INTRODUCTION

FAITHLIFE CHURCH INC is committed to protecting the privacy of personal and sensitive information which the organisation collects, holds and administers in accordance with the legislation. Personal information is information which directly or indirectly identifies a person.

PURPOSE The purpose of this document is to provide a framework for the Church in dealing with privacy considerations. The Church has adopted the following principles in relation to handling personal information. Although the Church is not legally bound by the Privacy Act 1988 (Cth) or the Privacy and Data Protection Act 2014 (Vic), it will endeavour to:

• collect only information which the organisation requires for its primary function;
• ensure that stakeholders are informed as to why we collect the information and how we administer the information gathered;
• use and disclose personal information only for our primary functions or a directly related purpose, or for another purpose with the person’s consent;
• store personal information securely, protecting it from unauthorised access; and
• provide stakeholders with access to their own information, and the right to seek its correction.

POLICY

1. What type of personal information do we collect?                                 

The type of information that we collect and hold will depend on the nature of your involvement with the Church.

Depending on the reason for collecting the personal information, the personal information that we collect may include (but is not limited to) name, age, residential address, suburb, postcode, date of birth, phone number, email address, bank account details, next of kin details, occupation, cultural information, images and group and ministry involvement.

We may also collect sensitive information from a person including marital status, gender, a working with children check or a police check.

You may seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services to you except for the most general responses to general enquiries, unless you identify yourself.

We sometimes receive unsolicited personal information. In circumstances where we do receive unsolicited personal information we will endeavour to destroy or deidentify the information as soon as practicable if it is lawful and reasonable to do so, unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.

     2. How do we collect personal information?

Personal information is collected:

• • via our staff and volunteers when you attend a service or church group
  • meeting;
  • online via our website;
  • via email correspondence, post or phone;
  • when you make a donation

The Church will endeavour to:

• • only collect information that is reasonably necessary for the performance and primary function of the Church and the activities that you are seeking to be involved in;
  • notify stakeholders about why we collect the information and how it is administered;
  • notify stakeholders that this information is accessible to them;
  • collect personal information from the person themselves wherever possible;
  • if collecting personal information from a third party, be able to advise the person whom the information concerns, from whom their personal information has been collected;
  • collect Sensitive information only with the person’s consent. (Sensitive information includes health information and information about religious beliefs, race, gender and others);
  • determine, where unsolicited information is received, whether the personal information could have collected it in the usual way, and then if it could have, it will be treated normally. (If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information)

We may collect personal information from individuals such as visitors, volunteers, contractors, and suppliers.

We will generally obtain consent from the owner of the personal information to collect their personal information. Consent will usually be provided in writing, however, sometimes it may be provided orally or may be implied through a person’s conduct.

In relation to the collection and disclosure of sensitive information, the Church will endeavour to collect and disclose in accordance with any legal obligations – where collection or disclosure is permitted, or required by law.

     3. How will we use your personal information?

The Church may collect, hold, use or disclose your personal information for the following general purposes:

• • to identify you;
  • for the purpose for which the personal information was originally collected or a directly related secondary purpose;
  • for a purpose for which you have consented;
  • for information for direct marketing, and you will be given an opt-out in such communications;
  • for any other purpose authorised or required by an Australian law; and
  • for any other purpose authorised or required by a court or tribunal.

Our primary purpose of collecting personal information is to collect information that is reasonably necessary for the performance and primary function of the Church and the activities that you are seeking to be involved in.

In relation to the personal information of job applicants, staff members, volunteers and contractors, we may collect the personal information for purposes including:

• • to enable us to carry out our recruitment functions;
  • to correspond with you, provide training and professional development;
  • to fulfil the terms of any contractual relationship;
  • to ensure that you can perform your duties; and
  • for insurance purposes.

If you have any concerns about your personal information being used by us in any of these ways, please notify us.

Where the Church receives unsolicited job applications or requests to be engaged as a Volunteer, these will usually be dealt with in accordance with the unsolicited personal information requirements under this policy.

     4. Direct Marketing and fundraising

From time to time, and in support of our programs and activities, the Church may send direct marketing or fundraising material if you have consented to receiving such information.

If you do not want to receive any such information, you can contact the Church by email on enquiries@faithlifechurch.com.au.

Once we receive a request to “opt out” from receiving marketing information, we will endeavour to cease sending such information within a reasonable period of time.

In relation to personal information which has been collected other than from the person themselves, the Church will endeavour to only use the personal information for direct marketing purposes if the person whose personal information has been collected has consented (and they have not taken up the opt-out).

The Church may disclose personal information to an organisation that assists the Church’s fundraising endeavours such as the Church’s FaithLife Foundation Inc also trading as Hope Ink Inc.

     5. Sending information overseas

The Church will endeavour not send personal information about an individual outside Australia without:

• • obtaining the consent of the individual (in some cases consent may be implied); or
  • otherwise acting consistently with applicable privacy legislation.

     6. How do we store personal information?

The Church will endeavour to take reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure.

The Church will protect personal information in a number of ways including securely storing paper records, using professional software systems, and password restricted access.

The Church also has policies in place in relation to archiving, destruction and storage of personal information.

The Church’s staff and volunteers are required to respect the privacy of personal information of individuals.

    7. How do we destroy personal information that is not required?

Under the Church’s destruction and de-identification policies, your personal information that is no longer required will be de-identified and destroyed.

In some circumstances, your personal information may be kept for direct marketing purposes if you have not opted-out and/or you have consented in writing for the Church to retain your personal information for that purpose.

The Church will only destroy records in accordance with the organisation’s Records Management Policy.

     8. How can you update your personal information?

The Church will endeavour to hold accurate and up-to-date personal information. If you would like us to update the personal information that we hold about you, due to inaccuracy, you can contact our Communications Manager via email on enquiries@faithlifechurch.com.au.

     9. How can a person access their personal information?

The Church will endeavour to provide individuals with access to their personal information held by the Church upon request. Requests for access can be made at no cost to the individual.

If you wish to access personal information held about you in order to seek correction of such information you may do so by contacting the COMMS Manager via email on enquiries@faithlifechurch.com.au. The Church may refuse access to personal information in a number of circumstances.

These might include where:

• • giving access to the information would pose a serious threat to the life, health or safety of a person;
  • giving access would have an unreasonable impact on the privacy of a person;
  • the information relates to existing or anticipated legal proceedings and would not be available under the discovery process; or
  • denying access is required or authorised by an Australian law or court order.

We will endeavour to handle all requests for access to personal information as quickly as possible.

  10. Complaints

If you have any concerns or complaints about the way the Church manages the personal information it holds, or are concerned that there has been a breach of privacy then please contact the Executive Minister via Church Office on +61 3 9108 0350 or on enquiries@faithlifechurch.com.au. We will consider any complaint and will notify the complainant of any decision in relation to the complaint as soon as practicable.

RESPONSIBILITIES

The Executive Minister/CEO is responsible for developing, adopting and reviewing this policy, and for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises. The Church may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the Church’s operations and practices and to make sure it remains appropriate to the changing legal environment.

RELATED DOCUMENTS

• Confidentiality Policy

Privacy Officer
FaithLife Church
PO Box 354 Newport,
Victoria 3015
Phone: (03) 9108 0350