Introduction

The Office of the Director of Safe Ministry is an entity of the Anglican Church Diocese of Sydney (“we”, “us” or “our”).

We undertake the following functions:

• administering the Diocesan Pastoral Care and Assistance Scheme for survivors of child sexual abuse, including through the appointment of ‘contact persons’ to receive allegations of abuse and applications for assistance,
• administering the diocesan complaints procedure in relation to clergy and church workers against whom complaints are made under the disciplinary ordinances of the Diocese,
• maintaining a database of persons against whom complaints have been made,
• undertaking screening of all clergy and church worker appointments for which a licence or authority is required from the Archbishop,
• having overall responsibility for ensuring that all parishes of the Diocese are child protection compliant,
• providing Safe Ministry Training to members of Anglican Churches and others (including through online means),
• providing other support and advice to parishes and diocesan organisations in respect to child protection, and
• providing a secure records repository for use by Anglican Parishes of the Diocese to store child protection and safe ministry information.

More information about our work is available on this website.

Purpose

This Privacy Policy explains how we will deal with your personal information.

Commitment

We are committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

By visiting our website, using any of our services or otherwise providing us with your personal information (or authorising it to be provided to us by someone else), you agree to your personal information being handled as set out in this Privacy Policy.

Definitions

For the purposes of this policy –
Permitted general situation includes –

• lessening or preventing a serious risk to life, health or safety,
• taking appropriate action in relation to suspected unlawful activity or serious misconduct,
• locating a person reported as missing,
• where it is reasonably necessary for establishing, exercising or defending a legal or equitable claim, and
• where it is reasonably necessary for a confidential alternative dispute resolution process.

Personal information is:  information or an opinion about an identified individual or an individual who is reasonably identifiable.

Proper administration of the Diocese includes any act or practice which is –

1. performed pursuant to or under an ordinance or resolution of the Synod or the Standing Committee of the Anglican Diocese of Sydney or a canon of the General Synod of the Anglican Church of Australia,
2. reasonably necessary to give effect to an ordinance or resolution of the Synod or the Standing Committee,
3. a discharge of the duties or exercise of the powers and authorities, however arising, of the Archbishop,
4. undertaken by or on behalf of the Registry, the Sydney Diocesan Secretariat or an officer of the Diocese in the course of administering the central affairs of the Diocese, or
5. otherwise identified in this policy as necessary for the provision of our services, or incidental thereto.

Sensitive information includes information about your health, your race or ethnic origin, political opinions, religious beliefs, philosophical beliefs, sexual orientation or practices and criminal record.

Personal information

We only collect personal information that is necessary for the proper administration of the Diocese. Having regard to our functions, this includes but is not limited to information about –

• Clergy, ordinands and lay ministers.
• Other officeholders of Anglican churches and parishes, such as wardens, parish councillors, nominators, Synod representatives, treasurers, and risk management coordinators.
• Parish safe ministry representatives.
• Parishioners and other persons who work with children in Anglican churches or organisations or who undertake or enquire about Safe Ministry Training offered by us.
• Members (and prospective members) of the Synod and boards, councils or committees of the Anglican Church Diocese of Sydney.
• Trustees of church trust property.
• Survivors of child sexual abuse and others whose personal information is collected in the course of investigating complaints and processing applications for pastoral care and assistance.
• Other people with whom we come in contact in connection with our services.

We may collect a wide range of personal information. This may include but is not limited to: name, contact details, date of birth, qualifications, next of kin and family, education, employment history or experience, roles you have held in Anglican churches or ministries, health information, criminal records history, the outcomes of Working with Children Checks and other forms of screening.

Sensitive information

Some personal information that we collect may be sensitive information. This may include, but is not limited to, information regarding –

• your personal history, health and the nature and impact of abuse you have experienced so that we can assess an application for pastoral care and assistance,
• your background, any complaints made about you or other relevant information gathered in the course of investigations or screening processes, or
• your religious beliefs such as the church you attend and your broader involvement in ministry activities.

Collection

We may collect your personal information in various ways, including through making records of face-to-face meetings or telephone conversations with you, through our website or completing of online forms, and through written correspondence (including email and other electronic means). We may also use contractors or other service providers to collect personal information. An example are the Contact Persons who receive disclosures via the abuse reporting hotline or online form.

