- Objective of Policy
The objective of this Policy is to protect the privacy of individuals dealing with TCS and to explain how TCS collects, uses, discloses and stores Personal Information in accordance with the APPs. This Policy also describes why TCS collects Personal Information and how You can access and correct Personal Information about You.
- Why TCS collects Personal Information
Collecting your Personal Information is essential for TCS to be able to properly and efficiently carry out its functions, including to inform congregants and other people interested in its services and activities.TCS also uses Personal Information to help it in assessing a person’s suitability for TCS membership. Information from applicants for membership may be collected and retained on file.
TCS also collects the Personal Information of job applicants, volunteers and contractors offering to provide services to TCS, to assess their suitability for a position, role or engagement with TCS and to manage the relationship between TCS and those who are appointed or engaged.
- How does TCS collect your Personal Information?
TCS collects information, directly from You and from third parties, by means such as application forms, letters from congregants, phone and email enquiries, website and survey responses and photographers at TCS events and activities.Information may be collected when you:
- become a member of TCS;
- subscribe to any publication of TCS;
- access the TCS website;
- apply for employment or a volunteer position with TCS; or
- attend any event or activity run or hosted by TCS.
Personal information may also be collected where TCS is required to do so by law (including as relevant for charitable collection purposes, child protection purposes, work health and safety purposes and other legislative requirements in Australia).
Personal Information provided to TCS will be handled by TCS in accordance with this Policy and the APPs, regardless of who provides it.
- What type of information does TCS collect?
The information that TCS collects may include Your name, gender, contact details, date of birth, photographs of You or Your family members, details of family members (living or deceased), credit card details, or other information that is required by TCS to conduct its dealings with you and/or to be used in connection with the operation of services, events and activities that TCS may from time to time provide. Generally, TCS also collects Sensitive Information in the nature of Your religious belief or affiliations. No Sensitive Information will be collected without Your consent.
- Notification of collection of information
If Personal Information about You is collected from someone other than You and if TCS is notified that You are not aware that TCS has collected the Personal Information then TCS will take reasonable steps to notify You that the Personal Information has been collected and will be dealt with in accordance with this Policy and the APPs.
- Use of Personal Information
TCS provides services and publications to its congregants and other people and organisations. In order to obtain and maintain membership of TCS and to receive services and publications from TCS, You will need to submit Personal Information to TCS. Information that You provide to TCS will be stored in a database procured by TCS. Personal Information provided by You for the purpose of obtaining any services and publications may be tracked, edited and/or disclosed in order to:
- provide You with the services, communications and publications You have requested;
- help Us develop, improve, manage and administer all of the services and publications TCS provides to You;
- seek donations and appeals;
- comply with the law;
- investigate, respond to and defend claims made against, or involving TCS; and
- enforce a contract or agreement which TCS has with You.
TCS may also use Your email address and phone number to:
- send You follow-ups on services, communications and publications You have enquired about; and
- keep You informed of changes to the services and publications offered by TCS.
TCS also uses the Personal Information that it collects for other purposes such as preparing marketing material, providing member support, market research and obtaining references.
TCS may use your Personal Information for direct marketing purposes to inform You, among other things, about life cycle events and other events, services, functions, charitable works, classes and other activities through weekly and other emails and periodic publications. If TCS has received Personal Information from third parties, TCS may use or disclose it for direct marketing if You have consented to receiving direct marketing or it is impracticable to obtain that consent. TCS will also give You the opportunity to opt out of receiving direct marketing communications.
Names and photographs of attendees at events and activities hosted by TCS may be used for the purpose of reporting on those events and activities to congregants and other persons interested, as well as for marketing purposes and keeping an archival record of those events and activities. TCS may publish the names and photographs in TCS newsletters, on the TCS website, or on the online social media pages of TCS or its Chief Rabbi. TCS may on occasion provide the names and photographs to Jewish community news publishers such as The Australian Jewish News and J-Wire.
TCS may publish the names of those who donate to certain appeals and projects unless requested not to do so. If you wish to be removed from the published list of donors, please advise TCS in writing.
