1. ABOUT GOSPEL LIGHT CHRISTIAN CHURCH'S DATA PROTECTION POLICY
1.1 We at Gospel Light Christian Church take our responsibilities under Singapore’s Personal Data Protection Act 2012, any regulations enacted thereunder, and any guidelines that may be issued from time to time by the Personal Data Protection Commission (collectively, the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
1.2 This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
2. INTRODUCTION TO THE PDPA
2.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and audio/video recordings.
2.2 As is true of most internet services, we use cookies and other internet technologies to gather non-personal information automatically and store in log files. This information includes Internet Protocol (IP) addresses, browser type and language, internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. This information is used to understand and analyse trends, administer the site, and to enhance user experience.
2.3 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
3. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
3.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
(a) the provision of pastoral and shepherding care;
(b) teaching and training;
(c) connecting you to a community or care group;
(d) organising events to support your Christian journey;
(e) informing you of any church-wide events, programmes and training;
(f) maintaining the membership register of constitutional members of Gospel Light, members of community or care groups and regular worshippers or congregants;
(g) communicating any administrative information with you, including changes in our policies, terms and conditions;
(h) complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to the Ministry of Defence, Ministry of Education, Immigration and Checkpoints Authority and Ministry of Health). For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction;
(i) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your relationship with us or for your benefit, or to improve any of our services for your benefit;
(j) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(k) responding to complaints, queries and/or requests;
(l) publicity and promotion purposes such as bulletins, newsletter, brochures, flyers, posters, banners, calendar, electronic publications, website and social media platforms;
(m) any other purposes which we notify you of at the time of obtaining your consent (collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
3.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above- 3 stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
4. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
4.1 We respect the confidentiality of the personal data you have provided to us.
4.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
4.3 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data in accordance with this Data Protection Policy.
5. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
5.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
5.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
5.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
5.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of 4 protection that is at least comparable to the protection under the PDPA. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
5.5 The sections of this Data Protection Policy that refer to websites apply only to Gospel Light’s website. Our website may contain links to other website not maintained by Gospel Light. Such third party websites are subject to their own data protection and privacy practices and you are encouraged to examine the privacy policies of those websites.
6. COMPLAINT PROCESS, RIGHT TO WITHDRAW CONSENT, REQUEST ACCESS TO AND CORRECTION OF PERSONAL DATA
6.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance by contacting the Data Protection Officer at the following address:-
6.2 You have a right to withhold provision of any of your personal data, withdraw consent, request access to, and make correction of personal data that Gospel Light holds about you, in accordance with applicable laws. All requests for withdrawal of consent, access to, or correcting of personal data held by Gospel Light shall be made by contacting the Data Protecting Officer as outlined at paragraph 6.1 above. In some cases, withdrawal of consent may mean that Gospel Light may not be able to fulfill our services to you.
7. UPDATES ON DATA PROTECTION POLICY
7.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
7.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at gospellight.sg
7.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
i. Children are a gift to the Church from a loving God (Psalm 127:3). But child abuse or neglect can and does happen within the Christian community, even within the premises of the Gospel Light Christian Church (thereafter referred to as “Gospel Light” or “the church”)
serves to provide a safe environment for the physical and emotional well-being of all children participating in church activities. The church exists to protect the reputation of the gospel of Jesus Christ by maintaining the highest ethical standards such that volunteers and staff always live and serve above reproach.
ii. Future revisions to this policy may be made with the authorization of the church leadership.
iii. This Child Protection Policy shall be available in the church office to all visitors, volunteers, members, and staff of the
Policy Statement
i. Gospel Light takes all indicators and reports of child abuse or neglect The church is aware that children who are ill-treated in one way are significantly vulnerable to maltreatment in other forms. As such, this Child Protection Policy helps to direct the church in taking extra steps to protect the child from known risks, and be extra attentive to and supportive of the child.
Scope
i. Thescopeofthis policycovers all Gospel Light endorsed activities that take place on-site at 39 Punggol Field Walk or off-site.
Definitions
i. The term “child” or “children” shall include all persons under the age of eighteen (18) years.
ii.
Abuse means
a. physical abuse, which includes conduct or behaviour that (i) causes or threatens to cause, personal injury or physical pain to an individual; (ii) coerces or attempts to coerce, an individual to engage in sexual activity; or
(iii) threatens an individual with the death or injury of the individual;
b. emotional or psychological abuse, which means conduct or behaviour by an individual towards another individual that torments, intimidates, harasses, or is offensive to the individual; or that causes or may reasonably be expected to cause mental harm to the other individual, including thoughts of suicide or inflicting self-harm;
c. conduct or behaviour in an individual that in any other way controls or dominates another individual and causes the other individual to fear for his or her safety or wellbeing; or
d. conduct of behaviour in an individual that unreasonably deprives, or threatens to unreasonably deprive, another individual of that other individual’s liberty of movement or wellbeing. (See Appendix 1 for Indicators of Abuse)
iii. Neglect, in relation to an individual, means the lack of provision to the individual of essential care (such as but not limited to food, clothing, medical aid, lodging and other necessities of life), to the extent of causing or being reasonably likely to cause personal injury or physical pain to, or injury to the mental or physical health of, the
iv. Grooming of children, is the befriending and establishing of an emotional connection with a child, and sometimes the family, to lower the child’s inhibitions with the objective of sexual abuse.
