persons who are required to discharge work for the Faculty Office.

2.3 Staff members are expected to discharge their responsibilities when working on Faculty Office or Firm work to the best of their ability and efforts.

2.5 The split in responsibilities and the question of conflicts will be explored at every appraisal and end of probationary period. There will be separate opportunities in the staff appraisal form to look at developmental objectives for each organisation.

2.12 Variations over 5% will generally be looked at to understand whether the variation has come about because of a disproportionate amount of time being spent for one of the two organisations and such a variation will then be addressed by the organisations.

2.13 The Firm will not employ or take on a client who is a practising notary.

2.14 All staff must be aware that information that they receive in the course of their work for one of the organisations may be confidential and therefore not capable of being shared with the other organisation. If in doubt, ask!

Avoiding conflicts with personal and business interests

To minimise risks arising from any potential conflict of interest and to protect the two organisations and their staff, staff are required to declare their interests, and any gifts or hospitality offered and received in connection with their duties or role in the organisation. There are separate gift and hospitality and anti-bribery policies for both organisations.

If staff are not sure what to declare, they should err on the side of caution.

If staff would like to discuss this issue, they should contact the Practice Manager.

Q & A – A Guideline to Avoid Conflict of Interest generally

When can we confront a conflict of interest?
What are conflicts of interest?
Are conflicts of interest wrong?
What are the dangers with conflicts of interest?
How do you overcome conflicts of interest?
How does your supervisor overcome your conflict of interest?
Using common sense.

The following guidelines are designed to answer the above questions.

Question: When can we confront a conflict of interest?

Answer: Whenever! In our routine work conflicts of interest can arise at any time. For example, you are:

a committee member responsible for recruiting staff and you become aware that one of the candidates is your cousin;
a member or chair of a tendering panel and you become aware that one of the competing contractors is an in-law;
working in recruitment or procurement, you find that one of the contracts that requires signing involves an old friend; or
a director / head in a particular field and your spouse or children own shares or have an interest in one of the contractors that you use.

All these situations represent a conflict of interest.

Question: What are conflicts of interest?

Answer: a conflict of interest occurs when you, as an employee, face a dilemma of “loyalties” that either are, or potentially can be, at odds with each other. A conflict of interest causes an individual to experience a struggle between diverging interests, points of view, or allegiances, as evidenced in the examples above.

Taking the example above of a committee member responsible for recruiting staff becoming aware that one of the candidates is your cousin. Here there is a potential conflict of interest; it is likely that the employee would want to recruit their cousin to the vacant position. Under this Policy the employee should disclose the potential conflict of interest, and it is likely that they will be unable to participate in recruitment for that role. If the cousin is the best candidate, they will be selected to the role on merit and not due to their association with a current employee.

The most common conflicts of interest are related to nepotism and collusion. Dealing with conflicts of interest is a most effective strategy to wipe out nepotism.

Question: Is a conflict of interest wrong?

Answer: In short – no. Indeed, during our day-to-day activities the emergence of a work-related dilemma can be a common problem.

The issue of conflicts of interest begins to become a problem if you decide to say nothing when you become aware of a conflict of interest, meaning that it cannot be effectively dealt with, and the organisation may be in breach of its obligations. Moreover, once you make the decision to favour the particular interest then you fall into a dangerous ethical trap. Additionally, this behaviour represents one form of criminal corruption.

Question: What are the dangers with conflicts of interest?

Answer: If a staff member or volunteer acts contrary to the provision of this Policy, for instance, by not declaring a conflict of interest and making a decision that favours their own interests (or the interests of their family and friends), they will have breached an important obligation owed to the organisation. Their actions may be seen as an assault on the common trust that the organisation put in them.

There is also a risk that the organisation’s reputation will be negatively affected. Such actions would hurt the interests of an organisation like the Faculty Office which works in the public interest and in the public eye. This behaviour could very quickly disturb the smoothness and even legitimacy of the overall work of the Faculty Office.

Question: How do you overcome a conflict of interest?

Answer: The short answer to this question is that it depends on the situation and the case.

