Privacy & Safer Churches
ImagineNations Church is committed to maintaining an environment and processes that protect the privacy of individuals associated with our church. We have chosen to use the Australian Privacy Principles (APP) as governed by the Privacy Act (1988), which from 12 March 2014 replaced the National Privacy Principles as a guiding principle for our church as your privacy is important to us.
For more information about the Privacy Act (1988) please refer to the National Privacy Commissioner’s website at: http://www.privacy.gov.au
What is your personal information?
In general terms “personal information” has the meaning given to it in the Act. This is information that can be used to identify you and may include your name, address, telephone number, email address and profession or occupation. If this information identifies you, or you are reasonably identifiable from it, then it is considered personal information.
Types of personal information we collect and hold include:
- Contact details (name, mailing or street address, email address, telephone number, facsimile number, age or birth date etc.
- Profession, occupation or job title.
- Country of origin.
- Details of services we have provided you or about which you have enquired.
- Any additional information relating to you that you provided to us directly through our website, through our representatives or otherwise.
- Information you provide to us through our activities and services, surveys or visits by Church representatives.
- Some services (including other activities) of ImagineNations Church are recorded. Images of people attending or participating in the service (or other activity) may be used for promotional or other purposes. Through attending any service (or other activity) you agree to ImagineNations Church using your image in these circumstances.
- In the interests of security and safety, and the comfort of the Church community, the church also operates video cameras within and around some Church premises.
Types of sensitive information we collect from communication between us include:
- On occasion, with your consent, we may collect health information where it is necessary for one or more of our functions or activities;
- Professional and practice information;
- Personal credit card data;
- Any idiosyncratic or personal information we obtain from you.
How is your personal information collected?
Personal information is collected directly from you unless it is unreasonable or impracticable to do so. Personal information may be collected in a number of ways including:
- The Church Connect Card, Faith Promise Cards, Children’s Connect Forms and other Departmental paperwork. The use of tools such as weekly Connect Cards allows congregation members the opportunity to provide updated information on a regular basis.
- During telephone calls.
- Through your access and use of our website.
- When you complete an application or purchase order.
- During conversations (face to face contact) or via correspondence between you and our representatives.
- When you register for conferences or Church events which can involve 3rd party service providers.
- When you complete our forms for the provision of services or to volunteer your services and assistance to the Church or its various organisations.
- When you complete a survey or make a donation.
- Via social media or conversation.
- Voice or image recordings.
- Personal information may be collected from third parties such as credit reporting agencies, law enforcement agencies, other government entities and specialist agencies to assist the Church achieve its objectives. This collection from third parties may occur in circumstances such as recruitment when conducting a criminal record check or verifying a Working with Children Check.
Anonymity and use of a pseudonym
In some instances, you will have the right to not identify yourself or to use a pseudonym when contacting us or participating in activities or obtaining services or assistance from us, unless we are authorised by law not to do so or it is impracticable for us to deal with individuals who have not identified themselves or have used a pseudonym. In such circumstances we will only obtain as much personal information as is necessary to provide you with the service or assistance you require. However, in some circumstances we may be limited in our ability to provide you with services or assistance without your personal information.
How we may share your information
- We will only use personal information for the primary purpose for which it is collected.
- In most cases, the purpose will relate to the spiritual, pastoral, social, educational and administrative functions of the Church. Those functions include maintaining personal information for the purpose of providing pastoral care within our congregation, and for the promotion of activities and functions associated with the church.
- We will only share your personal information and sensitive information in accordance with your express consent and instructions, as provided through the exclusions set out in the Australian Privacy Principles.
- We provide personal information to Church staff and lay leadership as related to the area of ministry in which the lay leader is involved. It is reasonable to expect that pastoral care cannot be done thoroughly without the use of lay leaders, and therefore the information collected may be disclosed for purposes of pastoral contact.
- Pastoring, on behalf of the church, will be conducted only by pastoral staff or authorised volunteers.
- We do not give out a person’s contact details to non-staff who may phone or otherwise request unless permission is given by the person whose contact details are required.
- Records made during the pastoring process will be kept secured.
- Where records are on paper, these will be kept in a locked office and/or filing cabinets.
- Electronic files will be password protected, accessible only to the person authorised to create or access that file.
- Access to these files by persons other than those who created the file should only occur in cases where pastoral care is being provided by another authorised staff member and the information contained in the file is necessary for effective pastoral care.
- Care will be taken to ensure the integrity of the information contained in files. Personal opinions will not be reflected as facts.
- We do not give, sell, rent or loan any identifiable information regarding members and adherents to any person or organisation without the consent of the person involved.
- When statutory requirements dictate that files are required to be kept for seven years after the file is closed, the Church will ensure the file is held securely for that entire time.
- When files are no longer needed, all information is to be shredded or electronically deleted.
- Care will be exercised when sending group emails to ensure email addresses are not provided unless authorised by the owners. To ensure privacy the “BCC” field will be used, as people whose names are in the “BCC” field cannot be seen by other recipients.
For what purposes do we collect, hold use and disclose your personal information?
We collect personal information from members of our congregation and visitors to our church for a variety of pastoral reasons so that we can perform our activities and functions and to provide best possible quality of service for the following purposes:
- To provide services to you and send communications to you.
- Answer enquiries and provide information or advice on existing and new services.
- To update our records and keep your contact details up to date.
- To departments of the Church to enable the development and promotion of other activities and services and to improve our general ability to assist Church attendees and the wider community.
- When there is reasonable need to provide contact details of church members to other church members who are involved in a team ministry together, pastors or staff may disclose those details.
- For the immediate reason for which you have provided it to us (for example, to enable us to process your request, payment, registration etc.
- We do not provide your personal information to other organisations for the purposes of direct marketing.
Due to the often sensitive nature of prayer requests, and taking into consideration the dire need often represented by a prayer request, we have endeavoured to implement a process which will protect the privacy of individuals and yet still allow those in our Church to be prayed for should they desire it. Names may only be used in public prayer if consent is first gained from the person who is the subject of the prayer request.
These guidelines will apply to all prayer within the Church that could be considered public, including any prayer requests submitted to the Emergency Prayer Chain.
Cross-Border disclosure of personal information
- The Church regularly communicates with missionaries overseas.
- The church has the highest responsibility to protect missionaries and must ensure that any personal information transferred to a recipient in a foreign country has adequate protection for the circumstance.
- No personal information will be sent without the individual’s consent, and only in the manner that the individual prescribes.
The church will never use an identifier that has been issued by a Commonwealth Government agency.
Quality and access of personal information
You have every right to access your personal and sensitive information, subject to exceptions allowed by the law. If you would like to access or seek correction of your personal and sensitive information, please contact our Privacy Officer if you need information. For security reasons we ask that you put your request in writing. To enable us to verify your request we require you to advise the following:
- Your full name
- Contact telephone number
- The relevant Department or service (if known) that your request relates to
There may be instances where we cannot grant you access to personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it results in a breach of confidentiality.
Correction of information
If you believe that personal information we hold is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us via the contact details below. We will consider whether 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.
Securing your information
We take reasonable steps to ensure the security of personal and sensitive information we hold and to protect it against loss, misuse or unauthorised access, destruction, use, modification or disclosure.
Our IT systems are password protected and comply with applicable security standards. Only authorised personnel are permitted to access these details.
Breach of Privacy
You need to be aware that confidentiality can be legally breached by issues relating to subpoenas or mandatory reporting. Over and above subpoenas and mandatory reporting, a decision to breach confidentiality may also be taken in the following situations:
- Suspected abuse and neglect
- Actual or possible overdose situations
- Where an individual issues substantive threats of intended violence or harm either to themselves or to others
Apart from the above, confidentiality will be regarded as a sacred trust by any Pastor. Such breaches of confidentiality will made only after the Pastor has consulted with their supervisor or professional associate.
In response to any subpoena, only the material specifically requested will be provided, in whatever form it may be held. Legal advice is recommended.
Released material must only be delivered to official individuals (e.g. to the Clerk of the Court) and an official receipt obtained.
If you have any further questions about our Privacy Policies please call us at (02) 4736 3000 or send an email to: Robert@inchurch.com.au
If you are not satisfied with how we have handled your complaint you can also contact the Office of the Australian Information Commissioner (OAIC) on http//oaic.gov.au/.