INTRODUCTION AND PURPOSE
The application of this policy extends to all employees across Calvary and its related entities and applies to any staff engaged by Calvary and its related entities on a full-time, part-time, contract, casual, temporary or volunteer basis, (except for Calvary Christian College and Emerald OSCH).
Related entities include Calvary International Ltd, Calvary Leadership College Ltd, and Calvary Care Ltd.
WHY WE COLLECT INFORMATION
Calvary is a loving, vibrant church community that seeks to maintain meaningful and professional contact with its participants. The primary purpose of the information we collect is to facilitate connection and communication with our church community in a manner that is relevant to them. Some additional purposes why we collect information include: ensuring we keep our participants safe, collecting demographics to improve how we run activities, and marketing what we have on offer.
You are welcome to attend our Church without supplying personal information. To participate as a volunteer, enrol your children in our activities and participate in certain activities we run, relevant personal information is required to maintain our safety standards.
THE INFORMATION WE COLLECT
Images and sound
Calvary services/activities/events may be recorded using sound, voice and images. Recordings of the people attending a service/activity/event may be used and shown in other services/events including our Online Church services (broadcast internationally), to prepare resources, and for other promotional purposes and commercial activities. By attending any Calvary service/activity/event, you are deemed to have consented to Calvary using your image and voice in these recordings and for these purposes.
In the interests of security and safety, Calvary also operates security video cameras within and around Calvary premises.
Calvary will collect and hold personal information about yourself and/or your family, such as:
- Phone & mobile number
- Email address
- Age and date of birth
- Parent/guardian details if you are under 18 years of age
- When relevant, your marital status, nationality, education, employment/qualifications and family details
- Financial and bank details
- Passport, driving licence, and other personal ID information
- Records of your contact with us
- Working with Children Blue Card information
For safety and pastoral care purposes we may also collect sensitive information such as:
- Health & medical information
- Racial or ethnic origin
- Religious affiliations
- Prayer requests
HOW WE COLLECT INFORMATION
We may collect this and other types of personal information during the course of dealing with you; for example, when you:
- Visit our website
- Wish to obtain goods or services from Calvary
- Register for conferences or events
- Participate in Church activities or complete other forms
- Make an appointment to see team
- Participate in training
- Apply for a Blue Working with Children Card that is linked to our site
- Issue a complaint
- Complete an accident report
- Donate to our tax-deductible building fun
Where practicable, the purpose for which we collect personal information will be made clear at the time of collection. If you do not provide us with certain information we may be unable to provide you with access to some of our services or the assistance you have requested.
HOW WE USE YOUR INFORMATION
We will never share, sell, or rent your personal information to third parties for their promotional or commercial use.
- Keeping you informed as to services, activities, events, resource and conferences.
- To provide the products or services you have requested from Calvary including registration at events and conferences
- To answer your enquiry
- To collect demographics to improve how we run Calvary activities
- To third parties where we have retained those third parties to assist us to professionally and safely operate Calvary and provide the products or services you have requested, such as: catering and event coordinators, transport providers, health care providers, our bank, website hosts and IT consultants, and our professional advisers such as consultants, lawyers and accountants. In some circumstances, we may need to disclose information about you to third parties as part of the services you have requested.
- To participate in community research or apply for grants
- When we are required by State and Commonwealth legislation to store and share personal information with agencies defined by law – for example in child protection matters. We fulfil our obligations to the full extent of the law in these situations.
- To manage employees and volunteers
- To carry out analysis and market research and improve our website and communications
- To assist our overseas locations associated with Calvary and listed on our website at calvarycc.global, with management and administrative purposes.
HOW WE HOLD AND STORE YOUR INFORMATION
Calvary takes reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification and disclosure.
Calvary takes thorough, reasonable steps to keep secure any personal information which we hold and to keep this information accurate and up to date.
Information you provide electronically will be held on computers and servers in Calvary locations and on servers based in Australia and the USA.
