Crossroads Christian Church Privacy Policy (Version 18 June 2009)

Your privacy is important to us.

This statement outlines the Crossroads Christian Church Inc (Crossroads) policy on how Crossroads and its associated ministries are to use and manage personal information provided to or collected by it.

Crossroads respects and values the personal information entrusted to it. Crossroads will comply with the National Privacy Principles (NPPs) in the Commonwealth Privacy Act (1991), hereafter referred to as the Act, in all its dealings with your personal information.

The primary purpose of collecting this information is to enable Crossroads to provide spiritual and pastoral care and in meeting its legal obligations, to provide care for children while they are under its supervision, and to discharge its duty of care.

1. What kind of personal information does Crossroads collect? How is it collected?

Information collected by Crossroads about members of the Church and visitors to the various congregations is, almost without exception, voluntarily provided by the member or visitor. This information generally relates to contact information, relationships within a family group and association of individuals with various groups or events within the Church context – such as membership of a home group or congregation.

1.1 Personal information you provide

Crossroads will generally collect personal information held about an individual in one of the following ways:

• forms, including online forms, completed either by the person or by a parent/guardian;
• face to face meetings;
• interviews;
• telephone calls.

1.2 Personal information provided by other people

In some circumstances Crossroads may be provided with personal information about an individual from a third party, e.g. a reference about an applicant for a position.

Personal information collected from children may be disclosed to their parents or guardians. Parents or guardians may seek access to personal information collected about them and their son/daughter as specified in part 5.3 of this policy.

1.3 Exception in relation to employee records

This policy does not apply in relation to the treatment of an employee record, where the information is directly related to a current or former employment relationship between Crossroads and the employee. These records are specifically exempt from the application of the Act.

2. How will Crossroads use the personal information you provide?

Crossroads will use personal information you provide for any of the following purposes:

• the provision of spiritual and pastoral care services to its community (the primary purpose);
• such other secondary purposes as are related to the primary purpose;
• any other purpose to which you have consented.

Crossroads will use health information for the primary purpose that you provide it for, and not for any other secondary purpose, unless one of the exceptions in the Act applies.

2.1 Children and their parents and/or guardians

Crossroads collects information about children and their parents and/or guardians to enable it to provide spiritual and pastoral care. Information may also need to be collected if Crossroads organizes other activities such as play groups or sporting events.

The purposes for which Crossroads uses personal information of children and their parents and/or guardians include:

• Communicating with parents and/or guardians about matters relating to their child's spiritual and pastoral care;
• Day to day administration;
• Satisfying Crossroads’ legal obligations and allowing Crossroads to discharge its duty of care.

In some cases where Crossroads requests personal information about a child or parent and/or guardian and the information is not obtained, the child may not be able to be enrolled in a Crossroads program for which the information was requested.

2.2 Adults

Information is used for purposes similar to those relating to children.

2.3 Job applicants, staff members, volunteers and contractors

The purpose of collecting information related to job applications, or information related to volunteers, contractors or members of staff is to assess the suitability of the person or persons for a particular role in Crossroads and, if successful, employ or engage the person or persons concerned.

The purposes for which Crossroads uses this information includes:

• Administering the person's employment or contract;
• Insurance requirements;
• Crossroads legal obligations.

2.4 Taxation

This information may also be used for accounting purposes, including complying with taxation requirements if required by law.

3. To whom might Crossroads disclose personal information?

Subject to the Act, Crossroads may disclose personal information held about an individual to:

• Government departments;
• Medical practitioners;
• Volunteers or staff who provide some form of service to members of Crossroads and need to know information for pastoral or duty of care reasons;
• People providing services to Crossroads;
• Recipients of Crossroads publications;
• Parents and/or guardians;
• Anyone you authorise Crossroads to disclose information to.

Information received from members of Crossroads or those who use its services may be used to seek financial or other forms of support from them. We will not disclose any personal information to third parties for fundraising purposes without obtaining your prior consent.

4. How does Crossroads treat sensitive information?

Crossroads will not collect sensitive information about you unless you consent or it is required by law. If sensitive information is collected, then it will be used and disclosed only for the purposes for which it was provided, or for a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.

Crossroads does not normally collect health information, but in the event that they do so, it will only be in accordance with its obligations under the Act.

5. Management and security of personal information

Crossroads staff are required to respect the confidentiality of personal information and the privacy of individuals.

5.1 Updating personal information

Crossroads endeavors to ensure that the personal information it holds is accurate, complete, and up to date. Persons may seek, and are encouraged, to update their personal information held by Crossroads by primarily accessing their data stored on the Crossroads CCB site, via the login provided on the Crossroads homepage (http://www.crossroads.asn.au) or by contacting the Church Office (office@crossroads.asn.au).