Having said that, there is one step that you must take every time as soon as you are aware that you are facing a conflict of interest, and that is reporting directly to HR that you are confronting a conflict of interest and require clarification and a solution to the situation.

Moreover, there is no need to wait until you are convinced that you face a conflict of interest. It is enough that once you feel there is a potential conflict of interest, that you declare it. Do not wait to report the issue later – because later may already be too late!

For example, you are in a meeting to select a new staff member. At that meeting you find out that one of the candidates is your sibling. You explain the situation to the meeting’s committee and request an appropriate solution. This explanation along with the agreed follow up (that is resolution of the conflict of interest) will be recorded formally in the meeting’s minutes. It will then be for the organisation to progress matters as it deems appropriate.

For efficiency and speed, use e-mail providing your explanation and request a solution.

Question: How does your line manager overcome your conflicts of interest?

Answer: As a line manager, there are several ways that you can confront and overcome conflicts of interest.

The first is not to underestimate the potential for conflicts of interest. Secondly, your response and follow-up to overcome any conflict of interest should be recorded formally; for example, by being entered into the meeting minutes. A copy of this response should be submitted to HR.

Substantively there are several ways of dealing with conflicts of interest faced by staff. The first is to directly exempt the staff member from the process. For example, where there is a recruitment process, the staff member who has a conflict of interest is exempted from the process. No staff member should sit on a recruitment board that will interview a member of his/her family. If the staff member is a part of a tender committee, then one response is to exempt them from subsequent parts of the tendering process.

In practical terms, it may not always be feasible for the above solution to be applied, for example, if the person is the only expert in a particular field being reviewed. In such a situation, the staff member could become a non-voting member i.e., when the committee is aware that the expert involved has a conflict of interest, the expert can provide technical input but is excluded from voting or making decisions.

Use common sense!

How will you know when you are facing a conflict of interest? How will you know that your response in resolving your staff member’s conflict of interest is appropriate?

The following is a test of ethics that will help you determine whether what you want to, or will, do is in accordance with high principles of integrity.

Does this action violate any law?
Does this action violate the code of conduct?
If you take this action, will you feel you have done something wrong?
Would your action be difficult to justify in the eyes of the press or the community?

If the answer to one of the above questions is “yes” then it is better that you do not take the action. If you are unclear, then you should seek advice from your line manager.

Essentially, consider that what you face or what you (as a person in charge) must decide will be material for the outside world to see and read. Will your attitude and behaviour be judged well, or will it conflict with high principles of professional integrity?

Date last reviewed: April 2024

Procurement Policy

Types of supply

These fall into three main categories:

Goods and supplies – generally the Faculty Office does not purchase many goods and supplies. Most equipment, stationary, catering etc. is provided by Lee Bolton Monier-Williams under an agreement dated 21 July 2022. A small number of items are directly procured such as special stationary.

Services – a range of services such as cleaning, receptionists, administration etc. is provided by Lee Bolton Monier-Williams under the said agreement. Other services are directly procured by the Faculty Office on the basis that these services are for the Faculty Office’s sole purposes. They include the delivery of training, consultancy and legal advice.

Works – the Faculty Office occupies its office premises under the agreement with Lee Bolton Monier-Williams and no works to land and buildings are procured directly by the Faculty Office. The costs of repairs, maintenance, improvement etc. to buildings are procured by Lee Bolton Monier-Williams and recharged under the terms of the agreement.

It can be seen therefore that the provision of services is the main concern of this policy. As for goods, services and works supplied and undertaken by Lee Bolton Monier-Williams, these are wholly covered by the agreement dated 21 July 2022 and the associated value for money reviews that take place annually.

The Faculty Office is committed to achieving value for money, in terms of quality and price, for all its procurement activity. In order to achieve value for money Faculty Office will endeavour to clearly communicate its requirements and evaluation criteria, as an informed purchaser, and to establish levels of competition appropriate to the size and complexity of the purchase. Throughout the competitive process Faculty Office will also seek to adopt the highest possible standards of probity. In all dealings Faculty Office will operate the highest standards of integrity, objectivity, fairness, efficiency and professionalism. In turn, it expects contractors to adhere to these same standards. Ethics in procurement require high standards of conduct which ensure that the probity of those acting on behalf of Faculty Office and the propriety of their actions is above question. This means that:

a) all dealings should be fair and even handed
b) all processes should be open and transparent and subject to internal compliance procedures and
c) the Faculty Office policies on acceptances of gifts and hospitality to prevent corruption are followed.

