The website www.safeplaceservices.org.au (hereafter "the website") is operated by Safe Place Services (hereafter "SPS") of the Seventh-day Adventist Church (Australian Union Conference) Limited (hereafter "SDAC [AUC] Ltd), PO Box 650 Wahroonga 2076 NSW Australia, for the Church throughout Australia and New Zealand. By 'the Church' we mean the Conferences and Unions that cover Australia and New Zealand, and their incorporated and affiliated entities, companies, departments and services and their constituent local Churches, church plants, and companies of believers.
The Commonwealth Privacy Act (2000) regulates how personal information is handled. For example, it covers:
- how your personal information is collected (e.g. the personal information you provide when you fill in a form)
- how it is then used and disclosed
- its accuracy
- how securely it is kept
- your general right to access that information
The SPS website (and service) complies with this as follows:
1. INFORMATION COLLECTION
No information is stored by the site. All information submitted via the website, such as using the on-line volunteer pledge OR the on-line forms in the Allegations/Complaints section of the website, is encrypted and sent to a dedicated secure SPS email system.
2. HOW INFORMATION IS USED
Information is only used for the purpose in which it was submitted. For example, on-line Volunteer Pledge forms are receipted to the Conference-region user (usually the Conference Safe Place Coordinator, committee chairperson, or the secretary), using the dedicated secure SPS email system.
Information is also used for: providing advice and feedback to individuals, groups and entities within the Church; responding to (and assessing) risk to individuals, groups or entities within the Church.
3. HOW INFORMATION IS DISCLOSED
No information is disclosed by SPS to third parties or organisations outside the Church, except as is required under mandatory reporting laws for notifying authorities of situations of abuse, harm or neglect to children and young people, or reporting of a like-manner in accord with the Church's Policy on reporting misconduct, abuse and assault to authorities (note: authorities include but may not be limited to Police and statutory child protection services). Records and files held by SPS may also be requested by Police, Courts or legal representatives. It is the Policy of SPS to cooperate with such a request, order or subpoena by disclosing the requested/relevant information. In some cases, it may also be deemed that a person has a 'natural justice' right to certain information. SPS may be duty-bound to disclose certain requested/relevant information in such cases and will therefore do so.
Since SPS is a point-of-access for receiving information in the Church system, including receiving private and sensitive information, it is necessary to share/send private information "on a needs to know basis" to the relevant entity within the Church for their response and actioning on certain matters.
SPS, in coordinating risk assessments and investigations, may also disclose private information to its agents or contractors. These agents of contractors may be external legal, professional standards/conduct, and investigative firms. This enables the Church to conduct investigations and risk assessments in a manner which minimizes the perception of bias in "the Church investigating itself, or one of its own", by offering a more transparent, impartial, and objective analysis and gathering of information and evidence from all parties.
This use and disclosure of information, including private information, occurs in accordance with the policies and procedures of SPS as adopted by the SDAC (AUC) Ltd and reviewed and amended from time to time.
4. HOW SECURELY INFORMATION IS KEPT
SPS keeps information secure as follows:
On-line forms submitted via the website use a dedicated, secure email server separate to the Church's regular "firstname.lastname@example.org" system as used throughout the South Pacific Division.
Hard copies of private information are kept in lockable filing cabinets when active and in secure, fire proof, combination lockable safes when in archive.
5. RIGHT TO ACCESS PRIVATE INFORMATION
SPS allows individuals to access private information held about themselves. This allows for it to be checked, updated and corrected if needed. When SPS releases, or provides access to private information, every care is taken to blank out or omit the private information of other people. However, someone close to a situation may still be able to identify - or believe they can - certain people or private information. SPS does not release reports or documents provided to it by other parties, since the original author/service/company hold may hold the copyright over such documents and therefore a request for the release of such a document should be made direct to the originator of the source, not to SPS. SPS may also limit, or deny, access to certain private information if it: jeapodizes, or has potential to, any law-enforcement process or interest; any investigative process or interest; or any risk assessment process or interest. SPS may also limit, or deny, access to certain private information if it is believed doing so may, or has a high liklihood of, placing and individual, group or entity at risk (either directly or indirectly).
6. SPECIAL MENTION
The SPS National Childsafe Database operates in accord with the SDAC (AUC) Ltd 'Safe Place Policy', 'National Childsafe Database Policy', and other SPS policies and procedures.
The SPS email newsletter only sends periodic emails from SPS to users who subscribe. Once subscribed, a user may unsubscriber at any time. SPS does not subscribe anyone, but cannot guarantee that another party might not subscribe a person without their consent, knowledge or actioning. Whilst SPS has no control other that, such users may unsubscribe at any time and report it to their email and ISP providers. SPS does not send 'spam', nor does SPS provide its subscription list, or any details of it whatsoever, to third parties and other companies or coorporations. On occasions, if a product or service is in accord with the goals and purpose of SPS, SPS may include a link or brief about a product or service, if it is deemed to be of likely relevance and usefulness in SPS fulfilling its goals and purposes. The primary goal of the SPS email newsletter is to keep people informed of updates and developments in: child protection; responding to harm, abuse and neglect to children and young people; creating and sustaining safe environments for children and vulnerable people; and promoting resources and established standards of 'best practice' for implimenting safeguarding in the Church.
In New Zealand, Privacy Legislation and principles outline that a person has the right to access private information about them in the form of their choice. SPS seeks to recognise this right, so far as is practical, but in exercising this right SPS will not accept any responsibility or liability for costs associated with doing so. Rather, any such expense will remain the responsibility of the individual.