Privacy Policy

CHURCH OF SCIENTOLOGY RELIGIOUS EDUCATION COLLEGE INC
PRIVACY AND DATA PROTECTION POLICY
Church of Scientology Religious Education College Inc ('the Church') is fully committed to compliance with the requirements of the Data Protection Act 1998 ('the Act'), which came into force on 1 March 2000. The Act is enforced by the Information Commissioner's Office ('ICO').

The Church has laid down procedures that aim to ensure that all staff who have access to any personal data held by or on behalf of the Church, are fully aware of their duties and responsibilities under the Act.

Personal data means data relating to a living individual who can be identified from that data. Data means name, address, phone number, etc. Personal data is also other information about an individual, this includes opinion about an individual, race, ethnic origin, the persons political opinion, their religious beliefs, trade union membership, physical or mental health, sexual life, criminal convictions or proceedings, etc.

The Act says that anyone who deals with personal data must comply with Eight Principles of good practice. These are:

Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met.
Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
Shall be accurate and, where necessary, kept up to date.
Shall not be kept for longer than is necessary for that purpose or those purposes.
Shall be processed in accordance with the rights of data subjects under the Act.
Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
The Church needs to collect and use certain types of personal data or information about living individuals for religious operational purposes. This personal information must be dealt with properly whether it is collected on paper, in a computer, visually, audio, electronic, etc. There are safeguards to ensure this in the Data Protection Act 1998.

This policy applies to all UK branches and offices of the Church, and applies to all staff. It has been approved by the Church Trustees (who have legal responsibilities for the Church corporation). The purpose of this policy is: (i) to enable the Church of comply with the law in respect of the data it holds about individuals; (ii) to follow good practice; to protect the Church's members, staff and other individuals; and (iv) to protect the Church from the consequences of a breach of its responsibilities.

The types of personal data that the Church might collect includes information about current, past and prospective volunteer religious workers; current, past or prospective members of the Church who have donated for religious services, books or other materials from the Church; information about past or current suppliers of goods and services to the Church; and others with whom the Church communicates such as professional and other advisors.

The Church regards the lawful and correct treatment of personal information as very important and therefore takes steps to ensure that personal information is treated lawfully and correctly. To this end the Church fully endorses and adheres to the Principles of Data Protection, as detailed in the Data Protection Act 1998. Church volunteer staff who obtain, handle, process, transport and store personal information for the Church must adhere to these Principles.

The Church will, through appropriate management, strict application of criteria and controls:

Observe fully conditions regarding the fair collection and use of information.
Meet its legal obligations to specify the purposes for which information is used by ensuring that its entry in the Data Protection Register maintained by the Office of the Information Commissioner is adequate and kept up to date. The purposes for which the Church holds personal data and a general description of the categories of people and organisation to whom this personal data may be disclosed is listed in the entry for the Church in the Data Protection Register.
Collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements.
Ensure the quality of information used.
Apply strict checks to determine the length of time information is held, and ensure that personal information is not kept for longer than necessary.
Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: the right to be informed that processing is being undertaken, the right of access to one's personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information. The Church will take steps, for instance, to ensure that a person's status on Church mailing lists is updated to 'ask off' within 48 hours of receipt of a request for removal. The Church also implements appropriate technical and organisational security measures to safeguard personal information, including ensuring that computers are equipped with passwords and that only authorised persons have access to any files containing personal data (including Addresso), and that files are kept secure with respect to external access in the case of both computer and manual files.
Ensure that personal information is not transferred abroad without suitable safeguards. (In particular, no personal information or records containing personal information may be transferred to Church of Scientology International (or any other Church corporation outside the EEA) without the express permission of the person concerned.)
Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information.
Set out clear procedures for responding to requests for information and correspondence with the Office of the Information Commissioner (contained within the legal rudiments checklist). It also will ensure that any subject access requests are dealt with strictly in accordance with legal requirements, including adherence to time limits for responding to such requests. In this regard the Church aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of the request accompanied by payment of any required fee unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.
In addition, the Church will ensure that:

There is someone with specific responsibility for Data Protection. For individual Churches this is the Legal Officer or the DSA if held from above.
Everyone managing and handling personal information understands that they are responsible for following good data protection practice.
Everyone managing and handling personal information is appropriately trained to do so. Everyone managing and handling personal information is appropriately supervised.
Anybody wanting to make enquiries about handling personal information knows what to do.
Queries about handling personal information are promptly and courteously dealt with.
Methods of handling personal information are clearly described.
A regular review and audit is made of the way personal information is held, managed and used.
Methods of handling personal information are regularly assessed and evaluated.
A breach of the rules and procedures identified in this policy by a member of staff may lead to disciplinary action being taken.
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998, and is subject to regular review at appropriate intervals (in any event at not less than 3-year intervals).

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© 2008 Church of Scientology Religious Education College Inc. (a non-profit association incorporated in South Australia). All Rights Reserved. Grateful acknowledgement is made to L. Ron Hubbard Library for permission to reproduce a selection from the copyrighted works of L. Ron Hubbard. L. RON HUBBARD, SCIENTOLOGY, DIANETICS and SAINT HILL are trademarks and service marks owned by Religious Technology Center and are used with its permission. Services relating to Scientology religious philosophy are delivered throughout the world exclusively by licensees of the Church of Scientology International with the permission of Religious Technology Center, holder of the SCIENTOLOGY and DIANETICS trademarks.