The purposes for which TCS uses personal information of job applicants, staff members, volunteers and contractors include (but are not limited to):
- managing the individual’s employment, engagement or contract;
- managing or obtaining insurance;
- marketing; and
- satisfying TCS’s legal obligations, for example in relation to child protection legislation and workplace health and safety.
- Disclosure of Personal Information
TCS will only disclose Your Personal Information to persons or bodies external to TCS where permitted by the Act, including in the following circumstances:
- where You consent to the disclosure;
- where required by law such as under a subpoena issued by a court; and
- to service providers that TCS engages to perform functions for TCS and supply TCS with services which enable it to communicate with You, complete transactions with You or provide You with services or publications (e.g. mailing campaigns to congregants, maintaining databases, and processing payments).
One such third party engaged by TCS is ShulCloud. ShulCloud provides a web cloud-based synagogue management software system that helps TCS to manage its relationship with its members. The ShulCloud system provides TCS with an online database and cloud storage of membership data. It provides TCS members with an online portal to receive information, pay bills and update their records.
Although TCS seeks to deal with reputable third parties, TCS cannot control, and will not be liable for, any use of Your Personal Information by any third party to whom Your information is sent.
- Photography at TCS events
TCS views the taking of photographs as an important way to share information and promote participation in our events and activities. Such photographs of You or Your child / dependant (or other family member) may be published by TCS or on our behalf in any medium (e.g. newsletter, publications, website or social media) and may be labelled with the name of the person photographed and the event at which the photograph was taken. If you have objections to the taking of your or your child’s photograph at a TCS event, please, in advance, inform the photographer and the TCS office at firstname.lastname@example.org. If we receive such a request, we will make all reasonable efforts to prevent the individual photographing of you or your child/ dependant (or other family member), or the publication of the photograph. However, please note that you or your child/ dependant (or other family member) may still be photographed incidentally in the background at events and in group photos, which is an unavoidable consequence of attending events and activities at which photographs are being taken and TCS shall have no liability in connection with this. If at any time you see a photograph or you, your child/ dependant (or other family member) that is on the TCS’s website or other social media managed by TCS and would like it removed please email such request to the TCS office at email@example.com.
- Cross-border disclosure of Personal Information
TCS will not disclose Personal Information outside Australia without complying with the APPs or other applicable privacy legislation. This may occur where (as is the case with ShulCloud, which is based in the USA) TCS has a reasonable belief that the recipient is subject to a law or binding scheme that protects the information in a way that, overall, is at least substantially similar to the way that the APPs protect the information, and there are mechanisms that You can access to enforce that protection.
- Security and storage of personal information
Upon receipt of Personal Information, TCS takes all reasonable steps to protect that information against loss and unauthorised access, use, modification or disclosure. TCS stores the Personal Information in a secure environment to include password protected electronic files, a password protected database, maintaining virus protection software, securing paper files in locked cabinets and ensuring physical access is restricted to authorised personnel.Although TCS has implemented security measures in relation to Personal Information, as the TCS website is linked to the internet (and the internet is inherently insecure) TCS cannot provide any guarantee regarding security of the Personal Information and other data provided to us or collected through the TCS website. TCS will not be liable in any way in relation to any breach of security, unauthorised access to records maintained by TCS or unintended loss or disclosure of Personal Information or other data due to the TCS website being linked to the internet or otherwise.
- Retention of Personal Information
TCS retains Personal Information for the duration of its dealings with You and for an indefinite period after its dealings with you become inactive. In the case of TCS members, TCS retains an historical record of memberships including name, ID acronym or account number, address, email addresses, mobile and home phone numbers, birth and marriage dates, ages, family names (children, grandchildren, great grandchildren), family relationships, deceased family and date of passing, photo (in some instances) and membership account data.Apart from Personal Information retained for its historical membership records, TCS takes reasonable steps to destroy or de-identify Personal Information within a reasonable period after TCS no longer needs the Personal Information for any use or disclosure permitted by the APPs, unless a longer period of retention is necessary or permitted to comply with law, resolve disputes or comply with technical and legal requirements and constraints related to the security, integrity and operation of services provided:
- TCS no longer needs the Personal Information for any use or disclosure permitted by the APPs; and
- TCS is not required under any law or order to continue retaining the Personal Information.
