PRIVACY POLICY

Privacy Policy

1. Introduction

The Christian Network (TCN) is a Religious, non-profit organisation of member
Churches which in the course of our functions, are allowed to process religious and
philosophical beliefs of their members as well as prospective members. Our
relationships, connections and partnerships are voluntary and stretch across the
country of South Africa.

This Privacy Policy was compiled in an endeavour to abide with ‘The eight
conditions for lawful processing” as set out in the Protection of Personal
Information Act, No. 4 of 2013 (called “POPIA”):
1. Accountability (with responsibility.)
2. Processing limitations (lawfully.)
3. Purpose Specific (with a reason.)
4. Further Processing limitation (compatible with a purpose.)
5. Information Quality (data should be correct.)
6. Openness (how information is gathered: with purpose, consent and voluntarily.)
7. Security Safeguards (to prevent loss, damage, unauthorised destruction,
unlawful access, and breach of data security).
8. Data Subject Participation (respecting the rights of a data subject).

For further information and definitions of the terminology of these eight conditions,
refer to https://popia.co.za

We commit to protect and respect your Personal Information. We want to give you
peace of mind with the following Privacy Policy and clarification in our context of
working with churches, senior pastors, their leaders and members:
“Data Subjects” –a person to whom the Personal Information relates, being
typically a congregant of the member Church or the Church themselves.
“Operators” – as it relates to TCN, these are persons who may process
information on behalf of the responsible party (members, volunteers, Life Group
Leaders, etc.).
“Personal Information” – means information relating to an identifiable, living,
natural person, and where it is applicable, an identifiable, existing juristic
person, including, but not limited to—
(a) information relating to the race, gender, sex, pregnancy, marital status,
national, ethnic or social origin, colour, sexual orientation, age, physical or
mental health, well-being, disability, religion, conscience, belief, culture,
language and birth of the person;
(b) information relating to the education or the medical, financial, criminal or
employment history of the person;
(c) any identifying number, symbol, e-mail address, physical address, telephone
number, location information, online identifier or other particular assignment to
the person;
(d) the biometric information of the person;
(e) the personal opinions, views or preferences of the person;
(f) correspondence sent by the person that is implicitly or explicitly of a private
or confidential nature or further correspondence that would reveal the contents
of the original correspondence;
(g) the views or opinions of another individual about the person; and
(h) the name of the person if it appears with other personal information relating
to the person or if the disclosure of the name itself would reveal information
about the person;
“process or processing’ means any operation or activity or any set of
operations, whether or not by automatic means, concerning personal
information, including—
(a) the collection, receipt, recording, organisation, collation, storage, updating or
modification, retrieval, alteration, consultation or use;
(b) dissemination by means of transmission, distribution or making available in
any other form; or
(c) merging, linking, as well as restriction, degradation, erasure or destruction of
information.
“Responsible Party” – The person or body who determines how and why to
process a data subject’s personal information. The Staff employed in TCN or a
member Church.
“Special Personal Information” means the religious and philosophical beliefs
of Data Subjects and other information defined in paragraph 3.
“Third party operators” – External parties outside of the authority of TCN
who have access to Personal Information e.g. PaySpace, Online Gmail,
Dropbox, OneDrive etc.

2. Purpose of this Policy

This Privacy Policy is made available to assist and give insight into and
understanding of the operations of TCN and how we process your information in
terms of laws that regulate our relationships.

This policy will also explain your and TCN’s rights and obligations concerning this
Policy and POPIA.
It is important that you read this Privacy Policy together with any supplementary
Privacy Policy or fair processing notice we may provide on specific occasions when
we are processing Personal Information about you, so that you are fully aware of
how and why we are using your information. This Privacy Policy supplements the
other notices and is not intended to override them.

3. Scope

The scope of this Privacy Policy is to explain and include this Privacy Policy of
TCN, as well as covering the areas of our Personal Information Sharing Policy[7],
Data Protection Policy[8],Security Compromises Policy[9], BYOD Policy[10],
CCTV, Video recordings and Photographic Images Policy[11] and the Data
Retention Policy[12.]

4. Personal Information we might collect from you

All information we process is provided to us voluntarily except where the law
requires us to obtain additional information, for instance, through investigation. You
will be informed in writing, or by this Policy, if TCN is collecting Personal
Information unless there is a justifiable reason for non-disclosure which will not
negatively influence you.