Approved Suppliers

The officers of the Faculty Office will select suppliers on the basis of their capacity to provide quality, service, timely delivery and value for money.

All purchases with a value greater than £20,000 (including cumulative costs over a 12 month period) must be put out to formal tender.

The following procedures must be followed in such circumstances:

A specification will be prepared and approved at a weekly Faculty Office management meeting (including the Registrar) and sent to at least three suppliers.

The following points will be considered when deciding which tender to accept:

Contract objectives

Contract duration

Definitions

Services to be provided

Service quality
Service quality standards
Contract value (including any hidden costs) and payment arrangements
Procedure for disputes
The qualifications and experience of the supplier

The financial status of the supplier

References from other clients.
Previous experiences may be a reason to decline a tender.

Once a tender is accepted the terms and conditions and other contractual documentation should be approved at a weekly management meeting or by the senior officers of the Faculty Office by email.

Quotations

For purchases above certain values, and below the tendering limit of £20,000, a specified number of quotations will be required as follows:

£12,000 or less: Budget holders are expected to purchase objectively using catalogue prices and written quotations.
Above £12,000 but below £20,000: Three written and/or verbal quotations as appropriate.
Above £20,000: formal tender.

The decisions in each case are to be approved at a weekly management meeting or by the senior officers of the Faculty Office by email.

Receipt of Goods

All goods received should be delivered to the premises of the Faculty Office if practicable. Under the supervision of the Chief Clerk, the Faculty Office checks the goods received against the delivery note, and the delivery note is checked against the invoice and order.

Defective items or shortages are brought to the attention of the Registrar immediately.

If goods received are part of a larger order, the Chief Clerk maintains a record of how much of the order has been fulfilled.

The Chief Clerk monitors the return of damaged goods, and any applicable credit note is appended to the purchase documentation.

Best Value and Purchasing Statement

The Faculty Office is accountable for the way in which its resources are allocated to discharge its functions. The offices of the Faculty Office must seek the best possible use of its resources, in the most efficient and effective way, at a reasonable cost.

What Is Best Value?

This is defined as “the best mix of quality and effectiveness for the least outlay over the period of use of the goods or services bought”.

Best value is not solely about price. Other factors include:

Complexity and sophistication of a service being provided
Credentials of the service provider including persons involved, standing, relevant experience, reputation, insurance
Reliability of the service provider
Speed of delivery – does the provider have the capacity and willingness to act in a timely manner
Accessibility of provider (how quickly and easily is it to get answers and engage in dialogue)
“Best fit” in terms of tailoring the service to the specific parameters set by the Faculty Office
Flexibility in the event that the instructions of the Faculty Office need to change
Availability of redress in the event of deficiencies in service given

The Faculty Office will apply the principles of best value when making decisions about the allocation of resources to best promote the aims and values of the Faculty Office.

The officers of the Faculty Office

will not waste time and resources on investigating minor areas where few improvements can be achieved.
will not waste time and resources to make minor savings in costs
will not waste time and resources by seeking tenders for minor supplies and services

The pursuit of minor improvements or savings is not cost effective if the administration involves substantial time or costs. Time wasted on minor improvements or savings can also distract management from more important or valuable areas.

Payment of Invoices

It is the policy of the Faculty Office to pay all invoices by the due date and also take advantage of any discounts available for early settlement where this is to the Faculty Office’s advantage. Invoices should not be paid early as a matter of course, apart from those due for payment during long holiday periods.

Payment is only made when the following checks have been made by the Chief Clerk:

Goods or services have been received and checked against the order.
Expenditure has been properly incurred and payment has not already been made.
Prices agree with quotations, tenders, contracts or catalogue prices and arithmetic are correct.
VAT has been properly accounted for.
Discounts have been taken where applicable.