- Access to Personal Information
You can ask TCS for Personal Information about You if it is stored by TCS. The information will be provided within a reasonable time after TCS receives Your request, at a reasonable cost based on time spent in retrieving the information. Requests for information may be sent to TCS using any of the Contact Details provided in this Policy.TCS may refuse to give access to Personal Information under certain circumstances permitted by law, such as where the request for access is frivolous or vexatious, giving access to information is unlawful, or if TCS suspects unlawful activity or anticipated legal proceedings with You. If TCS refuses to provide information, TCS will provide written notice to You within reasonable time that sets out the reasons for refusal unless it is unreasonable to do so.
In addition to access provided by TCS, it is proposed that TCS members will be able to access their Personal Information held by ShulCloud via the online member portal.
- Quality of Personal Information
TCS is committed to ensure that the Personal Information collected or used or disclosed is reasonably accurate, up-to-date and complete.
- You may seek correction
If You become aware that the information stored by TCS is wrong, You have the right to have such information rectified. This facility is provided free of charge to You. You may rectify the information by providing any necessary documentation. Such details may be supplied by using any of the Contact Details provided in this Policy. The information will be corrected within a reasonable time after receiving all necessary documents. It is proposed that TCS members will also be able to make corrections and additions to their Personal Information held by ShulCloud via the online member portal.
- Notification of correction
If TCS corrects Personal Information about You that TCS previously disclosed to another organisation and if You request TCS to notify that other organisation of the correction, TCS will take reasonable steps to give that notification unless it is impracticable or unlawful for TCS to do so.
The APPs allow for You to deal with TCS without the need to identify Yourself or by using a pseudonym. However, considering the nature of the services provided by TCS, it is impracticable for TCS to deal with You if You have not identified Yourself. If TCS is not able to collect Your Personal Information, it may not be able to provide appropriate services and publications or do business with You or any organisation with which You are connected.
- Closed circuit television
TCS operates a closed circuit television system for security and safety purposes, and individuals may be filmed while on TCS premises.TCS will only use the footage and by the providers of our security services for security purposes. TCS does not use surveillance videos for other purposes and the footage is not publicly available. Surveillance cameras are not located in any bathrooms or change room facilities.
- When visiting our website
- Links to other websites
The TCS website or emails may contain links to sites operated by third parties, including other communal organisations. Such linked sites are not controlled by TCS and TCS is not responsible for the privacy practices of the site operators. Before you disclose your personal information to any linked sites, TCS advises you to examine their privacy policies and terms and conditions of use. The links to third party sites available on the TCS website or in any emails sent to you by TCS do not imply that TCS endorses or has reviewed those third party sites.
- Privacy complaints and enquiries
TCS welcomes feedback about privacy issues and will endeavour to attend to all questions and complaints promptly. You can contact TCS about any privacy issues via the Contact Details below.If You are not satisfied with the response from TCS, a complaint can be lodged with the Australian Information Commissioner on or You can call the OAIC enquiries line on 1300 363 992.
In this Policy:
- “Act” means the Privacy Act 1988 (Cth).
- “APPs” means the Australian Privacy Principles as set out in Schedule 1 of the Act.
- “Personal Information” means information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Examples include name, address, phone number, email address, credit card number, bank account number, physical traits, hobbies, usage patterns, family members and income.
- “Sensitive Information” includes information about Your racial or ethnic origin, health, religious beliefs or criminal record,
- “ShulCloud” means ShulCloud, LLC, a Delaware, USA limited liability company.
- “TCS” means The Central Synagogue ACN 000 136 434.
- “You” means an individual dealing with TCS, and “Your” and “Yourself” have corresponding meanings.
- Contact Details
Email: firstname.lastname@example.orgTelephone: (02) 9355 4055
Mail: PO Box 169, Bondi Road, Bondi NSW 2026