This is our draft policy, first considered by the Parish Council in October 2020.
Waiting to be finalised by the 2021 Parish Council.
1. Purpose and Scope
Village Church Annandale (“Village Church”) is committed to protecting the privacy and confidentiality of members, attenders, visitors, staff members, volunteers, and stakeholders in the way information is collected, stored and used.
This Policy outlines how we deal with your personal information and our legal obligations and rights to that information. If we agree with you to use or disclose any of your personal information in ways which differ to those stated in this Policy, the provisions of that agreement will prevail to the extent of any inconsistency.
Privacy provisions of the Privacy Act 1988 govern the collection, protection and disclosure of personal information provided to Village Church by members, attenders, visitors, staff, volunteers, personnel and certain other persons.
Confidentiality applies to the relationship of confidence. Confidentiality ensures that information is accessible only to those authorised to have access and is protected throughout its lifecycle. Confidential information may be marked as such or deemed confidential by its nature, e.g. it is information that is not available in the public domain.
Consent means voluntary agreement to some act, practice or purpose. Consent has two elements: knowledge of the matter agreed to and voluntary agreement.
Individual means any person such as a member, attender, visitor, staff member, volunteer, contractor or a member of the public.
Organisational information includes publicly available, and some confidential, information about organisations. Organisational information is not covered in the Privacy Act (1988) but some organisational information may be deemed confidential.
Personal information means information or an opinion (including information or an opinion forming part of a database) about an individual (Office of the Federal Privacy Commissioner, 2001). It may include information such as names, addresses, bank account details. The use of personal information is guided by the Federal Privacy Act (1988).
Personnel means staff, student ministers, volunteers area leaders and team leaders.
The public domain in relation to confidentiality is “common knowledge,” i.e. information that can be accessed by the public.
Village Church is committed to ensuring that information is used in a Biblical, ethical and responsible manner.
This Policy sets out how we manage your information. It sets out:
• What information we collect and hold
• How we collect, hold and use information
• Why we collect, hold, use and disclose your information
• How you can access your information
• How you can correct your information
• How you can complain about the handling of your personal information.
4. Policy Detail
4.1 Information we collect and hold
Village collects personal information from church members and attenders, visitors, staff members, contractors and other individuals primarily for the purpose of providing personal ministry to those individuals, to administer their engagement with Village Church and ministries (including any volunteer activities) and to provide information about Village Church’s events and ministries. Without personal information, it is not practicable for Village Church to provide such services to individuals.
Village Church collects and holds various personal information, (including health information in limited circumstances) about those who attend and/or interact with Village Church Annandale. This includes information collected by Village Church as part of its day to day activities. In general, the information is stored on Village Church’s management system and database.
The information collected by Village Church may include:
1. Your full name, gender, age and contact details, including postal address, email address and telephone numbers;
2. Your education status (including the name of your education institution);
3. Your marital status;
4. Whether you suffer from any allergies or health conditions;
5. If you are part of a household, details relating to the household, such as:
a. personal information of your family members;
b. personal details of your children;
6. Your WWCC number, Sydney Anglican Safe Ministry Check and records of completion of the Anglican Diocese of Sydney’s Safe Ministry Training
7. Any records relating to personal skills or training, including but not limited to, First Aid Certificates, professional and ministry qualifications.
b. Church Personnel
Village Church also holds information relating to all its Personnel including:
1. the role and activities of the Personnel; and
2. the qualifications held by the Personnel relevant to his or her role, such as theological and other training. Village Church also records the current status of the qualifications, such as whether the Personnel are in the process of applying for the qualifications.
c. Attendee involvement
Village Church may also collect information from its attendees regarding the attendee’s use of Village Church’s gatherings. This includes:
1. the meetings that you attend and the number and frequency of the attendance;
2. your involvement in Village Church’s ministries;
3. details of pledges, gifts and donations;
4. records of your visits, phone calls and pastoral matters; and
5. records of any communications that you have with us.
From time to time Village Church may conduct a census to update its management system. Village Church will record and collect all the personal information that you may provide in your response.
e. Video recording and security
1. Village Church may from time to time record video, audio or images of gatherings and activities at Village Church. These videos and images may be used and shown for information, teaching and/or promotional purposes. By attending these gatherings and activities, you consent to Village Church taking the video and images and using and disclosing them for such purposes. However you may withdraw this consent at any time in writing.
In respect of those under the age of 18 years, Village Church will seek and obtain the consent of their parent/guardian to the recording of video or images and any use thereof in writing.
2. In addition, Village Church may also operate external and internal security surveillance cameras for security purposes. Village Church may use and disclose the video footage from these cameras for legal and security reasons.
In addition to the above, Village Church may also hold any other information you provided to us (whether orally, by mail, SMS, email or online).