Sensitive Information
We will only collect sensitive information about you with your consent unless –

• we are otherwise allowed or required by law to collect that information, or
• the information relates to our activities and relates solely to members of the Anglican Church Diocese of Sydney or to individuals who have regular contact with us in connection with our activities.

An example of where we are allowed by law to collect sensitive information without your consent is if a “Permitted General Situation” exists in relation to the collection of the information and it is impractical to obtain your consent to the collection.

If you provide us with sensitive information about yourself which is necessary for the provision of our services or the proper administration of the Diocese, we will treat this as collection of such information with your consent.

Third Parties
In most situations we collect your personal information directly from you. However, we may also collect personal information about you from third parties if it is impractical to collect it directly from you. An example is when we are investigating a complaint. Typically an investigator will gather information from a range of relevant witnesses without recourse to the person complained about.

We may also collect or receive personal information about you from another diocesan entity if the privacy policy of that entity permits the disclosure of the information to us. An example is the Archbishop’s Office and Diocesan Registry.

Unsolicited personal information
If we receive personal information about you that we have not requested (unsolicited personal information) we will assess whether it is information that is reasonably necessary for the proper administration of the Diocese and the conduct of our functions which we could have collected if we had solicited it from you. If we could not, we will delete or destroy the information as soon as practical after receiving it, unless we are required to retain it by law.

Consequence of not consenting to the collection of your personal information
In certain circumstances we may be required by law to collect certain personal information about you. For example, we may need to collect your name, residential address, date of birth, and other types of personal information to comply with our obligations under child protection legislation.

If you do not provide us with your personal information in such circumstances, you may be ineligible to hold certain positions or offices in the Diocese, and we may not be able to provide services or assistance to you.

Purpose of collecting your personal information

We only collect, hold and use personal information for the purposes for which it was provided, and related purposes (or directly related purposes, in the case of sensitive information) that we consider to be within your reasonable expectations or as permitted or required by law. These purposes include the proper administration of the Diocese and any other uses identified at the time of collecting your personal information.

Anonymity and the use of pseudonyms

You have the option of not identifying yourself, or of using a pseudonym, when dealing with us. In some circumstances it will be impractical for us to deal with you anonymously or through use of a pseudonym, and we may decline to provide services to you if you are not willing to provide us with your identity and other personal details or allow us to disclose your identity or personal details in the course of providing services.

Use or disclosure

Personal information we collect or hold in connection with the diocesan complaints procedure for clergy and church workers will only be used or disclosed for the purpose of that procedure, the implementation and maintenance of any sanctions or protective measures arising from that procedure and related matters.

Personal information we collect or hold in connection with the Pastoral Care and Assistance Scheme will only be used or disclosed for the purpose of that scheme and related matters.

Personal information provided to us will only be disclosed to other entities of the Anglican Church Diocese of Sydney where this is reasonably necessary for the proper administration of the Diocese or our functions. This may include, but is not limited to, disclosure to the following entities –

• Archbishop’s Office;
• Diocesan Registry;
• Sydney Diocesan Secretariat;
• Ministry Training and Development;
• Moore Theological College;
• Anglican Church Property Trust Diocese of Sydney;
• Office holders of parishes of the Anglican Church Diocese of Sydney;
• General Synod Office of the Anglican Church of Australia; and
• Professional Standards/Safe Ministry Directors in other dioceses or provinces of the Anglican Church (or other persons performing equivalent functions in those dioceses or provinces).

Where necessary we may also disclose your personal information to –

• government bodies, regulators, law enforcement agencies and any other parties where authorised or required by law,
• third party service providers, agents or contractors from time to time to help us in the proper administration of the Diocese or to otherwise provide our services, and in such event, we will generally require those parties to protect your personal information in the same way we do, and
• any other entities identified at the time of collecting your personal information, or which you subsequently request or expressly consent to us providing with your personal information.

Disclosure to overseas recipients
In general, we do not disclose your personal information to any overseas recipients. Unless a “Permitted General Situation” exists in relation to the disclosure, we will seek your consent to disclose your personal information to any overseas recipients and will outline to you who your personal information would be disclosed to and how it would be used by them.

Storage and security

We take reasonable steps to protect any personal information that we hold from misuse, interference and loss and from unauthorised access by implementing security procedures for access to our internal office areas and IT security procedures within our offices. All staff are required to maintain confidentiality unless they need to disclose it to carry out their employment duties.