Gospel Light Christian Church has a Reporting Team, comprising of 2 volunteers and a member of the Board of Elders as follows:
Chairman: Members:
Kenii Takashima (Legal Counsel) Irene Louis (Counsellor)
Pastor Jason Lim (Board of Elder Representative)
The Reporting Team can be contacted via phone at 9117 6000 or via email at [email protected] during office hours from Monday to Friday, 8am to 5pm.
If an allegation of child abuse or neglect is brought to a member of this team, that member is responsible to convene a meeting of the Reporting Team within twenty-four
(24) hours of the report. The team will be responsible for reviewing the allegation and determining next steps.
The list of numbers and persons to contact is given in Appendix 2.
Guidelines/ Reporting of incidents
i. The abuse of children is not only a sin, but a crime (Matthew 18:6). Gospeliters should contact the Reporting Team within twenty-four (24) hours when:
a. a child discloses abuse/neglect;
b. when they witness signs of abuse/neglect (See Appendix 1).;
c. when they observe signs of abuse/neglect (See Appendix 1).
d. when they hear a first-hand witness account of abuse/neglect.
ii. Before reporting a witnessing of abuse, the child’s safety must be Once the child is protected, the abuse/neglect must be reported to the Reporting Team immediately. If the reporter believes that the child is in immediate danger, they should first contact the police to report the situation (see Direct Reporting to Authorities) and only thereafter follow up with reports to the Reporting Team as soon as possible, and no later than than twenty-four (24) hours after the incident is disclosed, witnessed, observed or heard about.
iii. Appendix 3 gives the template to be used for reporting a case of
Internal Response to an Allegation
i. When the allegation is made, the Reporting Team shall:
a. Ensure the safety of the suspected victim and if imminent threat exists, to immediately call the police to ensure the safety of the suspected victim, if this is not done by the Reporter;
b. Immediately ensure that the suspected perpetrator of the abuse/neglect has no further contact with the suspected victim and suspend the suspected perpetrator
from any child-related activities, pending an investigation, and instruct him/her to remain away from the church premises during the investigation;
c. Conduct expedient follow-up to determine whether or not the suspicions of abuse/neglect are Discussions with relevant Elders or Ministry Leaders might be required;
d. Notify the child’s parents except in those cases where it is suspected that the parents might be the perpetrators of the abuse/neglect and/or are allowing the abuse/neglect to continue;
e. Report the outcome of the investigation by the Reporting Team to the Board of Elders. In the event that the report of suspected abuse/neglect is deemed to be unfounded, the Board of Elders can provide a second opinion;
f. Liaise with the Board of Elders to care for and address the congregation where An appointed member of the Board of Elders will be the spokesperson to address the congregation as well as to provide any media response. He will seek legal input from Legal Counsel in the Reporting Team;
g. Notify the reporter of the suspected abuse of the decision to report/not report to the In the event that the suspicions are deemed to be unfounded, a reason should be given to the reporter and they should be counselled on their options to independently report their suspicions;
h. Provide contacts of external counselling services to the family of the alleged victim for purpose of care and support;
i. Inform the alleged victim’s family as well as affected members of the availability of pastoral Pastoral care meted out should function in a strictly pastoral nature without regard to the truth of any accusation or circumstances surround the incident. The primary focus is to care and support the victim and family as well as affected members;
j. The Reporting Team will document in writing all reports of suspected abuse or neglect and all steps taken by the team in response to the
Appendix 4 shows the steps to be taken by the various parties involved:
Person who discovers the abuse/neglect (Reporter)
Ministry Leader
Reporting Team
Board of Elders
Determination of Status of the Accused
Depending on the accused’s position, the following actions will be taken if the accused admits guilt, does not contest guilt, or there is a finding of guilt in a criminal court:
Accused’sPosition
Action Taken by Gospel Light
Spiritual Leadership
• Removal from ministry and laicised
• Not be permitted to preach in any capacity for Gospel
Light
Even if found not guilty, they may also be removed from the ministry and debarred from working with or having unsupervised contact with children, if the church leadershipdeems them to be a danger to children.