Date last reviewed: June 2024

Data Protection Complaints Policy

1. Purpose

The Faculty Office of the Archbishop of Canterbury (‘the Faculty Office’) is committed to protecting personal data and complying with applicable data protection legislation, in accordance with the UK General Data Protection Regulation (‘UK GDPR’), the Data Protection Act 2018 and the Data Use and Access Act 2025.

This Policy sets out the procedure for receiving, investigating, and responding to complaints concerning the Faculty Office’s processing of personal data.

2. Scope

The Policy applies to:

Complaints made by data subjects or their representatives regarding the processing of personal data by the Faculty Office;
Complaints concerning the exercise of data subject rights;
Complaints regarding to the accuracy, security, retention, sharing, disclosure, or other handling of personal data, and
Complaints regarding compliance with applicable data protection legislation.

This Policy does not apply to general service complaints unless they specifically concern the processing of personal data.

3. Principles

The Faculty Office will:

Treat all complaints seriously and fairly;
Investigate complaints promptly and impartially;
Maintain confidentiality throughout the complaint process;
Keep appropriate records where necessary; and
Seek to learn from complaints to improve data protection compliance

4. How To Make A Complaint

Complaints may be submitted:

By Email – Faculty.Office@1thesanctuary.com

In writing – The Faculty Office
1 The Sanctuary
London
Westminster
SW1P 3JT

By Telephone: 0207 222 5381
To help us resolve your issue quickly, please provide:

Your full name and contact details.
A clear description of what happened, staff members involved, and why you
believe your data was mishandled.
Any supporting evidence or correspondence

5. Receipt and Acknowledgement

The Faculty Office will acknowledge receipt of a Complaint within five working days where practicable.

The acknowledgement will:

Confirm receipt;
Explain the complaints process; and
Provide contact details for any further enquiries
Investigation
Complaints will be referred to the Faculty Office Data Protection Officer (‘DPO’)
or other appropriately authorised individuals for investigation.
The investigation may include:
Reviewing relevant records and correspondence;
Interviewing relevant personnel;
Assessing compliance with data protection legislation and internal policies;
and
Seeking further information from the complainant where necessary
All staff and office holders are expected to comply and cooperate fully with
any investigation.

7. Response

The Faculty Office will aim to provide a substantive response within 30 days of
receiving the compliant.

Where the complaint is complex or requires extensive investigation, the response
period may be extended by up to a further two calendar months. The complainant
will be informed of any extension any the reasons for it.

The response will, where appropriate:

Summarise the complaint;
Explain the findings of the investigation;
State whether the complaint is upheld. partially upheld, or not upheld;
Describe any remedial action taken or proposed; and
Explain any further rights available to the complainant.

8. Remedial Action

Where a complaint is upheld, the Faculty Office may take one or more of the
following actions:

Correct inaccurate personal data;
Restrict or cease unlawful processing;
Improve security measures
Amend procedures or guidance
Provide additional staff training; or
Take any other action considered appropriate to address the issue.
Escalation and External Remedies

If a complainant remains dissatisfied after receiving the Faculty Office response,
they may contact the Information Commissioner’s Office to ask them to consider
the complaint further.

Their contact details are:

The Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF

Tel: 0303 123 1113

Website: Information Commissioner’s Office

10.Record Keeping

The Faculty Office will maintain a register of data protection complaints, including:

The nature of the complaint;
Dates of receipt and response;
Investigation findings;
Actions taken; and
Outcome.

Records will be retained in accordance with the Faculty Office’s record keeping
policy

11. Monitoring the Review

The Faculty Office will review complaints periodically to identify trends, recurring issues, and opportunities for improvement.

This policy will be reviewed at least every two years, or sooner if required by changes in legislation, regulatory guidance, or organisation practice.

12.Responsibility

The Data Protection Office is responsible for advising on compliance, monitoring, implementation of the Policy, and supporting the investigation of data protection complaints.

