By interacting with, submitting information to or signing up for any activity or event organised by Truth Baptist Church (“TBC”), you agree and consent to TBC collecting, using, disclosing and sharing of your personal data, for the purpose of engagement, operational planning of activities, as well as communication of events, programmes and church-related information, and other purposes as set out in TBC’s Personal Data Protection Policy. You also agree that any information or data submitted to TBC has been voluntarily provided and that it is reasonable to voluntarily provide such data or information. TBC respects personal data and privacy, and will only share such information with third parties on a required basis. Should you wish to withdraw or limit your consent, please write with full particulars to our Data Protection Officer at our church office.
1. Introduction
Truth Baptist Church (“TBC”, “we”, “us”, or “our”) is committed to safeguarding the personal data entrusted to us by individuals. This policy outlines the principles and practices adopted by TBC in the collection, usage, and disclosure of personal data in compliance with the Personal Data Protection Act 2012 (“PDPA”).
2. Policy Statement
2.1 TBC will collect personal data relevant to the purpose of the collection or if it is mandatory in order to accomplish the purpose in accordance with the PDPA. In compliance with the regulatory requirements, we will:
- Respect individuals’ rights;
- Be open and honest to the individuals whose data is held by TBC; and
- Provide training and support for staff and authorised personnel who handle personal data, so that they may confidently comply with this Policy.
2.2 TBC is also committed to being open and transparent and will respond to any legitimate inquiries from individuals regarding the use, storage, and accuracy of their personal data in a timely manner.
3. Collection, Use and Disclosure of Personal Data
3.1 Purposes
3.1.1 TBC collects, uses, processes, discloses and/or transfers personal data of its members, worshippers at its services, attendees of its activities (physical or virtual), visitors and staff for purposes reasonably required by it as a place of worship with its attendant activities and programs. These purposes include the following:
- planning, managing, conducting and implementing activities, events and programmes such as bible teaching, church ministry, fellowship and discipleship;
- providing services to and building TBC’s relationship with members, worshippers and visitors;
- sending communications in connection with TBC’s activities or events, including publicity notices / invitations;
- publishing church-related information, including church bulletins and other publications;
- sharing of testimonies;
- responding to and following up on queries or requests (including prayer and counselling requests) submitted to TBC;
- maintaining records such as membership, participants of activities and programmes, baptism, marriage, birth, death and financial pledges and giving;
- managing and administering employment relationships with staff such as work-related dealings, evaluation of performance, crediting salaries, administering staff benefit schemes and conducting audits on finance claims;
- managing and administering TBC’s operations, functions or other relevant matters, including audit, accounting, risk management and record keeping; and
- such other purposes as may reasonably be appropriate in the circumstances of the collection of personal data.
3.1.2 Such communications may take the form of voice calls, SMS, other messages receivable on electronic devices (such as WhatsApp, Line, WeChat, Skype, Messenger), email, fax or post.
3.2 Collection of Personal Data
3.2.1 TBC collects personal data via the following:
a. Application to join the church as a member and/or to be baptised, or for employment;
b. Registration for events, courses, seminars or other activities organized by TBC;
c. Interaction with the Pastors/staff for official purposes;
d. Responding to a request for additional personal data;
e. Personal Data submitted to TBC for any other reason.
3.3 Consent
3.3.1 TBC shall seek consent from the individual to collect, use or disclose the individual’s personal data, except in specific circumstances where the collection, use or disclosure without consent is authorised or required by law. Consent may be collected through written documentation (such as consent form, written note) or electronically (web page, email, any other electronic forms).
3.3.2 Personal data shall be collected directly from individuals. TBC may also collect an individual’s personal data from third parties with the individual’s consent or where required by law.
3.3.3 TBC may not be able to provide certain services if individuals are unwilling to provide
consent to the collection, use or disclosure of certain personal data.
3.4 Deemed Consent
TBC may assume an individual to have given consent to the collection, usage, and disclosure of personal data in situations where the individual has voluntarily provided information for obvious purposes. Such purposes include registering and/or participating in the church worship services, events, activities, courses or programmes of TBC.
3.5 Disclosure and Transfer of Personal Data to Third Parties
3.5.1. In the course of processing personal data for the above purposes, TBC may disclose such personal data to third parties within or outside Singapore. These third parties include:
- governmental organisations or authorities that TBC is required by law to disclose the data;
- individuals who are legally entitled to the data;
- third parties who require the data in order to process and operate programmes in which an individual intends to participate;
- third parties that provide services to TBC, such as legal, accounting and auditing services; and
- such other persons as may reasonably be appropriate in the circumstances of the collection of personal data.
3.5.2. Disclosure to third parties outside Singapore shall only be to organisations that are required or undertake to process the data with a comparable level of data protection as that required under Singapore law.
3.6 Retention
3.6.1. TBC will retain personal data for as long as it is necessary to serve the purpose for which it has been collected. Once the data in TBC’s possession is no longer necessary to serve the purpose for which it was collected, the data will be destroyed or anonymised in a secure manner.
3.7 Accuracy Obligation
3.7.1 TBC will make reasonable efforts to ensure that the individuals’ information is kept accurate and complete.
3.7.2 TBC shall deem information submitted by individuals as complete and accurate. Hence, the individuals remain primarily responsible and liable to ensure that all personal data submitted to TBC is complete and accurate. They are to inform TBC of any change to their personal data in TBC’s records.
4. CCTV, Video Recordings, Audio Recordings and Photography
4.1 CCTV, video recordings, audio recordings and photos captured within the premises of TBC or captured for during TBC’s worship services, or other events, activities, courses, programmes organised (or jointly organised) by TBC are the property of TBC. The recordings and photos may be used by TBC for communications/publicity purposes in print and electronic media, including but not limited to the church bulletins, church website, church newsletter, church publications and online photo galleries.
4.2 By entering TBC’s premises or participating in TBC’s worship services, or other events, activities, courses or programmes organised (or jointly organised) by TBC, you are deemed to have given consent for the use of your image captured in any picture or video recording by TBC for the above-mentioned purposes.
5. Protection of Personal Data
5.1 TBC keeps all personal data confidential and accessible to only authorised personnel and for authorised purposes. Reasonable and appropriate security measures are taken to ensure the storage of personal data is protected against unauthorised access and theft.
5.2 In the event of a security breach, the Data Protection Officer (“DPO”) shall be notified. The DPO shall investigate if such breach is a malicious act and shall take appropriate action after consulting with TBC’s Pastors and pastoral team.
6. Access and Correction of Personal Data
6.1 The DPO has oversight of the personal data access or correction requests and ensures that they are processed in accordance with this policy.
6.2 Requests for personal data access or correction by individuals (including any inquiries or complaints) shall be submitted to TBC in writing to the DPO at our church office.
6.3 The DPO shall verify the identity of the individual or request for additional information before responding to the request for access or correction. A record will be made of such requests and replies for future reference and verification.
7. Consent Withdrawal
7.1 An individual may withdraw consent to the use and disclosure of personal data at any time unless the personal data is necessary for TBC to fulfill its legal obligations. A written notice of request for withdrawal of consent can be submitted with proof of identity to the DPO at our church office.
7.2 Upon receipt of a written request for withdrawal of consent, TBC may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed. Depending on the nature of the withdrawal of consent, TBC may not be able to continue providing the services to you.
8. UPDATING THE POLICY
8.1 This Policy may be updated from time to time to take account of changes in policy, technology, and/or to ensure compliance with any legislative changes.