St. Luke’s Anglican Church, Vermont
This Policy applies to St. Luke’s Anglican Church, Vermont (‘SLV’). The word “individual” refers to a parishioner, or any other person with whom we come into contact.
This Policy outlines SLV’s obligation to manage and protect the personal information it holds about individuals.
SLV is bound by the National Privacy Principles (‘NPPs’) contained in the Privacy Act 1988 (C’th) (‘Privacy Act‘).
‘Personal information’ is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information collected is ‘sensitive information’. Sensitive information may include information relating to a person’s racial or ethnic origin, criminal record and may also include health information about an individual.
How personal information is collected
Personal information is generally collected directly from the individual. For example, an individual may deal with staff or ministry leaders on the phone, through correspondence (by letter, fax or email) or by face to face contact. Personal information is also collected from forms filled out by individuals, interviews, and from other people. Typically, the type of personal information collected about individuals includes name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the proper functioning of SLV ministries.
In some circumstances personal information about an individual may be provided by somebody else, for example a referral from another person. Where this happens, reasonable steps are to be taken to ensure that the individual is or has been made aware of the matters set out in this Policy.
If personal information is not provided when requested, we may not be able to process an individual’s application to join SLV, provide individuals with the benefit of our services, or meet an individual or a parishioner’s needs appropriately.
About whom do we collect personal information?
The type of information we may collect and hold includes (but is not limited to) personal information about:
- Other people with whom we come into contact;
- Donors of money where receipts are required for taxation purposes; and
- Staff members and employees.
Why does the Church collect personal information?
The Church collects personal information for the following purposes:
- to provide personal ministry services to its parishioners, and to other persons seeking assistance;
- to prepare the SLV Directory (of parishioners);
- to issue receipts for tax deductible donations;
- to help us manage and enhance our services; and
- to fulfil our obligations as an employer.
How might we use and disclose personal information?
When we refer to “use” of personal information, we mean use within SLV, for the purposes outlined above. When we use the word “disclose”, we mean providing the information to persons outside SLV.
SLV may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes, which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (eg, where required by law).
We use and disclose personal information for the following purposes:
- to provide personal ministry services to parishioners;
- to provide personal ministry services to other persons who may seek our services;
- to provide individuals with the SLV Directory (if prior consent is obtained);
- to comply with legal obligations; and
- to help manage and enhance the operation of SLV ministries.
Personal information we collect is not disclosed to others for the purpose of allowing them to direct market their products and services. Sensitive information is also not disclosed for direct marketing purposes.
In the event that SLV engages other people to perform services for it, which may involve that person handling personal information from its records, that person is prohibited from using that information except for the specific purpose for which it is supplied.
Wherever possible, attempts will be made to de-identify sensitive information.
All personal information about an individual will be deleted when it is no longer needed or relevant.
To whom might we disclose personal information?
We may disclose personal information to:
- other parishioners;
- consultants we engage;
- organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
- regulatory authorities, if required by law; and
- anyone else to whom the individual authorises us to disclose it.
We also collect personal information from these organisations and individuals, and deal with that information in accordance with this Policy.
Sending information overseas:
We will not send personal information to recipients outside of Australia without:
- obtaining the individual’s consent (in some cases this consent will be implied); or
- otherwise complying with the NPPs.
Management of personal information
The NPPs require us to take all reasonable steps to protect the security of personal information. SLV’s staff and ministry leaders are bound by a code of conduct agreement which includes a requirement to respect the confidentiality of personal information and the privacy of individuals.
SLV takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. All personal information contained in hard copy documents held by SLV are held in secure facilities. All personal information stored on SLV’s computer system is backed up regularly, and back-up copies are held in a secure location.
Where we no longer require the personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy it.
The following disclaimer will be used on any forms used to collect personal information.
A current copy of this Policy is to be posted on the SLV web site and all electronic forms are to include a link to the appropriate web page.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes.
How do we keep personal information accurate and up-to-date?
SLV takes reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. It is SLV’s policy and practice to update the information it holds about individuals every 12 months, to ensure that the information is accurate. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out below.
You have the ability to gain access to your personal information
Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information, which SLV holds about them by contacting the SLV Privacy Officer. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act.
An individual’s request for access to his/her personal information will be dealt with by allowing the individual to look at his/her personal information at the SLV offices. We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise the likely cost in advance whenever practicable.
The SLV Parish Council appoints a Privacy Officer from its number each year who is responsible to the Parish Council for monitoring and reporting on the implementation of this Policy, recommending changes to this Policy and for oversight of the investigation and resolution of any alleged breaches of this Policy.
Updates to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.
If you have any questions about privacy-related issues please contact:
St. Luke’s Anglican Church
St. Luke’s Anglican Centre
P.O. Box 26