privacy in the PCV
The range of activities in which our churches and organisations engage means that there are a number of uses for personal and/or sensitive information within the PCV. The Presbyterian Church of Victoria (PCV) has made a commitment to adhere to the Privacy Act (1988 and as amended) and to the Australian Privacy Principles (APPs) that are contained in the Act. The PCV Privacy Policy and Privacy Guidelines must be read in the light of the Act and the APPs.
This page contains the following sections:
The pcv privacy programme
The General Assembly of Victoria in 2015 approved the updating and adoption of the PCV Privacy Policy and Privacy Guidelines, along with the commencement of the PCV Privacy Programme to assist and resource the Church in implementation. The PCV Privacy Programme delivers privacy training and tailored resources for the Church.
privacy policy training
PCV Privacy Policy training for the denomination is made available as part of the PCV Privacy Programme.
The following training resources are available:
Online PCV Privacy Policy Training presentation at the PCV Safe Church Youtube channel
Reading and viewing the privacy training material is recommended for all PCV personnel who handle personally identifiable and/or sensitive information about individuals in the course of undertaking their role (paid or voluntary) in the Church.
Privacy resources
The following resources are provided to serve the Church - please contact the PCV Privacy Officer via
Email: safechurch@pcv.org.au
Tel: 0499 090 449
if you have any queries in relation to these or if you require assistance in relation to a specific resource.
PRIVACY COMPLIANCE
A PCV Privacy Compliance Checklist has been provided in order to assist sessions in implementing the PCV Privacy Policy in the Church. The aim of this checklist is to assist sessions in the implementation of privacy practices within the Church. This checklist is for internal use only and does not need to be forwarded to any other PCV body. It is merely a tool to assist the Church as it seeks to implement the PCV Privacy Policy.
Personal Information Collection Notice
Whenever practical, as personally identifiable and sensitive information is collected for the church (for example contact details for participants in ministries or in the preparation of church directories) a reference to the Privacy Policy should be made. When collecting personal information the use of a privacy collection notice is necessary. Attach the following recommended notice to any form/documentation that is used to collect personal and/or sensitive information:
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.
church directory advice
If your church has a directory of contact details then the APPs and the Privacy Policy apply to this activity.
If collecting contact details by use of a physical form a template for collecting this information is provided below:
Church Directory Information Collection Form Template
If collecting the information by email or by use of an online form (for example, as part of a church management software system) refer to the template above for wording of the email/form and make sure to include the following:
The privacy collection notice
A request for the recipient to email back their consent/indicate their consent on the online form, to be included in the directory and confirmation that the contact details provided are accurate and up to date
Upon publication - whether in paper or via access as part of a church management software system - include the following notice:
"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]."
It is also recommended to include the following statement:
"The information in the Directory will not be released to any organisations outside of [insert name] Presbyterian Church. No “mass mailing”, by post or electronic mail, will be allowed without the express permission of the Session of the [insert name] Presbyterian Church."
presbytery contacts lists
Some presbyteries choose to publish a contacts list for members. Again, the APPs and the Privacy Policy apply to this activity.
If collecting contact details by use of a physical form a template for collecting this information is provided below:
Presbytery Contacts List Information Collection Form Template
If collecting the information by email or by use of an online form (for example, as part of a church management software system) refer to the template above for wording of the email/form and make sure to include the following::
The privacy collection notice
A request for the recipient to email back their consent/indicate their consent on the online form, to be included in the contacts list and confirmation that the contact details provided are accurate and up to date
Upon publication - whether in paper or via access as part of a church management software system - include the following notice:
"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]."
It is also recommended to include the following statement:
"The information in this Presbytery contacts list will not be released to any organisations outside of the Presbyterian Church. No “mass mailing”, by post or electronic mail, will be allowed without the express permission of the Presbytery."
Advice for Pastors and pastoral carers
Presbyterian pastors and pastoral carers, in the course of undertaking their pastoral duties, may from time to time collect personal and sensitive information from individuals. Advice relating to this can be found in the section "Confidential Pastoral Duties" in the Privacy Policy Guidelines.
Photo Consent
It is important to remember that privacy extends to the use of images of individuals by the Church in any Church publication or display (including online). Where possible and practical always seek to attain the permission of those whose images are being captured (whether still or moving images) for these images to be used in any Church publication or display (including online). This does not extend to personal photographs taken by individuals for personal use and that are not intended to be used in any Church publication or display (including online).
Photo consent forms for use by churches can be found at www.safechurchpcv.org.au/forms
If photos or video are going to be taken of participants at a church event, you may choose to print and display at entrances, and verbally announce to the gathering, the following wording:
“[insert church name] will be taking photos and videos today, which may be published in print or online on the church website, in publications or on social media. If you don’t want your image published, please make sure you are not in any photos or videos by moving out of the photo/video. The photographer will wait for you to move out before taking it. If you are in a photo or video we will understand this as your consent for your image to be published.”
Make sure that the photographer(s) and/or videographer(s) are instructed to ensure that people are given opportunity to move out of any photo/footage.
Privacy and children under 18
Remember that children’s privacy is also necessary in how the Church conducts children’s ministries - especially in regards to the use of children’s images in photos and videos.
Obtain permission from the parent or guardian and clearly outline the purpose of using the image of the child, how it is going to be used and for how long.
Make sure professional photographers engaged to photograph or video children during children’s ministries and events are aware that any images taken will remain the property of the Church and cannot be used and sold for other purposes. Communicate this in writing (via email is sufficient) prior to the engagement.
Do not allow photographers to be unsupervised or with individual access to children.
Do not allow individuals to take photographs of children on-site at church without their parental consent.
Do not allow individuals to post photographs of children on-site at church on social media without their parental consent.
In the case where an individual photographs and/or posts images of children without their parental consent the Session must take steps to respond and instruct any individual undertaking this conduct to cease and desist from doing so immediately. Failure to comply with this reasonable direction of Session will result in further action, including but not limited to, the individual being restricted in their access to or being refused entry to, church worship services and activities.
Be mindful of identifying personal information accompanying photographs, such as the child’s name, address or phone number. Group photographs reduce the risk of identifying children.
Only use images that are relevant to Church activities. Particular care needs to be taken when using images of children for activities that involve minimal clothing (for example, swimming and camp activities).
Be mindful of listing children’s hobbies, likes or dislikes, school, etc. when using the images as these can be used as grooming tools. It is best to avoid all such personal information as much as possible and where it is not relevant.
Be mindful of privacy settings on websites when producing images online. Most websites are public places that any person can access; however, some websites can be made accessible only registered personnel.
Provide details for parents or other persons of how to contact the PCV Privacy Officer/SCU if they have concerns or complaints around the use of inappropriate images or inappropriate behaviour in obtaining images of children.