Review Date: June 2026

Data Security Policy

Policy statement

The Faculty Office of the Archbishop of Canterbury is the “data controller” of the personal information that we hold for the purposes of the UK General Data Protection Regulation (the UK GDPR) and the Data Protection Act 2018 (the Data Protection Act).

The principles set out in the GDPR are set out in the Annex.

Data under this policy is defined as “any information related to a natural person or data subject that can be used to directly or indirectly identify that person.”

The Faculty Office aims to protect Data from all threats (deliberate or accidental) whether internal or external. It aims to ensure a proper awareness and understanding of the need for Data security.

Scope

We collect, use and share data primarily in the exercise of our legal functions. Those functions – and our powers and duties – are chiefly found in primary legislation – the Ecclesiastical Licences Act 1533, the Public Notaries Act 1843, the Courts and Legal Services Act 1990, the Legal Services Act 2007 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We also collect an use data to comply with our duties with equality legislation including the Equality Act 2010. Our legal functions generally fall within three categories:

Special Marriage Licences – for couples to marry in a particular church building where they could not otherwise obtain the correct legal permission.
Notaries – to appoint a person as a Notary and to permit them to practise.
Lambeth degrees – to award a degree to a person either after completion of the Lambeth Research Degrees in Theology or to persons who have proven themselves worthy of such distinction.

Our lawful basis for processing this information is generally to be under UKGPR Article 6 Section 1(e) and Article 9 Section 2(g) as it is necessary for the exercise of our official authority in the public interest.

The policy extends to data held on Notaries practicing within non-EU jurisdictions:

Jersey and Guernsey
Gibraltar
New Zealand and Queensland
Papua New Guinea

The policy also extends to data held on employees of and contractors to the Faculty Office. It is to be read in conjunction with our Privacy Policy and Internal Handbook.

Data security

For the purpose of this policy Data security covers:

confidentiality (prevention of the unauthorised disclosure of information),
integrity (prevention of the unauthorised amendment or deletion of information);
security (the prevention of unauthorised access to information).

Application of this Policy

This policy applies to all third parties with whom the Faculty Office shares Data. This

includes employees and contractors. This policy expressly extends to those employees of Lee Bolton Monier-Williams (LBMW) who have responsibility for retention, management and maintenance of Data on behalf of the Faculty Office.

Expectations of employees

All employees of the Faculty Office (and the relevant employees of LBMW) are required to:

Be mindful at all times of their obligations to respect privacy and confidentiality.
Head communications “private and confidential” as appropriate.
Ensure their computer/laptop on which any Faculty Office Data is stored is password protected, and that the password is kept confidential.
Keep up to date suitable virus protection on their computer/laptop.
Refrain from the use of memory sticks and discs for data storage
Exercise care when taking phone calls to avoid any breach of confidentiality.
Double check the recipients of their emails before sending.
Refrain from opening any email or attachment which looks suspicious.
Return all documents, data and equipment on which Data is stored on request of the Faculty Office or when leaving the employment by the Faculty Office.
Continue to respect confidentiality (unless expressly released) after their contractual arrangement with the Faculty Office has concluded.

Data retention

The Faculty Office will only retain Data where it has a legitimate basis to do so including (but not limited to the powers granted under:

The Ecclesiastical Act 1533 (Special Marriage Licenses)
Education Act 1988 (Lambeth Degrees)
The Courts & Legal Services Act 1990, the Legal Services Act 2007 (Notaries) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. And also in compliance with other public laws. Data is retained in accordance with the data retention schedule.

Access to Data

The Faculty Office will limit access to Data to those who require it to undertake the three roles of the Faculty Office described above
Otherwise undertake the statutory and regulatory functions of the Faculty Office e.g. the Legal Services Board, the Legal Ombudsman, and other approved regulators.
Fulfil the legal obligations of the Faculty Office e.g. to the courts and the Police.

AND

Undertake services for the Faculty Office including but not limited to:

membership of the Faculty Office Advisory Board and Qualifications Board
IT development and maintenance including the website
marketing and events management

Control: Data audit

The Faulty Office maintains a record identifying, inter alia:

What Data is being held.
To whom the Data relates.
Where the Data came from.
The frequency of collection of that Data.
In what form the Data is held e.g. electronic or hard copy.
The right of the Faculty Office to collect that Data.
With whom the Faculty Office shares that Data.