If you provide information in paper form, this information will be transferred to secure electronic systems or stored in secured physical filing systems.
Where Third Party service providers are used to process and/or store your information, agreements are in place to secure your information according to applicable data protection and privacy laws and restrict the use of your information to the purpose for which it is provided.
We will hold and store your information for as long as it is required and in accordance with the Law.
Our staff and volunteers are trained and required to safeguard your information pursuant to this Policy and, using physical, electronic and procedural safeguards, we restrict access to personal information to those staff for church business purposes only.
The Internet is not a secure method of transmitting information. Accordingly, Calvary cannot accept responsibility for the security of information you send to us over the Internet or for any unauthorised access or use of that information during transmission.
ACCESS TO YOUR INFORMATION
You can request access to the personal information that Calvary holds about you by contacting Calvary’s Privacy Officer as set out below. We will provide you with access to your personal information unless we are legally authorised to refuse your request. We may charge a reasonable amount for providing access.
If you wish to change personal information that is out of date or inaccurate at any time, please contact us. After notice from you, we will take reasonable steps to correct any of your information which is inaccurate, incomplete or out of date. If you wish to have your personal information deleted, please let us know and we will delete that information wherever practicable and not limited by law.
We may refuse your request to access, amend or delete your personal information in certain circumstances. If we do refuse your request, we will provide you with a reason for our decision and, in the case of amendment, we will note with your personal information that you have disputed its accuracy. These actions would usually occur in cases where our ability to amend your personal information is restricted by law.
BREACHES TO OUR DATA SECURITY
While we will make every effort possible to ensure the security of your data, there are increasing examples of data breaches within Australia by sinister individuals and groups. If this were to occur, we will follow the procedures outlined in the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth). Under this scheme, we are required to notify you if a data breach is likely to result in serious harm to any individual whose personal information is involved in the breach. The Australian Information Commissioner will be notified of eligible date breaches according to the scheme.
We will respond to your enquiry within 30 days.
If you are not satisfied with our response to be above, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. The OAIC is a government body that is independent of our entity.
Whistleblower Policy and Procedures
Calvary Christian Church is multi-campus Church committed to high standards of behaviour amongst team members according to faith in Biblical principles and legislation governed by State and Commonwealth Law. As an employer of staff, manager of volunteers, contractor and training provider (Calvary Leadership College and work experience students), Calvary Christian Church is committed to promoting a positive culture of high ethical behaviour and therefore has policy and practice in place to detect and prevent illegal, unethical or undesirable conduct.
Moral imperative based on God’s Word
At Calvary, we have an unwavering commitment to behaving with kindness, compassion and without prejudice towards each other and those we meet via church activities. We follow the example of Jesus in all we do. Jesus commanded His followers to “Do for others what you want them to do for you … ” (Matthew 7:12) demonstrating a priority to never bring harm upon another person by intention, action or inaction. This imperative is further reinforced in Romans 12:10: “Be devoted to one another in love. Honour one another above yourselves.” Calvary policies and relevant government legislation require the same standard.
Godly behaviour is always others focussed and for the benefit of others. Sometimes this requires individuals and organisations to self-reflect, review and change. “… what does the Lord require of you but to do justice, and to love kindness, and to walk humbly with your God…” Micah 6:8. Team are encouraged to act fairly and to be humble to learn and adjust behaviour as guided by Calvary policies.
Through Jesus we understand that we are all equal. God has no favourites and loves us equally and unconditionally. We are all one in Jesus – “There is neither Jew nor Gentile, neither slave nor free, nor is there male and female, for you are all one in Christ Jesus.” (Galatians 3:28). A commitment to equity of access to church life and support is important to our actions.