Crossroads has procedures in place to ensure that it conducts reviews of the personal information that it holds to ensure that the personal information it has collected or proposes using or disclosing is actually complete and up to date.

Crossroads makes every effort not to store personal information longer than necessary.

5.2 Security of Personal Information

Crossroads has in place steps to protect the personal information it holds from misuse, loss, unauthorised access, modification or disclosure by use of various methods which as a minimum standard includes storing paper records in locked cabinets and pass-word protected access rights to computers which contain computerised records of personal information.

Crossroads will take reasonable steps to destroy or de-identify personal information if it does not need it for any purpose for which it may have been used or disclosed.

Crossroads holds some information (such as name and address details, group involvement and attendance records) about members of the church congregation on servers provided by Church Community Builder (CCB).

CCB maintains personal information in a manner that complies with the Act and the National Policy Principles.

CCB uses servers that reside in the United States and the privacy of the information is subject to a Service Agreement between Crossroads and CCB as well as law relating to the US State and Federal Laws. The service agreement does not allow CCB to monitor, edit, use, distribute or disclose any of the data without Crossroads' express written permission or as may be required by law. The services provided by CCB ensure data is protected through encrypted links and secured services and is fully maintained and backed up.

Crossroads Staff will not place the following types of information on a web-based server, although this information may be required to be stored in other forms:

• Personal financial account information, such as bank account details, credit card details, or giving records;
• Medical information;
• Pastoral counseling notes, or similar sensitive information.

5.3 You have the right to check what personal information Crossroads holds about you

Under the Act, and with some exceptions, an individual has the right to obtain access to any personal information that Crossroads holds about them, and to advise Crossroads of any perceived inaccuracy. Children will generally have access to their personal information through their parents and/or guardians.

To make a request to access any information Crossroads holds about you or your child, please contact Crossroads Office (office@crossroads.asn.au or 02 6247 4409) and request that we send you a 'Request for Personal Information Form - Content Only', which must be completed before Crossroads can give access to you to personal, sensitive or health information. Crossroads may require you to verify your identity and specify what information you require.

There are exceptions as to when Crossroads may provide you with access to personal information. It will depend upon the circumstances surrounding your request as to whether Crossroads can disclose that personal information to you. As such, each request for access to personal information will be assessed on a case by case basis.

Crossroads will not charge you for applying to lodge a request for access, but if it does provide the personal information there may be a charge associated with Crossroads complying with that request.

If Crossroads denies you access to personal information, you will be given reasons for that denial.

5.4 Consent and right of access to the personal information of children

Crossroads respects every parent and/or guardian's right to make decisions concerning their children's spiritual upbringing and care. Generally, Crossroads will refer any requests for consent and notices in relation to personal information of a child to the parent and/or guardian. Crossroads will treat consent given by a parent and/or guardian as consent given on behalf of the child, and notices to parents and/or guardians will act as notices given to the child.

5.5 You have the right to have information removed from Crossroads storage.

It is your right to have information removed from storage by Crossroads Christian Church, subject to any legal requirements that may be placed on that information. If you wish to have information deleted a request should be submitted to Crossroads Office (office@crossroads.asn.au). There may be cases where removal of information will exclude participation by a person in an event due to the requirements of Crossroads in discharging its duty of care (see also 2.1).

6. Identifiers

Crossroads does not adopt Commonwealth identifiers, such as Medicare numbers, to identify an individual.

7. Anonymity

If you make arrangements with Crossroads, you have the option of not identifying yourself whenever it is lawful and practicable that you not have to do so. Please contact the Church Office to implement this (office@crossroads.asn.au or 02 6247 4409).

8. Enquiries

If you would like further information about the way Crossroads manages the personal information it holds, please contact the Church Office.

Appendix I - Email

Crossroads makes use of email to communicate and adheres to the Spam Act 2003. The Spam Act has three steps of application; Consent, Identify and Unsubscribe.
Consent is given through the form of "Inferred Consent" from information taken from information slips and other transactions of personal information. In all transmissions made by email, Crossroads will clearly identify that the message is from Crossroads and will give a short explanation as to how to unsubscribe from the mailing list.

Please note that emails sent to Crossroads through the address may be viewable by all staff. Emails sent to the personal addresses, normally denoted by a staff member’s name , are maintained by their respective owner, but they are subject to viewing by other staff members from time to time for administration purposes. All staff are aware the significance of your privacy.