This record is kept under review on an ongoing basis.

Control: Data control system

The Faculty Office documents the controls it exercises in relation to:

General Data.
Data held electronically.
Data held manually.

Controls are kept under review on an ongoing basis (and will be formally reviewed every two years).

Data protection registration

The Faculty Office will at all times maintain a current and relevant data protection registration with the Information Commissioner’s Office. All parties captured by this policy will respect the terms of that registration, seeking clarification on a needs be basis from the Chief Clerk of the Faculty Office to avoid any breach.

Access to Data

The Faculty Office will respond within 1 calendar month (which may be extended by the Faculty Office by a further two calendar months if the requests are numerous or complex) to any request for access to and/or confirmation of Data being processed by the Faculty Office, by an individual to whom that Data relates. The Faculty Office will charge the applicable statuary fee (if any) for this information unless it considers the request to be manifestly unfounded or excessive, particularly if it is repetitive, in which case a reasonable fee (based on administrative costs) will be charged.

In the event the Faculty Office refusing an access request, it will explain in writing its reasons for doing so, advising of the right to refer the matter to the ICO.

Objection to Data processing

The Faculty Office will comply with a legitimate objection to processing Data unless it can demonstrate compelling legitimate grounds for doing so, which override the interests, rights and freedoms of the individual; or the processing is for the establishment, exercise and defence of legal claims.

Data correction and Data erasure

Upon receiving a valid request the Faculty Office will:

correct incorrect Data;
(but having due regard to the statutory and regulatory duties of the Faculty Office and the public interest in the availability of the data in question) delete Data. The Faculty Office will then also require third parties with whom it has shared Data to erase that Data. If the Faculty Office refuses a request for the deletion of Data it will give its reasons.

Data Destruction

Data will generally be retained in accordance with the data retention schedule and then destroyed, so far is practicable.

Data Protection officer

The Deputy Registrar is the data protection officer.

Data impact assessment

Based on the Faculty Office Data processing activities, it is not considered appropriate to undertake a Data protection impact assessment.

Breach of policy

Any breach of this policy, actual or suspected, must be reported immediately or as soon as reasonably practicable to the Chief Clerk of the Faculty Office by anyone to whom this policy applies. Any breach of this policy by the Chief Clerk of the Faculty Office must be reported by them to the Master of the Faculty Office immediately or as soon as reasonably practicable. A breach by an employee of the Faculty Office may be treated as a disciplinary offence. A breach by a third party e.g. contractor may result in their contract being terminated with immediate effect.

In the event of a breach likely to result in a risk to the rights and freedoms of individuals, the Faculty Office will notify the ICO within 72 hours of the event happening, and affected individuals as required under prevailing data protection legislation. All breaches must be recorded on the data breach log. Related guidance and policies:

LBMW GDPR Framework
Faculty Office data protection complaints policy
Faculty Office Privacy Notice
SharePoint and NotaryPRO Usage
Record Keeping Policy
Intelligence Sharing Policy

Review

The Faculty Offices will review this policy periodically and at least one in every four years to ensure it remains current and fit for purpose.

Appendix

The EU General Data Protection Regulation (GDPR) – summary

The EU General Data Protection Regulation (GDPR) came into force on 25 May 2018. It replaces all data protection legislation in EU member states.

The data protection principles state that personal data must be:

Processed fairly, lawfully and in a transparent manner.
Collected for specified explicit and legitimate proposes.
Adequate, relevant and limited to what is necessary.
Accurate and up to date.
Kept in a form that permits identification of the data subjects for no longer than is necessary.
Processed with appropriate security.

The rights of the data subject are:

Access
Rectification
Object to direct marketing
Processed only for restricted purposes
To call for data to be transferred
Erasure

Version date: Revised June 2026

Privacy Policy

The Faculty Office Privacy Policy is available to read here

Version date: June 2026

Data Retention Policy

The Faculty Office Data Retention Policy is available to read here

Last revised: June 2026