1. Purpose and Scope
Churches of Christ in Victoria and Tasmania (CCVT) is committed to protecting the privacy and confidentiality of members of the public, local church members, Board members, staff, volunteers and stakeholders in the way information is collected, stored and used.
This policy provides guidance on CCVT’s legal obligations and ethical expectations in relation to privacy and confidentiality.
CCVT is bound by the Australian Privacy Principles (APP) under the Privacy Act 1988 (Cth) (Privacy Act).
This Policy outlines how we deal with your personal information as to our legal obligations and rights to that information. If we agree with you to use or disclose any or 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.
2. Definitions
Privacy provisions of the Privacy Act govern the collection, protection and disclosure of personal information provided to members of the public, local church members, Board members, staff, volunteers and stakeholders.
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 members of the public, local church members, Board members, staff, volunteers and stakeholders.
Organisational information includes publicly available, and some confidential, information about organisations. Organisational information is not covered in the Privacy Act 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 Privacy Act.
The public domain in relation to confidentiality is “common knowledge,” i.e. information that can be accessed by the public.
3. Principles
CCVT is committed to ensuring that information is used in an 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 and hold information;
- Why we collect, hold, use and disclose your information;
- How you can access your information;
- How you can correct your information; and
- How you can complain about the handling of your personal information.
4. Policy Detail
The privacy of personal information is defined by legislation (the Privacy Act). At all times, CCVT acts in accordance with these legal requirements which are underpinned by the following policy statements 4.1- 9.
4.1 Information we collect and hold
We only ask for personal information relevant to our activities as the Churches of Christ. When you interact with us, we may request information such as:
- identifying information, like your name, address and other contact details;
- your church and/or agency; and
- your reasons for interacting with us.
4.2 How we collect your Information
Wherever possible, we will collect personal information directly from you.
4.3 We may collect and use your personal information for several purposes, such as:
- Entities that verify identity;
- Lawyers, conveyancers, accountants, brokers and agents representing you;
- Contractors for newsletter printing and mail out, card and cheque production,market research or direct marking;
- Executing your instructions;
- Direct marketing; and/or
- Maintaining and developing our business systems and managementprocesses.
We will also disclose your information to law enforcement and government agencies as required by law or to assist with their enforcement activities.
4.4 How we hold your information
We hold your information in our internal filing system. We take all reasonable steps to ensure that your personal held information is protected from:
- Misuse, interference and loss; and/or
- Unauthorised access, disclosure or modification.
4.5 Electronic Communication
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 such information is destroyed or deidentified.
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;
- Your browser type; and
- Internet protocol details of the device used to access the site.
4.5.2 Cookies
A “cookie” is a small text file which is placed on your internet browser and which we may access each time you visit our website. When you visit the secured pages of our website (i.e. pages that you must provide login details to access) we use cookies for security and personalisation purposes.
When you visit the unsecured pages of our website (i.e. public pages that you can access without providing login details) we use cookies to obtain information about how our website is being used.
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.
4.5.3 Email
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.
Your email address will only be used or disclosed for the purpose for which it was provided. It will not be added to any mailing list or used for any other purpose without your consent.
4.5.4 Security
We use up-to-date security measures with electronic communication and on our website to protect your personal information. Any data containing personal, credit or related information which we transmit via the internet is encrypted.
CCVT is bound by the Privacy Act and is committed to complying with the Notifiable Data Breaches Scheme (NDB) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017.
The NDB requires that where a data breach is likely to result in serious harm to any individuals to whom the information relates, we are required to notify those individuals and the Office of the Australian Information Commissioner (OAIC).
4.6 Accuracy
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 CCVT.
4.7 Marketing
We may use your personal information, including your contact details, to provide you with information about products and services.
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 marketing information through a channel, like email. To do so, you will need to request that we no longer send marketing materials (except those received via statements) to you.
You can make this request by contacting CCVT.
4.8 Changes to the Privacy Policy
We may make changes to this Privacy Policy from time to time (without notice to you) that are necessary for our operational requirements or the law. Our current Privacy
Policy is available on our website.
4.9 Questions and complaints
If you have any questions, concerns or complaints about this Policy, or the handling of your personal information, please contacting CCVT.
You can also contact CCVT (see below) if you believe that the privacy of your personal information has been compromised or is not adequately protected.
Once a complaint has been lodged, CCVT 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.
Churches of Christ in Victoria & Tasmania
T: (03) 9488 8800
E: ccvt@churchesofchrist.org.au
Level 5, 111 Cecil St., South Melbourne VIC 3205
If you still are not satisfied, you can contact the Australian Information Commissioner who deals with external privacy complaints (see below).
Office of the Australian Information Commissioner
T: 1300 363 992
www.oaic.gov.au
GPO Box 5218 Sydney NSW 2001
Internal Documents
- Data Breach Policy; and
- Data Breach Response Plan
End of document