Staff
• Immediate termination
• Immediately prohibited from working with, or having unsupervised contact with children
• Head (HR) will include this information as part of the Staff’s personnel file and take steps to ensure that the
individual be not employed or permitted to volunteer for Gospel Liqht in any capacity
Member
• To be highlighted to BOE for removal from membership roll
• Immediately prohibited from working with or having
unsupervised contact with children
Regular worshipper/ volunteer
• Immediately prohibited from working with or having
unsupervised contact with children
Visitor
• Inform all parents so that accused will not be able to communicate or contact their children
• Inform all Children’s Ministry volunteers to be on the lookout to ensure that visitor is not permitted in any of
our children activities
• Barred from the church premises (unless under exceptional circumstances decided by the church
leadership)
i. If the accused’s position falls under multiple categories e.g. both a staff and a member of the church, the actions taken would be
ii. In cases where the accused is a Christian in a spiritual leadership position, a member of the church, a regular worshipper, volunteer or a Staff, Gospel Light will undertake to pray for, encourage and offer pastoral support to those convicted of such offences if there is credible evidence of
iii. If the accused leaves Gospel Light and attends another church, Gospel Light’s church leadership will disclose allegations or self-admission or criminal conviction of neglect or abuse to the leadership of the other church if the accused is found guilty.
Managing Safe Bahaviour
i. Gospel Light requires at least 2 unrelated adults to supervise all child For youth activities (age 12 to 18), supervision by 1 adult will be sufficient.
a. Should there be a need for one-on-one mentoring g. tuition, the adult and child should meet at a place where the supervisor or Children Ministry Leader can interrupt the time or observe from a distance. Furthermore, the meeting will take place at a public place with high visibility. (For more details, please refer to ii. Statements of Physical Boundaries under Appendix 5: Code of Conduct)
ii. Safe Toucha. Gospel Light prohibits the following:
i. Sexually or physically abusive touch;
ii. Touching a child’s thighs, stomach, bottom, or back;
iii. Massages on the shoulder, back, thighs, bottom and legs;
iv. Tickling on the back or hips;
v. Any touch that is unwanted by a child;
vi. Any touch that is done in secret;
vii. Lap sitting;
viii. Full frontal hugs;
ix. Corporal
b. Gospel Light desires to show healthy affection to its children through the following instead:
i. Displays of affection that are observable and interruptible;
ii. Kind words or praises;
iii. High fives;
iv. Handshakes;
v. Pats on the shoulder;
iii. Language and Media Contenta. Gospel Light acknowledges that sexual and violent language is a serious boundary As such, the following are prohibited:i. Sexually suggestive language, racy jokes, sexual innuendo, descriptions of sexual experiences;ii. Uploading, downloading or viewing of pornography/ gory or violent imagery;
iii. Music/ video games or movies with sexual or violent
b. Gospel Light encourages godly and positive verbal interactions including:i. Encouragement;ii. Kind words;
iii. Prayer.
In the event that the child/youth expresses discomfort with any action of a staff/volunteer, the staff/volunteer should cease from that action, even if it is listed above as a safe behaviour.
As a church, Gospel Light is committed to upholding the highest standards of integrity and ethics in all of our activities. The purpose of this Whistleblowing Policy is to provide channels through which staff, members or external parties of Gospel Light to raise concerns, in confidence, about possible violations pertaining to financial or other matters involving Staff and Board members of Gospel Light Christian Church.
(A) General Guidelines for Whistleblowing
Anyone can whistleblow at any time without fear of retaliation or
It is assumed that all whistleblowing is done in good faith based on genuine
Whistleblowing is directed at Staff or Board members of Gospel Light on matters such as (but not limited to):
Financial malpractices or impropriety such as fraud, corruption, bribery or theft;
Misappropriation of Gospel Light’s classified documents;
Harassment, abuse or misrepresentation of power and authority;
Failure to comply with laws and regulations;
Actions detrimental to health and safety or the environment;
Serious conflict of interest without disclosure;
Breach of Gospel Light’s policies or Code of Conduct; and
Concealing information about any of the above malpractice or
All complaints raised by a whistleblower will be The follow up actions by the church will take into account the sufficiency of the information provided, the severity of the allegations and the parties involved.
General complaints and grievances over service quality, ministry deficiency, operational matters, HR policy, staff development review, unhappiness over private conduct of fellow Gospeliters are not matters for whistleblowing. These concerns should be taken up with ministry leaders, pastors or department heads.
(B) Disclosures and Information
All concerns must be documented using the form given
The Whistleblower should provide specific information such as names of parties involved, places, dates, times and descriptions of alleged The ability to investigate depends on the quality and adequacy of the information provided by the Whistleblower.
The whistleblower is strongly encouraged to provide his/her name and contact number to facilitate investigations and verification.
Subject to Singapore laws and the Gospel Light’s Constitution, Gospel Light will protect the confidentiality of the Whistleblower.
(C) Whistleblowing Channels
Write to Gospel Light Christian Church’s Church Committee Chairman as well as Senior Pastor via:
Letter: Addressed to GLCC Church Committee Chairman at 39 Punggol Field Walk #05-00 Singapore 828753
Report Of Whistleblowing Case
Please indicate if you are a/an: Member of Gospel Light
Employee of Gospel Light
External party
Informant’s Name:
Informant’s Email:
Informant’s Contact Number:
* Identity of Informant will be kept strictly confidential as stated in the Policy.
Description Of Case
Describe the suspected improper activity or misconduct and how you know about it. Specify who, what, when, where and how. Provide evidence where available.
