PRIVACY POLICY
BACKGROUND
As a small business Horizon Church is exempt from the application of the Australian Privacy Principles. Notwithstanding Horizon Church is committed to protecting privacy where possible by complying with the provisions of the Privacy Act that relate to handling Personal Information.
This Policy explains how we handle Personal Information relating to individuals, whether or not they are attenders of a Horizon Church celebration service or other ministry, participant in a Horizon Church program or are a service provider/customer of Horizon Church, so as to take all reasonable steps to ensure the Privacy of your information.
By providing us with your Personal Information, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Policy.
TERMINOLOGY
In this Policy the expressions “we”, “us” and “our” are a reference to the Company.
The expressions “you” and “your” refer to each and every individual whose personal information we may handle from time to time.
A list of defined terms is set out below:
- APPs means the Australian Privacy Principles.
- Company refers to Horizon Church Limited ABN 89 123 149 799, its subsidiary companies, operating divisions and business units.
- Personal Information means information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion, including symbolic identifiers such as citizenship and immigration status.
- Privacy Act means the Privacy Act 1988 (Cth).
PROTECTING PERSONAL INFORMATION
Types of Personal Information Collected
We only collect, use or disclose an individual’s Personal Information to the extent that this is reasonably necessary for one or more of our functions or activities.
This includes the following kinds of information:
1. Business partner information, namely:
- contact person’s name and position title
- the name of the organisation which employs the person
- telephone numbers
- fax number
- street and postal addresses
- email address/es
- area of interest by category and industry
- bank details (if Horizon Church is to receive payment or make payment for services received)
- Australian Business Number (ABN)
2. Prospective employee, volunteer and contractor information, namely:
- contact details (name, address, telephone numbers, email etc)
- personal details including personal details of emergency contact person/s, and date of birth
- country of birth/citizenship, residency and/or visa details, Tax File Number details
- details of current/previous employment or volunteer involvement
- religious beliefs
- skills, experience, qualifications, drivers license details
- information and opinions from referees for prospective employees and candidates for volunteer work
- work and personal history checks (e.g. Police check, Working with Children Check, Blue Card, etc) may be required for some roles. Individuals may be required to provide some information for a Police check). In some cases the Working with Children and police checks will be received, then stored securely or destroyed
- in some situations, it is necessary for Horizon Church to collect or receive information about an individual’s health. In this circumstance, Horizon Church will advise why the information is being collected and whether and to whom it will be released
3. Congregation participants and prospective participants
- contact details (name, address, telephone numbers, email etc)
- personal details including personal details of emergency contact person/s, and date of birth
- religious beliefs
- Bank, Credit Card details, Tax File Number
- details of current/previous employment or volunteer involvement
Method of Collection
Our preference is to collect Personal Information about an individual directly from that individual unless it is unreasonable or impracticable for us to do so. However, we may collect Personal Information from third parties during job recruitment processes for example from your nominated referees and/or through police or background checking processes.
Personal Information will generally be collected from you in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on our website.
Purposes of Collection
Purposes for which we may collect Personal Information include, but are not limited to:
- provide or inform you of Horizon Church services
- process an application to become a volunteer or employee of Horizon Church
- facilitate placement in an appropriate service
- assist with services whilst an individual is employed or engaged as a volunteer of Horizon Church
- process donations and provide accurate receipts
- pay for services
- establish and manage partnerships and relationships
- receive services
- facilitate ongoing fundraising and marketing activities
- comply with legal obligations and provide transparency relating to donated funds.
- to consider job applications and whether to employ an individual;
- to retain an individual as a contractor;
- to interview and consider an individual as a prospective employee or contractor;
- to engage with a potential customer or supplier;
- for complaints handling or data analytics purposes; and
- for any other purpose permitted by law.
Use and disclosure
We will generally use and/or disclose Personal Information for the primary purpose of collection and reasonably related secondary purposes, unless you consent to another use or an exception under the APPs or Privacy Act applies. Secondary purposes might include service improvement programs, disclosure of metrics for statutory reporting purposes, and disclosure to maintenance personnel or other third party contractors (including outsourced and cloud service providers) who may be unable to avoid accessing Personal Information in the course of providing technical or other support services to our Company.
Access, Correction and Further Information
We will take such steps as are reasonable to ensure that the Personal Information which we collect remains accurate, up to date and complete. We will provide you with access to your Personal Information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us via the details below if you:
- wish to have access to the Personal Information which we hold about you;
- consider that the Personal Information which we hold about you is not accurate, complete or up to date; or
- require further information on our Personal Information handling practices. Horizon Church 7 Stapleton Ave Sutherland 2232 AUSTRALIA T: 9521 2933 E: [email protected]
Privacy Officer: Deb Lenzo – Pastoral Care Pastor
There is no charge for requesting access to your Personal Information but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the Personal Information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.
Storage
Typically, we will store Personal Information in hard copy and electronic form.
Security
We will take reasonable steps to:
- protect the Personal Information held by us from misuse, interference and loss;
- protect the Personal Information held by us from unauthorised access, modification or disclosure; and
- destroy or permanently de-identify Personal Information once we no longer require it for our business purposes.
Openness
From time to time, we may change our policy on how we handle Personal Information or the types of Personal Information which we hold. Any changes to our Policy will be published on our website and you are encouraged to check the website regularly for updates. You may obtain a copy of our current Policy from our website or by contacting us on the details listed above.
Complaints
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your Personal Information, you should advise us via the contact details set out above.
Procedure
- All new employees, contractors and volunteers will be required to read and understand this Privacy policy and where possible be provided with training on Privacy regulations and the requirements and effects of the Privacy policy on private information they have access to.
- Horizon Church will undertake an annual review of private information (hard copy and electronic) ensuring the commitments of the Horizon Church Privacy policy are adhered to, including the secure storage and/or destruction of Private information.
- No private information should be transmitted electronically over email or any other non-secure or unencrypted electronic transmission means (eg SMS, Social Media, instant messaging etc). This includes a person’s credit card details, bank account details and Tax File Numbers.
- Horizon Church will provide regular opportunity for persons or entities they hold Private Information on, to ensure accuracy of the Private information held
- Horizon Church will provide a simple process to unsubscribe or request the destruction of Private Information.