📄 DATA PROTECTION POLICY

Our Lady Queen of Africa Catholic Church (OLAQA)
Version 1.0 | July 2025

Table of Contents

  1. Introduction
  2. Purpose of the Policy
  3. Scope
  4. Legal and Ethical Framework
  5. Definitions
  6. Types of Data Collected
  7. Lawful Basis for Data Collection
  8. Principles of Data Protection
  9. Rights of Data Subjects
  10. Data Access and Sharing
  11. Data Retention and Disposal
  12. Security Measures
  13. Role of the Data Protection Officer (DPO)
  14. Data Breach Protocol
  15. Consent and Communication
  16. Children's Data
  17. Confidentiality and Clerical Ethics
  18. Use of Technology
  19. Training and Awareness
  20. Complaints and Redress Mechanisms
  21. Review and Amendments
  22. Appendices

Introduction

Our Lady Queen of Africa Catholic Church (OLAQA), based in Oshuiman, Ghana, is committed to protecting the personal data of its members, clergy, staff, and volunteers in compliance with both civil and ecclesiastical laws. This policy outlines our approach to data collection, storage, processing, and sharing in a way that respects privacy and the dignity of the human person, in accordance with the teachings of the Catholic Church.

Purpose of the Policy

The purpose of this policy is to:

Scope

This policy applies to:

Legal and Ethical Framework

This policy aligns with:

Definitions

Types of Data Collected

We collect the following categories:

Lawful Basis for Data Collection

We collect data based on:

Principles of Data Protection

All data must be:

  1. Processed lawfully and fairly
  2. Collected for explicit purposes
  3. Adequate, relevant, and limited
  4. Accurate and up-to-date
  5. Stored only as long as necessary
  6. Handled securely and confidentially

Rights of Data Subjects

All individuals have the right to:

Data Access and Sharing

Data Retention and Disposal

Security Measures

We enforce:

Role of the Data Protection Officer (DPO)

The appointed DPO is responsible for:

Data Breach Protocol

In the event of a breach:

Children's Data

Confidentiality and Clerical Ethics

1. Staff & Volunteer Duties

All personnel accessing personal data (secretaries, youth leaders, finance officers, etc.) must sign a Confidentiality Agreement and may only access data required for their roles.

2. Pastoral Counseling

Information shared in spiritual or personal counseling must be kept private and stored securely. Notes must be encrypted or physically locked.

3. Use of Examples in Preaching or Bulletins

No personal stories or examples may be shared in sermons, publications, or testimonies without written permission or proper anonymization.

4. Secure Storage and Limited Access

All sensitive data must be encrypted or stored in locked cabinets. Only authorized individuals may access such data.

5. After Leaving Office

Former staff and clergy are still bound by confidentiality. They must return or delete any personal data they held during their service.

Use of Technology

The Church utilizes secure digital platforms for collecting, storing, and managing member data. These platforms operate under written agreements as third-party data processors and are selected based on their compliance with applicable data protection laws and international standards.

All data stored or transmitted through these platforms is:

The Church does not disclose the specific service providers publicly to maintain security integrity, but ensures that all processors adhere to relevant provisions of the Ghana Data Protection Act (Act 843) and, where applicable, the General Data Protection Regulation (GDPR).

Training and Awareness

Complaints and Redress Mechanisms

Complaints may be lodged to the:

Steps:

  1. Submit written complaint
  2. Investigation within 14 days
  3. Feedback and resolution

Review and Amendments

Appendices

Data Processing Agreement (DPA)

This agreement is made between:
Our Lady Queen of Africa Catholic Church ("Data Controller")
and ("Data Processor")

1. PURPOSE: The Processor shall handle personal data solely for the purpose of .

2. DATA HANDLED: [Specify types – e.g., names, contact details, images]

3. SECURITY: The Processor shall implement appropriate security measures.

4. CONFIDENTIALITY: All data is confidential and may not be shared.

5. DATA BREACH: The Processor shall notify the Controller within 24 hours of any suspected breach.

6. TERMINATION: Upon end of service, all data must be deleted or returned securely.

Signed:
Data Controller (OLAQA): Date:
Data Processor: Date:

Data Breach Incident Report

Date of Incident:
Time of Discovery:
Reported by:
Contact Info:

DESCRIPTION OF INCIDENT
- What happened?

- What data was affected?

- Number of individuals affected:

IMMEDIATE ACTIONS TAKEN

Reported to the Parish DPO: ☐ Yes ☐ No
Reported to the Data Protection Commission: ☐ Yes ☐ No

Date of report to Commission (if applicable):

Name of Investigator:
Signature: Date:

Staff & Volunteer Confidentiality Agreement

I, , acknowledge that in my role as a staff member or volunteer with Our Lady Queen of Africa Catholic Church, I may have access to personal and sensitive data.

I agree that:

  • I will not disclose or share any personal data unless authorized.
  • I will access only the data necessary for my duties.
  • I will follow the parish's data protection policy.
  • I will report any data breaches immediately.

This agreement remains valid even after my role ends.

Name:
Role:
Signature:
Date: