Your membership database holds some of the most sensitive information people will ever trust you with. This policy ensures every person on your team handles that data with the care, access controls, and legal compliance it demands.
**[CHURCH_NAME]** **Effective Date:** [EFFECTIVE_DATE] **Policy Owner:** [POLICY_OWNER] **Information Officer (POPIA):** [INFORMATION_OFFICER] **Review Date:** [REVIEW_DATE] ---
This policy governs how [CHURCH_NAME] collects, stores, accesses, shares, and removes the personal information of its members. It supports our obligations under the Protection of Personal Information Act 4 of 2013 (POPIA) and reflects our commitment to treating every person's information with care and respect. Membership data belongs to the person who gave it. We hold it in trust. ---
### 2.1 Standard Membership Information When a person registers as a member or regular attendee of [CHURCH_NAME], we may collect: 1. Full legal name 2. Date of birth 3. Gender 4. Marital status 5. Home address 6. Email address 7. Mobile phone number 8. Spouse's name and contact details (if applicable) 9. Children's names and dates of birth (with parental consent) 10. Membership date and status ### 2.2 Ministry Participation Data - Small group / life group membership - Volunteer team participation and roles - Ministry training records - Event attendance history ### 2.3 Financial Data - Giving history and donation amounts - Bank details (only where set up for recurring giving, stored securely in the financial system) - Section 18A tax certificate records ### 2.4 Pastoral Data - Prayer requests (noted with explicit consent) - Pastoral care interactions (recorded in pastoral notes, not membership system) - Baptism records, membership commitment records - Counselling referral history (anonymised where possible) ### 2.5 What We Do Not Collect Without Explicit Consent The following special categories are only collected when specifically necessary and with explicit opt-in consent: - Medical or health information - Criminal record information - Detailed family circumstances (bereavement, separation, addiction histories) ---
Data is collected through the following authorised methods: 1. **Membership forms** — physical or digital 2. **Event registration forms** — for specific events or programmes 3. **Giving platform** — [GIVING_PLATFORM] collects financial data directly 4. **Church management system** — [CHURCH_MANAGEMENT_SYSTEM] is our primary membership database 5. **Verbal or pastoral intake** — staff may capture information shared verbally with consent All data collection forms must include a brief privacy notice informing the person of how their data will be used and their rights under POPIA. ---
**System:** [CHURCH_MANAGEMENT_SYSTEM] ### 4.1 Security - The CMS is protected by secure login credentials - All admin accounts require strong passwords and two-factor authentication - Access permissions are role-based and set to minimum necessary access - The CMS provider is contractually bound to protect data in line with POPIA-equivalent standards - Regular security updates are maintained ### 4.2 Data Accuracy - [CHURCH_NAME] aims to maintain accurate records. Members are encouraged to notify [POLICY_OWNER] of any changes to their information. - Data is reviewed for accuracy at least annually as part of the membership audit process. ---
### 5.1 Access Levels | Role | Access Level | |------|-------------| | Senior Pastor | Full read access; no bulk export without approval | | Administrative Staff ([ADMIN_STAFF_ROLES]) | Full access within assigned areas | | Ministry Team Leaders | Access to their own team's data only | | Small Group Leaders | Access to their group members' basic contact info only | | Volunteers | No direct database access; data shared on need-to-know basis | | Contractors (e.g. accountants) | Limited access under data processing agreement | ### 5.2 Access Reviews Access permissions will be reviewed: - At least annually during the system access audit - Immediately when a staff member or volunteer changes role or leaves ### 5.3 Prohibited Access No person may access membership data: - For personal use unrelated to their ministry role - To compile lists for personal commercial purposes - To provide to external organisations without authorisation ---
### 6.1 Internal Sharing Ministry leaders may share member contact information within the church for legitimate ministry purposes, subject to: 1. The information is shared only with those who need it 2. It is not used for purposes beyond the stated ministry purpose 3. It is not stored unnecessarily on personal devices Example: A small group leader may receive a member's mobile number to coordinate group activities, but should not retain it after the person leaves the group. ### 6.2 External Sharing Membership data will not be shared outside [CHURCH_NAME] except: 1. With the member's explicit consent (e.g., connecting them with a referral counsellor) 2. To comply with a legal obligation or SAPS request 3. With approved service providers under POPIA-compliant data processing agreements (e.g., the church management system vendor, giving platform) **Membership lists must never be sold, rented, or traded under any circumstances.** ---
All members have the following rights under POPIA: ### 7.1 Right to Access You may request a copy of the personal information [CHURCH_NAME] holds about you. Submit your request to [INFORMATION_OFFICER] at [INFORMATION_OFFICER_EMAIL]. We will respond within 30 days. ### 7.2 Right to Correction You may request that inaccurate or outdated information be corrected. Submit the correction to [POLICY_OWNER] with the updated information. ### 7.3 Right to Object You may object to the processing of your personal information. Note that some processing (e.g., retention of donation records for tax purposes) is required by law and cannot be stopped on request. ### 7.4 Right to Deletion You may request that your personal information be deleted from our records. We will: 1. Confirm what data we hold 2. Delete data that is not subject to legal retention requirements 3. Inform you of any data we are legally required to retain (e.g., financial records) 4. Confirm deletion within [DELETION_CONFIRMATION_DAYS] days ---
1. Submit a written request to [INFORMATION_OFFICER_EMAIL] with subject line: "Data Deletion Request — [Your Name]" 2. We will acknowledge receipt within [ACKNOWLEDGEMENT_DAYS] business days 3. We will process the request within 30 days (POPIA standard) 4. We will provide written confirmation that deletion has been completed (noting any retained records and the reason) ---
In the event of a data breach involving membership data: 1. Immediately notify [INFORMATION_OFFICER] 2. The breach will be assessed for severity and scope within 24 hours 3. The Information Regulator will be notified if required by POPIA 4. Affected members will be notified as soon as reasonably possible 5. A breach record will be created and corrective actions documented Suspected breaches must be reported to [INFORMATION_OFFICER_EMAIL] without delay. ---
| Data Type | Retention Period | |-----------|------------------| | Active membership records | Duration of membership | | Lapsed member records | [LAPSED_RETENTION_YEARS] years after last contact | | Donation/financial records | 7 years (SARS requirement) | | Section 18A certificates | 7 years | | Event registration records | 2 years | | Children's ministry records | Until child turns 21, then deleted | ---
For questions about your data or this policy, contact: [INFORMATION_OFFICER] at [INFORMATION_OFFICER_EMAIL] For complaints about how your data has been handled, you may also contact the Information Regulator of South Africa: www.inforegulator.org.za --- *[CHURCH_NAME] — Membership Data Handling Policy — Effective [EFFECTIVE_DATE]*