Conflict and misunderstanding are normal occurrences in human relationships. Calvary acknowledges this and provides an option to address conflict and bring resolution following principles of privacy, procedural fairness and natural justice. Conflict resolution options for team will always be grounded in best practice and legislation and ensure that the wellbeing of the individual parties is paramount in all spheres of life being body, mind, emotion or spirit. In the first instance and in minor matters, team are encouraged to talk over the matter privately between parties. “If your brother sins against you, go to him and show him his fault. But do it privately, just between yourselves. If he listens to you, you have won your brother back”. (Matthew 18:15). However, some instances of behaviour require a higher level of protection for the person who has concerns and this will be provided for via policy and procedure.
There are a number of policies, procedures and practices in place where team can be guided by what constitutes ethical conduct and how they can report a wrong doing in key areas:
- Calvary Christian Church Complaint Resolution Procedure
- Calvary Christian Church Workplace Bullying Policy
- Calvary Christian Church Sexual Harassment Policy
- Calvary Christian Church Anti-Discrimination Policy
- Calvary Christian Church Workplace Health and Safety Policy
- Calvary Christian Church Employee Code of Conduct
- Calvary Christian Church Volunteer Code of Conduct
- Calvary Christian Church Work Placement Code of Conduct
- Australian Christian Churches Ministerial Code of Conduct
- Australian Christian Churches Child Protection Policy
- Australian Christian Churches Safer Churches Policy
- RiskEZI – Calvary Christian Church’s online safety management system which includes Incident Reporting and review
- Annual preparation of financial statements including an annual audit by an external auditor
- Annual Staff and Volunteer Inductions
- Regular group team meetings (usually weekly) lead by the Senior Pastor/local Campus Pastor where ethics and conduct are a regular discussion
- Regular Campus Pastor meetings (usually every 2 months) lead by the Senior Pastor where ethics and conduct are a regular discussion
- Regular supervisory one-on-one meetings lead by the Senior Pastor/local Campus Pastor where ethics and conduct are a regular discussion
- Ministry Area Handbooks (eg Youth and Kids Ministries) that detail expected behaviours and interactions towards the ministry target group
- Regular group training for ministry areas lead by the ministry Director
- A local open-door policy to the Campus Pastor
- An open-door policy to the Business Manager/Privacy Officer
- Escalation of issues to the Senior Pastor if there is an inadequate local response.
Calvary Christian Church acknowledges that there are situations which are beyond the scope of the above and meet the criteria of Regulation Guide 270 under the Corporations Act 2001 that require a response that protects the person who is bringing the disclosure. In these instances, an individual may choose to take action as a Whistleblower and receive the protections associated with this action guaranteed under the Corporations Act.
The purpose of this Whistleblower Policy is to identify how a person can voluntarily disclose Misconduct (as defined in Section 5) or suspicions of Misconduct within the Church. This Policy ensures that this disclosure can be made anonymously, confidentially and without fear of repercussion. All people utilising this Policy will be treated fairly and with strict confidentiality.
This Policy defines the protections available to Whistleblowers under the Corporations Act (2001).
Reports regarding personal work-related complaints will not be afforded protections under this Policy and will be referred to existing appropriate policy documents for alternative resolution mechanisms (See Section 7).
This Policy applies to all staff, contractors, volunteers, students (Calvary Leadership College and work experience students), and Board Members of Calvary Christian Church entities (except for Calvary Christian College and Emerald OSCH).
4. GUIDING DOCUMENTS
Corporations Act 2001
Regulatory Guide 270: Whistleblower Policies. November 2019. Australian Securities and Investments Commission.
For the purpose of this Policy:
“The Church” means Calvary Christian Church
“Misconduct” in this Policy includes conduct that:
- Constitutes an offence against, or a contravention of, a provision of any of the following:
- The Corporations Act 2001;
- The Australian Securities and Investments Commission Act 2001;
- The Banking Act 1959;
- The Financial Sector (Collection of Data) Act 2001;
- The Insurance Act 1973;
- The Life Insurance Act 1995;
- The National Consumer Credit Protection Act 2009;
- The Superannuation Industry (Supervision) Act 1993;
- Constitutes an offence against any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more; or
- Represents a danger to the public or the financial system; or
- Is prescribed by regulations for the purposes of paragraph 1317AA(5) of the Corporations Act 2001.
