Privacy
1. Introduction
1.1 The policy embraces the values and ethos of the Uniting Church in Australia. As referred to in the Basis of Union, the Church acknowledges that Christ alone is supreme in the Church and that responsibility for government within the Church belongs to the people of God by virtue of the gifts and tasks God has laid upon them.
1.2 Attention is directed to the UCA Regulations and Synod By-Laws, and particularly Regulation 3.7.4.7.
1.3 The proper management of privacy related matters is essential to the success of the Church’s missional and operational activities.
2. Purpose
2.1 The purpose of this policy is to outline the obligations and expectations of Synod Mission Services (SMS) regarding the collection and management of your personal information in accordance with relevant privacy laws.
2.2 The policy serves to provide you with an understanding of the personal information we hold and the way in which we manage that information.
3. Scope
3.1 This policy applies to all SMS employees, contractors, members, third party providers of services and collaborative activities undertaken with partner organisations in support strategic and operational activities across SMS. The policy may be adopted by any church entity at their discretion as a code of best practice.
3.2 This policy replaces all previous privacy policies.
4. Regulatory Context
The Church as a not-for-profit organisation has obligations under the Privacy Act (1988) (“the Act”) and associated Australian Privacy Principles set out in Schedule 1 of the Act when collecting and handling personal information. The Act and Privacy Principles have been considered in the preparation of this policy.
5. Policy Statement
5.1 The Church recognises the importance of protecting your privacy and your right to privacy in relation to the personal information we collect and use.
5.2 We will manage the personal information we hold in an open and transparent manner, consistent with the Australian Privacy Principles and with the expectations of our position as a leading provider of community services.
6. What is Personal Information and Why Do We Collect it?
6.1 Personal information is information or an opinion that identifies an individual. Examples of personal information we collect includes names, addresses, email addresses, phone numbers, age or birth date, occupation, or job title.
6.2 This personal information is obtained in many ways including interviews, correspondence, by telephone, by email, via our website www.nswact.uca.org.au, through our activities and services, from your website, from media and publications, and from other publicly available sources. We don’t guarantee website links or policy of authorised third parties.
6.3 We collect personal information for the primary purpose of providing our services to the community, our employees, and members, providing information to our clients and stakeholders and marketing. We may also use personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
6.4 When we collect personal information, we will, where appropriate and where possible, explain why we are collecting the information and how we plan to use it.
7. Sensitive Information
7.1 Sensitive information is defined in the Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.
7.2 Sensitive information will be used by us only:
for the primary purpose for which it was obtained.
for a secondary purpose that is directly related to the primary purpose; and
with your consent, or where required or authorised by law.
8. Third Parties
Where reasonable and practicable to do so, we will collect personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
9. Disclosure of Personal Information
Your personal information may be disclosed in several circumstances including the following:
third parties where you consent to the use or disclosure; and
where required or authorised by law.
10. Anonymity
We will generally provide you with the option of not identifying yourself (or using a pseudonym) when contacting us or participating in our activities or obtaining our services unless we are authorised by law not to do so, or it is impractical for us to interact with you. In such circumstances we will only obtain as much personal information as is necessary to provide you with the service or assistance you require. If we do not have your personal information, we may be limited in our ability to provide you with the services or assistance you are seeking.
11. Security of Personal Information
11.1 Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification, or disclosure.
11.2 When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. We will destroy information in accordance with applicable laws or requirements for records retention.
12. Access to Your Personal Information
12.1 You may access the personal information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your personal information you should contact us in writing via email.
12.2 SMS will not charge any fee for your access request but may charge an administrative fee for providing a copy of your information.
12.3 To protect your personal information, we may require identification from you before releasing the requested information.
13. Maintaining the Quality of Personal Information
It is important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete, and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
14. Notifiable Data Breaches
We will comply with the Notifiable Data Breaches (NDB) Scheme and other requirements of the Act as it applies to SMS where your personal information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to you.
15. Responsibilities
General Secretary, Synod of NSW & ACT
has overall responsibility for ensuring that SMS complies with any statutory privacy management requirements whether stated or inferred in any legislation the Church is subject to as well as the principles referred to in this policy.
Executive Director, Mission Support
has delegated responsibility (on behalf of the General Secretary) for being the senior responsible officer for ensuring that privacy management supports organisational and public accountability.
General Manager Communications, Collaboration & Information
ensures that privacy management is strategically integrated as part of a broader information governance framework and linked to other organisational services as appropriate.
serves as the Privacy Champion and represents privacy management interests within SMS executive leadership; and
has overall responsibility for the implementation of, and adherence to, this policy.
Head of Information Management
develops, implements, and manages the privacy management framework (on behalf of the General Manager Communications, Collaboration & Information).
develops and implements privacy policy, procedure, and guidelines to underpin and complement privacy management.
serves as the Privacy Officer for SMS.
prepares annual reports to the General Manager on privacy matters; and
ensures that mechanisms for responding to privacy complaints are in place.
Functional Heads and Team Leaders
provide direction and guidance within their areas of accountability to ensure the requirements of this policy are adhered to.
ensure that their team considers privacy management needs with the development of any project, systems or service that may involve the use of personal information; and
report to the Privacy Officer any complaints relating to privacy related matters or access to personal information.
All Employees
be aware of and comply with the requirements of the privacy policy and all supporting procedures and guidelines; and
report to the Privacy Officer any complaints relating to privacy related matters or access to personal information.
16. Policy Responsibility, Ownership and Support
Approval: General Secretary.
Owner/Custodian: General Manager Communications, Collaboration & Information.
Support and guidance: Head of Information Management
17. Policy Updates
This policy may change from time to time and is available on our website.
18. Privacy Policy and Complaints
For any queries or complaints about our Privacy Policy please contact our Privacy Officer at:
Postal | The Uniting Church in Australia, Synod of NSW and the ACT |
19. Version history
Version | Approved by | Approval date | Effective date | Sections modified |
1.0 | Gen Sec | 13 June 2024 | 13 June 2024 | New document |
20. References
Information Governance Framework