Our Data Privacy Policy

This Data Privacy Policy (“Policy”) sets out the basis which Covenant Evangelical Free Church (“we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

Personal data refers to data, whether true or not, about a member who can be identified:

(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, gender, date of birth, marital status, nationality, race, photograph, video footage, employment and other personal information.

Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

We may collect your personal data when (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes.

We may collect and use your personal data for any or all of the following purposes:

Providing pastoral and shepherding care;
Teaching and training in discipleship and disciple-making;
Connecting you to a small group as part of your discipleship journey;
Organising events to support your discipleship growth;
Informing you of any discipleship and/or disciple-making events, programs or training;
Verifying your identity;
Responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
Effecting other ministry and church management/administration;
Any other purposes for which you have consented to provide your information for.

We may share your personal data with relevant leaders, staff, vendors, volunteers, partners and service providers or other organizations, for fulfilling any of the purposes stated above.

We may also disclose your personal data, without notifying you, to outside entities if required by law or in the good faith belief that such action is necessary to:

Conform to the law or comply with any legal process served on CEFC;
Protect and defend the rights or property of CEFC; and
Act under exigent circumstances to protect the safety or physical or mental health of members, visitors, staff and volunteers of CEFC, or the public.

exception to consent requirement

We may use the personal data, without consent, for the following purposes:

– Improving, enhancing or developing new programs or services
– Improving, enhancing or developing new methods or processes for operations
– Learning or understanding the behaviour and needs of individuals in relation to providing care and services

We may also use and/or disclose personal data for our research purposes, including historical or statistical research.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we 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 and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) calendar days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email before the stipulated date in the notification to our Data Protection Officer at the contact details provided below.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

access to & correction of personal data

You are encouraged to regularly access to review and update your personal account with accurate and current information through the Voyager System which is maintained by CEFC.

If you wish to make

(a) an access request for a copy of the personal data which we hold about you or information about how your personal data had been used or disclosed over the past year, or

(b) a correction request to correct or update any of your personal data which we hold about you,

you may submit your request via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) calendar days. Should we not be able to respond to your request within thirty (30) calendar days after receiving your request, we will inform you in writing within thirty (30) calendar days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised (need-to-basis) collection of personal data, authentication and access controls (such as good password practices, need-to-know-basis for data disclosure, etc.), up- to-date antivirus protection, regular patching of operating system and other software, web security measures against risks, and security review and testing performed regularly.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, you are encouraged to regularly access to review and update your personal account with accurate and current information through the Voyager System which is maintained by CEFC.

CEFC is committed to make a reasonable effort to ensure the accuracy of the personal data we collect and keep. However, it will be incumbent on you to ensure that your personal information is updated and correct. As stated above, we encourage you to ensure your personal data you provide is accurate and current.

Retention of PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or ministry purposes.

transfers of personal data outside of singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer (DPO) if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request or complaint. Please provide the following details:

Your full name:
Your contact details:
Details of request/complaint:
Timeframe when a wrong-doing has occurred (if applicable):
Documentary evidence in support of your claim:

(to be addressed to)
Data Protection Officer
ACKCentre 2 Kallang Avenue
#10-26 CT HUB
Singapore 339407
Contact No.: (65) 63601657
Email: dpo@cefc.org.sg

Effects of policy & changes to policy

This policy is to be read in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this policy from time to time without any prior policy. You may determine if any such revision has taken place by referring to the date on which this policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 30/09/2022
Last updated : 30/09/2022