- Some examples of the Misconduct relevant to this Policy might be fraud, money laundering, and misappropriation of funds. It may also be engaging in detrimental conduct towards a person who has made or is making a disclosure. A disclosable matter regarding Misconduct could also include information that indicates a significant risk to public safety or the stability of, or confidence in, the financial system even if it does not involve a breach of a particular law.
- For noting is that disclosures that are not about ‘disclosable matters’ (as outlined above) do not qualify for protection under the Corporations Act.
“Whistleblowing” is the voluntary disclosure of Misconduct (as defined above) by a person who has witnessed instances of, or, holds suspicions regarding Misconduct (as defined above) within the Church.
“Whistleblower” is an officer, employee, contractor or volunteer of any entity within the Church who reports Misconduct (as defined above) in accordance with this Policy.
“False reporting” is knowingly bringing a report which is false, baseless or vexatious. Such reports will be dismissed, and no further action will be taken on these types of reports under this Policy.
All officers, employees, contractors or volunteers of any entity within the Church will be made aware of this Policy and the pathways available to report instances of (or suspicions of) Misconduct.
This current version of this Policy will be available to all officers and employees through RiskEZI – Calvary’s online risk management system. A copy will be given to any person upon request.
Nominated Whistleblower Protection Officer
The Church has nominated an Internal Whistleblower Protection Officer, to receive reports of Misconduct and protect the interests of the Whistleblower in terms of this Policy. The Church will seek to ensure that all officers, employees, contractors and volunteers are aware of the current nominated Whistleblower Protection Officer/s and mechanisms to contact them.
Where reporting within the Whistleblower’s normal reporting channels (ie. to their immediate leader or supervisor) is not desirable or appropriate, the Whistleblower may report instances of, or suspicions of, Misconduct to the Internal Whistleblower Protection Officer.
Internal Whistleblower Protection Officer: Paul Hutchinson
All reports of Misconduct made under this Policy will be assessed and investigated.
Upon receiving a report from a Whistleblower, the Whistleblower Protection Officer inform the Church’s Board Chair, the Senior Pastor, that a report of Misconduct has been received and will determine whether the disclosure is a matter of Misconduct to which this Policy applies, within 72 hours of receiving the report.
Where the Whistleblower Protection Officer determines that a report is trivial, vexatious or baseless, the Whistleblower Protection Officer will inform the Whistleblower of this assessment and no further action will be taken in relation to the report.
If it is determined that the report is a matter to which this Policy applies, the following investigation processes will apply:
- The Whistleblower Protection Officer will appoint an investigator within 7 days of receiving the report. The investigation must not be conducted by a person who may be the subject of the investigation or has connections (actual or perceived) to the persons or issues under investigation. In making this appointment, the Whistleblower Protection Officer must consider whether the appointment of an external investigator is appropriate, having regard to the nature of the Misconduct alleged and the persons implicated in the allegations.
- Investigations must be conducted in a fair and transparent manner, affording principles of natural justice to any persons implicated in a report of Misconduct and preserving the confidentiality (to the greatest extent possible) of the person.
- Investigations regarding reports made under this Policy should be completed within 21 days of the appointment of an investigator. If for any reason an investigation cannot be completed within 21 days, the Whistleblower must be informed of the delay by the Whistleblower Protection Officer.
- The investigator will provide a report confirming the outcome of the investigation to the Whistleblower Protection Officer within 7 days of completing the investigation.
- The Whistleblower Protection Officer will immediately make the report available to the Church’s Board Chair, the Senior Pastor, who will determine the appropriate action to take as a result of the investigation outcomes (in consultation with the Board as appropriate).