We may collect the following Personal Information from you for a relevant, specific
purpose and legitimate interests with your direct or indirect interactions with TCN:
Identity information – includes first name, maiden name, surname, , marital
status, title, date of birth, photograph, gender, ID number, and marriage licence
reference.
Contact information – includes physical and postal addresses, email address
and telephone numbers.
Financial information – includes account numbers, bank account and Card
payment details. Details about payments to and from you and other details of
events you have attended; products or services you have purchased from us or
gifts/contributions you have donated to us.
Technical information – includes Internet Protocol (IP) address, your login
information, browser type and version, time zone setting and location, browser
plug-in types and versions, operating system, platform and other technology on
the devices you use to access this website.
Profile information – includes your username or similar identifier, password,
interests, preferences, feedback, and survey responses linked to your profile.
Usage information – includes information about how you use our website,
events, products, and services.
Marketing and Communications information –includes information about
your preferences for receipt of communications.
Audio or video recordings during an event.
Special and sensitive Personal Information:
– Medical conditions revealed during interaction with one of our staff/leaders.
– Religious information/affiliation/convictions.
– Prayer requests which may contain sensitive information.
– Some of you have volunteered to share your personal situation, health,
religious affiliation, convictions, testimonies with TCN and/or its leaders
and gave us consent to use them in our media and communications.
– When dealing with member/s, according to this Act – TCN may gather special
Personal Information of a member’s family if they need to make active
contact with them and the member has no objections to this. This is to assist
us in effectively supporting and ministering to the member/s involved.

This information described above will include any information you may provide
through this website when you interact with us, register for an event, donate, or
apply for or work as a volunteer within TCN.

As a faith-based non-profit organisation, we collect information about conferences,
meetings, training, and events you attend. These are close to the Special Personal
Information criteria. These may include details about religious or philosophical
beliefs, race or ethnicity, trade union membership, political opinions and
persuasions, information about your health, sex life and sexual orientation, criminal
behaviour, and biometric information. We will always make it clear to you when we
collect this information and why.

Children
The TCN website is not intended for children. We may gather information about
children which the parent/guardian submits voluntarily to us when attending one of
our conferences, trainings or events. We do, however, respect and protect their
details and will only communicate events for children with the senior pastors of the
churches.

We will not collect Personal Information that is not relevant to our purpose, unless a
legitimate interest, or specific law applies which requires us to do so.

Please take note that where we need to collect your Personal Information as part of
our relationship with you, and you fail to provide this information when requested,
we may not be able to carry out a commitment we made to you.

5. How do we process this information?

From 1 July 2021, we will process any new documentation that you complete based
on the consent you have given to us by providing your information voluntarily.

The Personal Information we gather assists us to send you the necessary information
that you need, when you need it. If we need your Personal Information, you will be
contacted directly unless directly contacting you is not necessary, this is to:
• Keep you connected and informed.
• Administrate your donation or manage, administer, and promote mutual
beneficial activities (direct marketing.)
• Ensure we know how you prefer to be contacted.
• Keep a record of your correspondence, donations history, questions you have
asked us, or comments or complaints you have made.
• Understand how we can improve your membership experience based on your
interests and interaction with us.
• Understand how we can improve our services, and the resources or information
we send out.
• Contact you in your capacity as a representative of an organisation such as a
church, school, or business.
• Manage our websites and social media accounts.
• Manage our HR function.
• Prevent and detect crime and where we need to comply with a legal or
regulatory obligation.
• To see when to assist underprivileged pastors and churches in TCN according to
our Financial Policy.
• Inform you should there be a specific cause that we know you may want to be
involved in.
• Under the POPIA, TCN may process Personal Information that was deidentified (Not able to be linked to a specific person) for statistical purposes.

Religious organisations like TCN are allowed to process religious and philosophical
beliefs of their members and family members of their congregation, even if they are
not part of the church. Only if they are making active contact with those family
members and the family member(s) have not objected in writing.

We will not:
• Further process Personal Information if it is not compatible with the original
purpose for collection.
• Share your Personal Information with unauthorised people.
• Give your Personal Information to a third-party for marketing purposes or an
. international connection without your consent.

6. Right of Access and Obligations

It is important that the Personal Information we hold about you is accurate and
current.
Please keep us informed if your Personal Information changes during your
relationship with us.

We are committed to assist you to:
Update your information – You are responsible to keep your Personal
Information and that of your church/ministry, marriage officers up to date,
correct and complete.
Request correction of the Personal Information that we hold about you in order
that we have complete and accurate information, to better assist you and
perform our functions.
Request deletion of your Personal Information where it is inaccurate, incorrect,
or out of date. You may also ask us to delete or remove your Personal
Information where you have successfully objected to processing, where we may
have processed your information unlawfully or where we are required to delete
your Personal Information to comply with the law. Please note that because of
tax and banking laws we may not be able to delete some of your Personal
Information e.g. Financial information.
Consent – Be notified and informed when and what you give us consent to
process in an easily understandable language and format. E.g. Membership
forms, etc.
Object or complain about processing of your Personal Information where
there is a particular situation which makes you want to object to processing
because you feel it impacts on your rights.
Request the transfer of your Personal Information to you or to a third party. In
certain circumstances, we may be able to provide you, or a third party you have
chosen, with your Personal Information in a structured format.
Withdraw consent – The law gives you the right to withdraw the consent you
previously gave to process your Personal Information within lawful boundaries.
Since TCN is an NPO and membership and communication driven, withdrawing
your consent on some of your Personal Information could make it difficult for
us to provide certain services to you. We will advise you if this is the case at the
time you withdraw your consent.
Request access – Should you request access to your Personal Information please
submit this request in writing and specify or send a copy of the relevant
document. Should someone else request your Personal Information you will be
notified.
Request restriction of processing of your Personal Information to suspend the
processing of your Personal Information where:
(a) You want us to establish the information’s accuracy;
(b) Our processing of the information is unlawful;
(c) You need us to hold the information; or
(d) You have objected to our processing of your information but we need to
verify whether we have an overriding legitimate basis to process it.

Please contact our office and Information Officer, should you feel you have reason
to make requests or object, which will enable TCN to assist your request and to
change our systems should your objection be valid.

We may need to request specific information from you in order to help us confirm
your identity and to ensure that you have a right to access Personal Information. This
is a security measure to ensure that Personal Information is not disclosed/shared with
any person who does not have the right to receive it.

If you are a member, or are on probation or you are a friend of TCN, you have the
right to receive the Personal Information of people in relationship with TCN with
their consent. However, please note that you do not have the right to share that
information on social media or with any parties outside of TCN.

TCN does not normally have any cross border sharing but should one of our
international partners request Personal Information you will be notified and given
the option to engage directly with them.

7. Personal Information Sharing Policy

We will share some of your Personal Information with parties as follows:
• Other TCN members and leaders for collaboration.
• Prospective new church and ministry members.
• TCN leadership to enable them to serve you as set out in TCN’s Membership
Policy.

We require all operators and third-party operators to respect the security of your
Personal Information and to treat it in accordance with the law. We do not allow our
third-party operators to process your Personal Information for their own purposes
and only permit them to process your Personal Information for specified purposes
and in accordance with our instructions.

We do not share your Personal Information with third parties for marketing
purposes.

8. Data Protection Policy and who sees your information
Internal:

We ensure that there are proper controls and processes in place to protect your
Personal Information. For example, Personal Information in our possession, which
you submit on a physical form will be stored in lockable cupboards. Personal
Information submitted online e.g. completing of online forms are encrypted and
stored on a secure server.

Third-Party Operators and Members:
Your information may occasionally be passed to third party operators that perform
functions on our behalf, such as sending postal mail, couriers, bulk SMS, email or
analysing data. These companies may only process your information to perform
these functions and may not process it for any other purposes. Should we ever need
to make use of a third party operator, a contract will be put in place to protect your
Personal Information under the obligations of POPIA when supplying a service to
TCN. If they fail to, they will be held liable.

This website may include links to third-party websites, plug-ins, and applications.
Clicking on those links or enabling those connections may allow third parties to
collect or share information about you including Cookies. We do not control these
third-party websites and are not responsible for their Privacy Policy. When you
leave our website, we encourage you to read the Privacy Policy of every website you
visit. However, despite all the security and protections we put in place, the Internet
is not guaranteed to be 100% secure. Therefore, you submit data at your own risk.

You are obliged to responsibly discard Personal Information of members, churches
on probation or friends of TCN, should you have such Personal Information.
Similarly, you must discard Personal Information if you find that you are processing
Personal Information which does not apply or is not relevant to your relationship
with them. This request further applies to Personal Information on personal devices.

9. Security Compromises Policy

You will be notified immediately if there was any data security compromise and
steps taken to remedy the compromise if any reasonable grounds to believe Personal
Information has been accessed, processed, otherwise used or acquired by an
unauthorised person.

10. BYOD Policy (Bring Your Own Devices)

The TCN members and leaders were made aware to not save your Personal
Information on their personal devices (BYOD) beyond what is needed to enable us
and them to serve and support you well. Devices are password access protected.

11. CCTV, Video recordings and Photographic Images Policy

Please note that it is your own responsibility to take note of any signs of notification
of CCTV recordings, Video recordings or photos taken when attending a TCN
conference, training or meeting at a venue we may use. The CCTV recording is to
protect the property of the venue and is within your interest. By “posing” for a
photo, or taking part in a video recorded event, it is considered that you are giving
your consent to the use of your image. If any children are in attendance the above
will be the responsibility of the parent/guardian of the children.

12. Data Retention Policy

We commit to retain your Personal Information only for as long as it is needed and
required by the POPIA and for other legal requirements e.g. Financial Information
for tax purposes. TCN’s financial records are archived with one anchor church at a
secure site, and electronic copies of Financial Information or other Private
Information are stored on secure password protected servers.

If you resign from TCN and leave your relationship with TCN, we will keep the
necessary information required by law, but will make sure that no future contact is
made with you.

13. Changes to this Privacy Policy

This Privacy Policy may change from time to time to accommodate amendments to
POPIA or any other changes or updates of the law. We will publish any changed
versions here on our website should we make any amendments in the way that we
treat your Personal Information.

In the event that you may want to comment or make suggestions about this policy,
please email us at: .

Our Information Officer can be contacted through this email or through the postal
address on our website.