Introduction

Hills Church is committed to maintaining an environment and processes that protect the privacy of individuals associated with our church.

Hills Church is not required by law to comply with the private sector provisions of the Privacy Act 1988, however, because of our commitment to privacy, we have voluntarily chosen to use the National Privacy Principles (NPPs), as contained in the Act, as the guiding principles for our church and they are applied within the church in the practical ways as described in this document.

For more information about the Privacy Act (1988) please refer to the National Privacy Commissioner’s website at: http://www.privacy.gov.au

 

 

1.      Policy Background

While the essence of being a church is being involved in each others lives, caring for one another and creating a strong sense of community, we are also mindful of respecting and protecting the privacy of all who attend our church. We recognise that an individual’s privacy may be of utmost importance to them and that they have a right to control their personal information. We also recognise the individual’s need for appropriate protection and management of personal information that is shared with us.

This policy has been developed to assist the understanding of how we collect, use and safeguard the personal information that is provided to us. It is the intention of this church to regularly review this policy statement in accordance with new developments in State and Federal legislation, best business practices, technology and individual needs.

This church acknowledges that when individuals provide personal information about themselves, it is an act of trust. Unless the individual gives us explicit consent to act otherwise, this policy will govern how we handle an individual’s personal information and safeguard their privacy.

2.      Management of the Policy

1. 1. This policy will govern all aspects of privacy and the collection of personal information within Hills Church.
   2. All staff and departments collecting information and operating within Hills Church will be educated in, and comply with, this policy.
   3. Hills Church will appoint a Privacy Officer who will be responsible for maintaining the privacy policy and educating the staff in its application and use.
   4. The Privacy Officer will oversee the storing, correcting and providing people access to personal information collected about them.

 

3.      Collection and Use of Personal Information

1. 1. Hills Church collects personal information when such information is provided to the church through the completion of documents such as, but not limited to:
      1. Church Census Forms;
      2. Pastoral Care Slips;
      3. Visitors Information Sheets;
      4. Decision Cards;
      5. Course or Event registrations.
   2. Personal information may also be collected when an individual accesses a service provided by the church to the general and church community (e.g. counselling).
   3. Such information may be added to our church databases.
   4. Each person remains in control of their information.
   5. Hills Church will take reasonable steps to keep personal information secure and will, consistent with the NPPs, comply with any request from a person to correct or remove his or her information on demand.
   6. In accordance with the NPP sensitive personal information can be collected by Hills Church if:
      1. the individual has consented; or
      2. the collection is required by law; or
      3. the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual.
   7. In accordance with the NPP, sensitive personal information collected by Hills Church (e.g. information about a person’s religious beliefs) must meet the following conditions:
      1. the information relates solely to the members of Hills Church or to individuals who have regular contact with it in connection with Hills Church’s activities;
      2. at or before the time of collecting the information, Hills Church undertakes to the individual whom the information concerns that Hills Church will not disclose the information without the individual’s consent.
   8. In the normal course of operations, Hills Church will only use personal information for the primary purpose for which it is collected:
      1. In most cases, the purpose will relate to the spiritual, pastoral, social, educational and administrative functions of the Church;
      2. These functions include maintaining personal information for the purpose of analysing the role of the Church in society and recording the family histories of its members;
      3. Information may be disclosed to scholars studying the Church and to relatives of Church members – in these instances, proper authority would be sought from the person before their information was disclosed.
   9. Hills Church will only use personal information about an individual for a secondary purpose (i.e. something beyond the scope of the primary purpose) if that individual has consented, or the use is otherwise provided for by the NPPs (i.e. the NPPs in some cases permit the disclosure of personal information for things such as police criminal investigations).
   10. 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.
   11. 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.

4.      Public Prayer

1. 1. 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. For those who strongly identify with a congregation, there can be a sense of great comfort knowing that their church is aware of their situation and praying for them.

      Therefore, when the Church is asked to publicly pray for any prayer request, the following guidelines will apply:

      1. When praying publically for any person who is the subject of a prayer request, every effort will be made to ensure that that person is aware of, and has agreed to, the prayer being offered. Additionally, where their identity is, or can be revealed through the prayer being offered, their consent to be identified will be sought. A prayer request can take the form of, but not limited to a completed prayer card, an email, a SMS, a written note or a direct verbal request in person or by phone;
      2. If the person who is the subject of the prayer request is a member of our church and is incapacitated, a prayer request can be made by immediate family members and may take the form as listed in 4.1.a.;
      3. If the person needing prayer is unknown to us, and we are unable to receive a written or verbal request from them, no names identifying the person will be used. Rather a general reference to a ‘request for prayer’ will be made without identifying the recipient of the prayer being offered.
   2. These guidelines will apply to all prayer within the church that could be considered public – including prayer meetings, church services, home group meetings, etc.

5.      Counselling and Pastoral Care

1. 1. It is understood that a large part of pastoral care is the use and transmission of information relating to those in the congregation. Information must be treated as confidential and with great care.
   2. All participants working within the pastoral care teams will be briefed on, and abide by, the requirements as prescribed in this policy document with regards to the privacy of individuals.

6.      Church Database

1. 1. The church database (currently housed within the Elvanto Church software system) is a password protected system. Access to the database is limited to church staff and a small number of authorised volunteers. A list of these people is available from the Privacy Officer.

7.      Counselling

1. 1. Counselling, on behalf of the church, will be conducted only by pastoral staff, authorised counselling volunteers or external counselling services that may be employed by Hills Church.
   2. Paper records created during a counselling session will be kept physically secured (e.g. in locked drawers or cabinets).
   3. Electronic records created during a counselling session will be password protected and encrypted (e.g. MS Word’s document protection mechanism).
   4. 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.
   5. Care will be taken to ensure the integrity of the information contained in files.
   6. 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 length of time.
   7. When files are no longer needed, all information is to be shredded or electronically deleted.

8.      Breaching Confidentiality

1. 1. 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:
      1. Suspected abuse and neglect;
      2. Actual or possible overdose situations;
      3. Where an individual issues substantive threats of intended violence or harm either to themselves or to others.
   2. Apart from the above, confidentiality will be regarded as a sacred trust by any minister or counsellor. It would be advisable that such breaches of confidentiality are made only after the pastor/counsellor has consulted with their supervisor or professional associate.
   3. In response to any subpoena, only the material specifically requested will be provided, in whatever form it may be held. Legal advice is recommended.
   4. Released material must only be delivered to official individuals (e.g. to the Clerk of the Court) and an official receipt obtained.
   5. Breach of any confidentiality could be grounds for disciplinary action against the offender. Such matters are to be clearly stated in appropriate job descriptions and contracts.

9.      Accessing Counselling Records

1. 1. Should a person wish to access pastoral information about them, they may apply in writing to the Privacy Officer. Access to the file, in the first instance, should be done in the presence of a pastor, who can provide explanation for terminologies used.

10.   Church Websites

1. 1. If a website administered by the Church uses cookies for collecting any detailed user information from that site, the user will be advised.
   2. Our website does not currently use cookies, therefore, we collect no information when you visit our website at HillsChurch.com.au or HillsChurch.Elvanto.com.

11.   Emails

1. 1. Email addresses are treated as personal information and so will be protected along with normal privacy procedures.
   2. When sending bulk emails (e.g. church notices, newsletters, marketing) to multiple recipients, addresses will be placed in the BCC (blind carbon copy) field to hide the email addresses.

12.   Requests for Personal Information

1. 1. General requests for personal information of individuals will not be processed by church staff or volunteers. This includes the requests for church member’s mobile phone numbers, home numbers, addresses, work place contact details, etc.
   2. Where a request for personal information is made to Hills Church staff by an individual or organisation (requestor), one of three options apply:
      1. the requestor may have their contact information taken (e.g. mobile phone number) and then forwarded to the person in question which gives that person the opportunity to make reverse contact at which point they can provide or deny their own personal information to the requestor; or
      2. the requestor may be instructed to make a direct request for the information they seek from the person in question; or
      3. the request for information will be denied with no additional comment from church staff (e.g. a telemarketing company).

13.   Securing Your Information

1. 1. Personal information that exists in printed form (e.g. printed address lists) will be kept secure and destroyed when no longer required.
   2. Paper records created that contain sensitive personal information will be kept physically secured (e.g. in locked drawers or cabinets).
   3. Electronic records created that contain sensitive personal information will be password protected and encrypted (e.g. MS Word’s document protection mechanism).

14.   Anonymity

1. 1. While we recognise the importance of pastoral care in church life, those who attend this church and do not wish to provide any personal information are free to do so.
   2. It should be recognised that anonymity will restrict the ability of the church to contact and provide any care for the person.

15.   Trans-Border Data Flows

1. 1. The Church regularly communicates with missionaries overseas
   2. Some missionaries are in countries where the practise of Christianity is illegal. The church has the highest responsibility to protect these missionaries and must ensure that any personal information transferred to a recipient in a foreign country has adequate protection for the circumstance
   3. No personal information will be sent without the individual’s consent, and only in the manner that the individual prescribes