If at any time another person provides personal information about you to us then we will ask that person to ensure that you have read and understood this policy and separately consented to that personal information being used and disclosed by us for the purposes described below. If you provide personal information about any other person (including your family members), then you must ensure that the person has read and understood this policy and consents to us collecting, storing, using and disclosing the information that you provide as described in this policy.
4.2 How we collect your Information
We collect most of this information directly from those individuals (or through a parent or guardian in respect of persons under 18 years of age), such as when someone attends a Village Church gathering, personally provides information to a Village Church staff member, leader or volunteer through personal interaction or email or message, or fills in a form or connect card.
4.3 How we use your information
Village Church uses the personal information about its attendees to:
1. administer the records of your relationship with Village Church; and
2. assist Village Church in providing services to you and others
Village Church uses personal information about its Personnel to assess their suitability to perform their role, and to match their skills to particular activities.
Village Church also uses personal information about you:
1. to respond to your queries;
2. to contact and communicate with you;
3. to assist Village Church in caring for you pastorally, operating and improving its services, gatherings and activities;
4. to send information about and invitations to future events, worship services, gatherings, events or current issues;
5. for our internal administrative, promotional and planning requirements; and
6. to compile and report statistics, with all the relevant personal and/or proprietary information de-identified prior to the completion of such statistics.
d. Opt out
You may opt out of receiving any communications from Village Church at any time. If you wish to do this, please make all requests to us (see “Contact Us” below). Please indicate on your request whether you would like to opt out of either, or both, postal and electronic communications.
Village Church does not routinely disclose personal information to external individuals or organisations without consent. Only Village Church Personnel access the information in order to use it for the purposes for which it was collected. The circumstances when we might disclose this information include:
when required by law;
when it is necessary for the purpose for which the information was collected such as providing booking details to a conference organisation;
when it is necessary or desirable to protect the personal safety or welfare of the individual or another person;
on a confidential basis to agents and other service providers that Village Church uses in the day to day operations of its activities such as the manager of Village Church’s management system;
when a change in Village Church’s organisational structure makes it necessary; or
with your consent.
Like most organisations, from time to time Village Church may use contractors who could have access to personal information on our systems, such as IT technicians. Any contractors who have access to personal information relating to Village Church attendees are required to adhere to the Privacy Act and may not retain this information or use it for any unauthorised purpose.
You may request access to personal information we hold about you by writing to Village Church at the address below (see “Contact Us” below). Where we hold information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you access it (eg emailing or mailing it to you).
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request correction of that information by contacting us. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
Unless otherwise required by law, you are not obliged to give us your personal information. However, if you choose not to provide Village Church with personal details, such as your name or address, the range of options and services available to you may be limited.
4.4 How we hold your information
We hold your information in cloud storage systems. We take all reasonable steps to ensure that personal information held is protected from:
Misuse, interference and loss
Unauthorised access, disclosure or modification.
When we no longer require personal information (including when we are no longer required to keep records relating to you), we take reasonable steps to ensure that it is destroyed or de-identified. Computer records are archived securely.
4.5 Electronic Communication
4.5.1 Visiting our Website
Anytime you access an unsecured part of our website, (that is, a public page that does not require you to log on), we may collect information about your visit, such as:
The time and date of visit;
Any information or documentation that you download or view;
An email address;
Your browser type; and
Internet protocol details of the device used to access the site.
You may change the settings on your browser to reject cookies; however, doing so might prevent you from accessing the secured pages of our website.
When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so.
Emails sent by Village Church including Personnel and volunteers may be automatically digitally monitored (for example whether they are opened or viewed). Data obtained through this process may be retained by Village Church in accordance with this Policy.
We use up-to-date security measures on our website to protect your personal information. Any data containing personal, credit or debit card or related information which we transmit via the internet is encrypted.
We take reasonable steps to make sure that the personal information that we collect, use or disclose is accurate, complete and up-to-date. However, if you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting Village Church.
4.7 News and information
We may use your personal information, including your contact details, to provide you with information about our activities.
We will consider that you consent to this, unless you opt out. You may opt out at any time if you no longer wish to receive information through a channel, like email, or by unsubscribing from email updates. You can also make this request by contacting Village Church.
4.9 Questions and complaints
If you have any questions, concerns or complaints about this Policy, or the handling of your personal information, please contact the Village Church office. You can also contact Village Church if you believe that the Privacy of your personal information has been compromised or is not adequately protected.
Once a complaint has been lodged, Village Church will respond to you as soon as possible. We will aim to deal with your complaint at the time of your complaint. If you are not satisfied with the response you receive, please let us know and we will investigate further and respond to you.
If you remain unsatisfied, you may contact the Federal Privacy Commissioner (see below).
Church Contacts Phone: (02) 9244 6600 Email: firstname.lastname@example.org
Federal Privacy Commissioner
Post: GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992