Your personal information may be stored in a third-party data centre operated by Salesforce that is located overseas. We access this data through the Internet. Salesforce’s systems are subject to a number of internationally recognised privacy and security audits (see http://trust.salesforce.com).

Access

You may access the personal information we hold about you.

If you wish to access the personal information we hold about you or request that it be corrected or updated, you should contact our Privacy Officer using the contact details below.

Access to personal information is subject to certain legal restrictions and exceptions. If we decline to provide access on the basis of such restriction or exceptions we will provide you with a written notice that sets out the reasons and any other relevant information.

While we do not charge you for a request for accessing your personal information, you should be aware that we may charge a reasonable fee (which will be notified to you once you make a request) for our time and expenses in the following circumstances –

• if an extended amount of time is required to collate and prepare material for you; and
• if you wish to have material photocopied or printed.

Quality of information and correction

We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date, on the basis of information known to us. We appreciate you keeping us up-to-date if there are any changes to your personal information.

If there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete, up-to-date or is misleading, please contact us so we can update our records accordingly. In some cases we may refuse to make changes in the manner requested by you, and in such case will provide you with a written notice that explains the reasons for our refusal. In such circumstances you may provide us with a statement in respect to the need for correction and ask us to associate the statement with the information in question.

Information relating to the use of this website

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded Content From Other Websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics and Tracking Tools

We use certain third-party analytics and tracking tools that are necessary for the proper administration of the Diocese and our website. These tools collect personal information about website visitors to help us understand how our services are used and to improve our website functionality.

Types of Analytics Tools

We currently use the following analytics and tracking tools:

• Google Analytics
• Google Tag Manager
• Hotjar

Information Collected Through Analytics Tools

These tools may collect and process the following types of personal information:

• Device information (including IP address, browser type, operating system, screen size)
• Pages visited and time spent on pages
• Geographic location data (country and region only)
• Referral sources (how you reached our website)
• Usage patterns and interactions with website elements
• Mouse movements and clicks
• Keystroke activity (excluding specific content entered)

Google Analytics and Google Tag Manager

Google Analytics and Google Tag Manager are services provided by Google LLC that help us analyze website traffic and user behavior. These services process your personal information in accordance with Google’s privacy policy, which can be accessed at https://policies.google.com/privacy.

You may opt out of Google Analytics tracking by:

• Installing the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout
• Adjusting your browser’s cookie settings
• Enabling your browser’s “Do Not Track” setting

Hotjar

We use Hotjar to better understand how visitors interact with our website. Hotjar’s services include heatmaps, session recordings, and user feedback tools. Hotjar processes information in accordance with their privacy policy, which can be accessed at https://www.hotjar.com/legal/policies/privacy.

You may opt out of Hotjar tracking at any time by visiting https://www.hotjar.com/legal/compliance/opt-out.

Additional Cookie Information

In addition to the cookies mentioned in the “Cookies” section above, the following cookies may be placed on your device:

Google Analytics & Tag Manager Cookies:

• _ga: Used to distinguish users (2 years)
• _gid: Used to distinguish users (24 hours)
• _gat: Used to throttle request rate (1 minute)

Hotjar Cookies:

• hjSessionUser[site_id]: Used to store user session data (365 days)
• hjSession[site_id]: Contains session-specific data (30 minutes)
• _hjAbsoluteSessionInProgress: Used to detect the first pageview session (30 minutes)

The use of these analytics tools and the associated collection of personal information is based on our legitimate interests in the proper administration of the Diocese and our website, in accordance with the “Purpose of collecting your personal information” section of this policy.

Complaint handling

If you wish to make a complaint about a breach of this Privacy Policy or Australian Privacy Principles, you can contact our Privacy Officer using the contact details below.

You will need to provide us with sufficient details regarding your complaint together with any supporting evidence.

Our Privacy Officer who will investigate and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation within 30 days of the date your complaint is made or the date you provided us with any additional information.

If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time so please review it periodically on our website for any changes.

Where it has been updated, your continued use of our services (including online services) or providing further personal information to us (directly or via an authorised person) after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

Contacting us

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details –

The Privacy Officer
Office of the Archbishop and Registry of the Anglican Diocese of Sydney
PO BOX Q190
QVB Post Office 1230

Phone: 02 9265 1526
Email: registrar@sydney.anglican.asn.au