The Whistleblower Protection Officer will keep the Whistleblower informed generally regarding the progress of the investigation and the outcome of the investigation, subject to privacy considerations for any persons implicated in the report of Misconduct.
Persons implicated in Whistleblower report
Any persons implicated in allegations of Misconduct by a Whistleblower under this Policy are entitled to be afforded natural justice and procedural fairness during the course of the Church’s investigation of the alleged conduct. This shall include:
- Being informed of the substance of the allegations;
- Having the opportunity to be heard by the investigator about the substance of the allegations; and
- Being informed of the outcome of the investigation.
Where allegations of Misconduct are not substantiated by an investigator’s report, any persons implicated in the allegations must be formally informed of the outcome of the investigation.
Where it is determined by a Whistleblower Protection Officer that a report is trivial, vexatious or baseless and no formal investigation is required, the Whistleblower Protection Officer may determine whether or not (in their sole discretion) to inform the person against whom any allegations of Misconduct are made that a report has been received and dismissed.
Personal work-related grievances
This Policy is concerned with the disclosure of instances of (or suspicions of) Misconduct as defined in Section 5 of this Policy only and is not intended to replace existing policy documents regarding complaints resolution, discrimination, harassment or bullying (except in circumstances where such behavior may constitute Misconduct as defined in this Policy).
Reports regarding personal work-related complaints will not be afforded protections under this Policy and will be referred to existing appropriate policy documents for alternative resolution mechanisms. To be clear, a personal work-related complaint will generally concern a complaint about any matter relating to the discloser’s employment having implications for the discloser personally, which does not constitute Misconduct as defined in Section 5 of this Policy.
8. WHISTLEBLOWER PROTECTIONS
Where a Whistleblower makes a report of actual or suspected Misconduct to a Whistleblower Protection Officer under this Policy, the Whistleblower Protection Officer must take all reasonable steps to keep the identity of the Whistleblower confidential unless disclosure of the Whistleblower’s identity is required by law.
The Whistleblower’s right to confidentiality regarding their identity (unless disclosure is required by law) may only be waived with the consent of the Whistleblower.
The Church acknowledges that in some instances, a Whistleblower may wish to make a report of Misconduct anonymously. However, it also acknowledges that a proper investigation may not be possible with an anonymous complaint, as the inability to make inquiries and seek further information from the disclosure may limit the scope of any potential investigation. For this reason, Whistleblowers are encouraged to make any reports of Misconduct without the condition of anonymity and rely on the assurances provided in this Policy regarding confidentiality of their identity.
Protection of Whistleblowers
The Church is committed to protecting the rights of a Whistleblower who reports Misconduct in accordance with the procedures set out in this Policy.
A Whistleblower must not be subject to any detriment, or the threat of detriment, for making a disclosure of Misconduct. Detriment may include, but is not limited to:
- Dismissal of the Whistleblower as an employee, or alteration of the employee’s duties or position;
- Discrimination against the Whistleblower as an employee as compared to other employees;
- Harassment or intimidation of the Whistleblower;
- Harm or injury to the Whistleblower (including psychological harm);
- Damage to the Whistleblower’s property, reputation or business or financial interests;
- Threats of any of the above.
Where a Whistleblower believes that they have been subjected to detriment for making a disclosure of Misconduct, the Whistleblower should raise these concerns with a Whistleblower Protection Officer as soon as practically possible.
Subjecting a Whistleblower to detriment for making a disclosure of Misconduct will itself be considered an instance of Misconduct and investigated in accordance with this Policy.
Where a Whistleblower is implicated in reports of Misconduct which are investigated and found to be substantiated, the protections under this Policy will not apply to any disciplinary action taken by the Church in relation to the Misconduct itself.
9. MORE INFORMATION
If you have a query about this Policy or need more information, please contact the Business Manager (+61 7 4722 9260).