This policy has been adopted by Kairos Prison Ministry Australia (KPMA) in an endeavour to protect the privacy of our participants and volunteers.
Because of its small size and scope of its operations, KPMA is not legally obliged to comply with the requirements of the Privacy Act (Commonwealth) 1988 however we do seek to be guided by the National Privacy Principles (NPPs) set out in the Privacy Act. Staff and volunteers should seek to be guided by these principles.
- In this policy, a reference to “KPMA” means Kairos Prison Ministry Australia (a company limited by guarantee) and its associated bodies.
- KPMA seeks to comply with the NPPs. If there is any inconsistency between this policy and the NPPs then the policy will prevail.
- Subject to paragraph 4, KPMA will only use personal information for the primary purpose for which it is collected. In most cases, the purpose will relate to the programs organised by KPMA and the associated administrative functions.
- Those functions include maintaining personal information for the purpose of recording the attendance on KPMA programs and the involvement in activities subsequent to the participation in the KPMA programs. The information may be disclosed to authorised officers of KPMA to facilitate the KPMA programs.
- KPMA does not seek to obtain or retain any personal information from inmates of Correctional Centres who become participants in its Courses.
- KPMA will only use personal information about an individual for a secondary purpose (i.e. something beyond the scope of the primary purpose) if that individual has consented or the use is otherwise permitted by the NPPs.
- KPMA will take reasonable steps to keep the information secure and will, subject to the NPPs, comply with any request from a person to correct or remove his or her information.
- Personal information collected by KPMA may be sensitive information for the purpose of the NPPs (e.g. medical information necessary to participate in a KPMA program). Non-profit organisations, such as KPMA are permitted under the Privacy Act to collect sensitive information without a person’s express consent. However, KPMA will endeavour to seek to obtain consent from a person if sensitive information is sought for something other than the primary functions of KPMA described in paragraph 3.
- The operating procedures (whether or not they are formalised in a manual) of KPMA will seek to comply with this policy and the NPPs.
- The KPMA Chair is empowered to receive and deal with any complaint that the company has not complied with this policy.
National Privacy Principles we believe relevant to KPMA and which guide our behaviour include:
- If it is lawful and practicable to do so, we will give people the option of interacting anonymously with us.
- We will only collect personal information that is necessary for our functions or activities.
- We will only use fair and lawful ways to collect personal information.
- We will get consent to collect sensitive information unless specified exemptions apply.
- We will ensure at the time of collection the individual is aware of what the information will be used for, who will have access to it, and how the individual can access or change it.
- We will only use or disclose personal information for the primary purpose of collection unless one of the exceptions in National Privacy Principles 2.1 applies
- We will ensure as much as possible the personal information we collect, use or disclose is accurate, complete and up-to-date.
- We will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure.
- We will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed
Staff and volunteers should take particular care in relation to:
- the publication of personal information in Church or similar newsletters, the Kairos website and promotional material.
- the recording and publication of voices and images of individuals, especially inmates and their families, who as a population are considered less free to give informed consent.
- the use and security of all personal information, especially sensitive information, held by Kairos staff and volunteers in their homes or in KPMA offices.
- speakers engaging in deputation on behalf of Kairos, using illustrations involving inmates or
their families, protecting the privacy of these individuals
During Kairos programs, with their emphasis on vulnerability, volunteers, participants and guests will share information about themselves which they expect will be treated respectfully. The passing on of such confidences is defined as ‘gossip’. There is no room for ‘gossip’ in the Kairos ministry.
Forms and other means of collecting information for Kairos are to contain the following statement: