🙏 Intercessions
Use of last names in intercessions
It is current policy to not include the last names of people being prayed for either as sick or in long-term care. The legal reasoning behind this decision is explained below.
The decision not to include full names was most recently reviewed by the PCC on 23 June 2026.
The law
The following is our understanding of the relevant legislation and guidance as it applies to intercessions at Whitkirk. It is not legal advice.
The pieces of legislation which we base this decision on are the UK General Data Protection Regulation and the Data Protection Act 2018. When talking about “the legislation”, this usually means the General Data Protection Regulation (GDPR).
Under the GDPR, personal data – information relating to an identified or identifiable living individual – must be processed in accordance with a number of legal requirements. We consider a person’s full name, together with the fact that they are associated with Whitkirk, to constitute personal data. Article 6 of the GDPR provides a list of cases in which processing of personal data is considered lawful. Of these cases, only two would plausibly apply to intercessions; consent (ie the individual has said we can use their data), and legitimate interests (praying for the sick is a fundamental function of the Church).
However, by identifying someone as being sick, we are processing information concerning their health. Information concerning a person’s health is special category personal data, and must also satisfy Article 9. Under this article we have a much stricter set of requirements; the only one we could realistically use is again consent.
We would struggle to rely on the non-profit exemption here. Whilst Article 9 includes a condition for certain non-profit organisations, including churches, our services are open to the public both in person and online, making it difficult to argue that disclosure of full names remains within the limited audience required by that exemption.
We would also struggle to argue that using full names is necessary to protect a person’s vital interests. Although we believe that prayer is powerful, we also believe that God knows who we mean.
It is therefore the view of the PCC that the only realistic lawful basis on which we could include someone’s full name in intercessions for the sick or in long-term care is with their explicit consent. There are only very limited circumstances in which a friend or family member would be able to provide this consent on someone else’s behalf, and it is the view of the PCC that the administrative overhead required to maintain a suitable record of consent – as well as the need to get that consent from people already in a stressful situation – is not justified by the benefits of including a last name in the intercessions.
How about recently died and year’s mind?
Under UK law, the GDPR applies only to living individuals, and therefore there is no legal basis to prohibit sharing full names of those who have recently died or who are being remembered.
However, it may be prudent in some cases not to name the recently dead in order to maintain the privacy and dignity of their families. This is a pastoral decision which can be made case-by-case. If you are in any doubt, please consult with the Vicar.