Guidelines
related to the Presbyterian Church of Victoria Privacy Policy
and for other associated organisations within the PCV
Scope
The church and any person or organization affiliated with the church are bound by privacy and data protection legislation in Australia. As a result, anyone who deals with the collection, management and transfer of personally identifiable data on behalf of the church will need to understand and comply with the terms of the church’s privacy policy. These guidelines are specifically for the privacy policy applicable to the church. However, there may be other church privacy policies in use for various church activities, (e.g. schools and aged care facilities). If there are questions or concerns as to the terms of this policy, or which church policy might apply to your situation, please contact the Privacy Officer whose details are at the end of this document.
Personally identifiable information includes information which can identify you as a person ‐ such as your name, your address and other specific details about you. This information is referred to as ‘personally identifiable information’ and the collection and use of personally identifiable information is regulated in Australia and in other countries by specific legislation.
Sensitive information is similarly regulated by legislation and the church’s privacy policy. Sensitive information includes information about a person’s:
health
financial status
racial or ethnic origin
political opinions
membership of a political association
religious beliefs or affiliations
philosophical beliefs
membership of a professional or trade association
membership of a trade union
sexual preferences or practices, or
criminal record
The church’s privacy policy applies to both personal and sensitive information collected by the church where no other privacy policy applies.
Adoption of the Church’s Privacy Policy
Sessions, boards of management, presbyteries, and members of other church committees should familiarise themselves with the privacy policy and minute their adoption of it.
General Rule
Personal information must only be used or disclosed for the purposes allowed in the privacy policy.
If there is reason to believe that collected information may be used for purposes not included in this privacy policy, further permission may be required from the person whose information has been collected.
Personally identifiable information and sensitive information are both defined in the privacy policy. All personally identifiable information and sensitive information collected by the church should be held securely and used only as allowed by the policy.
Types of Personally Identifiable and sensitive information collected include:
Lists and records identifying individuals (including congregation members, adherents, attendees of church activities, committee members and elders, baptismal and wedding registers).
Directories or newsletters identifying individuals and their contact or other personal details.
Sensitive information collected during pastoral duties.
Oral information provided at public meetings (e.g. church service) identifying an individual.
Other information collected as part of the operations of the church’s usual activities.
In respect of these common circumstances a consistent and thoughtful approach should be applied to let persons whose data we are collecting know how and why we collect their information and how we use it.
Notice to use when information is collected
Whenever practical, as personally identifiable and sensitive information is collected for the church a reference to the privacy policy should be made.
As an example, a paragraph included on any form used to collect information could read: 'Personal and sensitive information provided by you and collected by the Presbyterian Church of Victoria will be used in conformity with our Privacy Policy (which can be found at www.pcv.org.au and www.safechurchpcv.org.au or mailed to you on request). This information is collected for the primary purpose of the [insert name] Presbyterian Church and may be used for any activities conducted or promoted by the [insert name] Presbyterian Church. If you do not want your information to be used by us please do not provide it to us.'
Notice to include when information is published
The following statement should be included in church directories, newsletters or notice sheets distributed which identify individuals:
‘The information in this document has been collected and published in conformity with the privacy policy of the Presbyterian Church of Victoria (which can be found at www.pcv.org.au and at www.safechurchpcv.org.au or mailed to you on request). If you would like to update any information in this document please contact us at [provide contact address and email]’
Confidential Pastoral duties
If a minister, other church staff or another body of the church intends to record personal and sensitive information arising from deputations or counselling sessions, any person whose data will be collected should be informed of this and advised that:
a) the records will be kept pursuant to the church's privacy policy;
b) the purposes for which the collected information will be used; and
c) information collected will not be disclosed to any third party and securely destroyed when the purpose of collection is no longer relevant or it is no longer appropriate to maintain the record(s). For example, the minister has moved parishes or retired.
An example of such advice is:
‘Any personal and sensitive information collected will be kept confidential and used only as allowed by the privacy policy of the Presbyterian Church of Victoria for purposes relating to the [insert reason for collecting information]. If you do not consent to my retention and use of your information for this purpose, please tell me. A copy of the church’s privacy policy can be found at www.pcv.org.au and at www.safechurchpcv.org.au or mailed to you on request.’
Conclusion
All church staff and volunteers should be regularly reminded that both personal information and sensitive information such as health, financial status, and marital status is regulated by law and by the church’s privacy policy. Consent from persons disclosing the personal information and the sensitive information should be gained before providing that information to others.
ACCESSING INFORMATION YOU HAVE PROVIDED TO THE PRESBYTERIAN CHURCH OF VICTORIA
When seeking access to your own personal information collected from you and held by the church, you need to provide proof of your identity, consistent with the identity checks used by other organisations, known as the 100 point check:
Please ensure that your documents are current, contain your full name and add up to at least 100 points. Document 100 points must include ONE Primary Document, and at least ONE Secondary Document which must contain a photograph.
PRIMARY IDENTIFICATION DOCUMENTS - points value of 70
Only ONE form of identification accepted from this category
Birth Certificate/Birth Extract
Australian Passport (Current, or expired within the previous two years, but not cancelled)
Australian Citizenship Certificate
International Passport (Current, or expired within the previous two years, but not cancelled)
Other document of identity having the same characteristics as a passport e.g. diplomatic/refugee (photo or signature)
SECONDARY IDENTIFICATION DOCUMENTS - points value of 40 or 25
Your initial Secondary Documents will score 40 points, any additional documents will be awarded 25 points each
Current license or permit (Government Issued)
Working With Children Check/Teacher's Registration Card
ASIC/MSIC Card
Public Employee Photo ID Card (Government Issued)
Department of Veteran's Affairs Card
Centrelink Pensioner Concession Card or Health Care Card
Current Tertiary Education Institution Photo ID
Reference from a doctor (must have known the applicant for at least 12 months)
Foreign/international driver's license
Proof of age card (Government Issued)
Medicare Card/Private Health Care Card
Council Rates Notice
Property Lease/Rental Agreement
Property Insurance Papers
Tax Declaration
Superannuation Statement
Seniors Card
Electoral Roll Registration
Motor Vehicle Registration or Insurance Documents
Professional or Trade Association Card
If you wish to use more than one of these documents they must be from different organisations
Utility Bills (e.g. Telephone, Gas, Electricity, Water)
Credit/Debit Card
Bank Statement/Passbook
Requests for access are considered on a case-by-case basis and may or may not be granted, either in full or in part.