Q: What information should my ministry include in its online privacy policy? 

A: Your ministry’s online privacy policy should identify the type of information your ministry collects, how that information is collected and why, the security measures you use to protect that information, and your policy on “cookies.”

Keep the following in mind when working with a local attorney to draft an online privacy policy for your ministry:

1. If your ministry collects identifying information or financial information, it is especially important to indicate this in your privacy policy. Make sure you tell visitors if you store information gathered in other ways, such as on a paper form.
2. Tell users why your ministry collects specific information. Often, this statement may be as simple as “to further the purpose of the ministry by connecting the user with other members.”
3. If your website uses “cookies,” be sure to include what the cookies do and tell visitors that they can change their web browser settings to decline cookies.
4. If your ministry’s website includes links to other websites, make it clear that your ministry’s privacy policy does not apply to these sites.
5. If your ministry is involved in any “e-commerce” activities such as selling materials or transferring funds out of a person’s bank account electronically, your privacy policy should include the security measures taken to protect a user’s financial information.

Several states have laws that require privacy policies be included on a website. Be sure your policy follows all laws that apply to your situation. The National Conference of State Legislatures provides a helpful resource on state laws related to Internet privacy that can help you determine the laws that apply in your state.

If all or part of your ministry’s website is directed to children under 13, the Child Online Privacy Protection Act (COPPA) likely applies. COPPA requires website owners to obtain parental consent before collecting information about children under 13, and include special provisions to the website’s privacy policy.

Additional Resources

• Your Online Privacy Policy - Sample Wording
• Does Your Website Need a Privacy Policy? 

*Important information: Brotherhood Mutual is pleased to provide Legal Assist as a complimentary resource. The services we offer through Legal Assist are intended to provide general legal information to our current and prospective policyholders.

The information we provide is intended to be helpful, but it does not constitute legal advice and is not a substitute for the advice from a licensed attorney in your area. Accordingly, no attorney/client relationship is created through this process, and no legal advice will be provided. We strongly encourage you to regularly consult with a local attorney as part of your risk management program.