International Ministries
Privacy Policy
Word of Life International Ministries (WOLIM)
| Version | 1.0 |
| Effective date | 1 September 2026 |
| Next scheduled review | 1 September 2027 |
| Approved by | The Board of Trustees, on the recommendation of the Data Protection Officer |
| Published at | wolim.org/privacy |
1. Our promise to you
Word of Life International Ministries (“WOLIM”, “the Ministry”, “we”, “us”) is a church. People trust us with things they would not tell anyone else — a prayer request, a decision to follow Christ, a child’s name and allergies, a family address. That trust is a spiritual matter before it is a legal one, and we treat it that way.
This Policy explains, in plain language, what personal information we collect, why we collect it, who sees it, how long we keep it, and the rights you have over it. It applies wherever we collect information about you: on our websites, in our mobile applications, on our premises, on our forms and envelopes, in our livestreams, and at every WOLIM branch.
We handle personal information in line with the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe (the “Act”), the Cyber and Data Protection (Licensing of Data Controllers and Appointment of Data Protection Officers) Regulations, 2024 (Statutory Instrument 155 of 2024), and section 57 of the Constitution of Zimbabwe, which guarantees every person the right to privacy. Where a WOLIM branch operates outside Zimbabwe, we also comply with the data protection law of that country, and where that local law gives you stronger protection than this Policy, the local law applies.
2. Who is responsible for your information
WOLIM is the data controller of the personal information described in this Policy. That means we decide why and how your information is used, and we are accountable for it.
| Data controller | Word of Life International Ministries |
| Registered address | 4 Connaught Avenue, Newlands, Harare, Zimbabwe |
| Data Protection Officer (DPO) | dpo@wolim.org |
| Privacy enquiries and requests | privacy@wolim.org |
| Partnership enquiries | partner@wolim.org |
| Supervisory authority | Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ), designated as the Data Protection Authority under section 5 of the Act |
We have appointed a Data Protection Officer, whose appointment is notified to the Data Protection Authority in writing as required by section 20(5) of the Act and by Statutory Instrument 155 of 2024, and we have applied for a data protection licence as a data controller. Our DPO is responsible for ensuring that the Ministry complies with the Act, for handling the requests you make under this Policy, and for working with the Authority.
Each WOLIM branch outside Zimbabwe processes personal information under this Policy and under the direction of the Ministry, and where local law requires a locally established representative or information officer, one is appointed.
3. What this Policy covers
This Policy covers personal information collected through:
- the WOLIM website at wolim.org and any other website we operate;
- the Wolim Connect mobile application and our online services;
- our church buildings, offices and events, including CCTV, photography, video recording and live streaming;
- our Partnership Forms and Partnership Envelopes;
- our first-time visitor (“yellow”) brochure;
- our Commitment Cards for those who make a decision to follow Christ;
- Children’s Church and youth ministry registration and check-in;
- membership, small group, volunteer, event and departmental records;
- correspondence with us by letter, telephone, SMS, WhatsApp, email or social media.
4. What we mean by “personal information” and “sensitive data”
The Act defines personal information broadly. It includes your name, address and telephone number; your age, sex, marital or family status; identifying numbers; information about your health, finances, education or employment; and opinions expressed about you.
The Act treats certain categories as sensitive data, including information revealing religious beliefs or affiliations, racial or ethnic origin, political opinions, philosophical beliefs, sex life, health information, genetic information, criminal, educational, financial or employment history, and gender, age, marital or family status.
Because we are a church, much of what we hold about you is sensitive data by definition: the fact that you attend WOLIM, that you have made a commitment to Christ, that you partner with us financially, or that you have asked us to pray about a matter of health or family. We treat all of it as sensitive, and we protect it accordingly.
5. The information we collect
5.1 Information you give us
| What we collect | Where it comes from |
|---|---|
| Title, first names, surname, date of birth, wedding anniversary | Partnership Form, membership and event registration |
| Postal or street address, city, country | Partnership Form and Envelope, Commitment Card, visitor brochure |
| Telephone or WhatsApp number, email address | All of our forms, the app and the website |
| Home branch or assembly | Partnership Form and Envelope, membership records |
| Monthly contribution amount, giving history, receipt records | Partnership Form and Envelope, giving platforms and bank records |
| Prayer requests | Partnership Form and Envelope, prayer cards, the app, phone and email |
| Your decision to follow Christ, your baptism, and follow-up notes | Commitment Card and pastoral follow-up |
| The fact that you visited us for the first time, and how you heard about us | First-time visitor (yellow) brochure |
| Child’s full name, date of birth or age group, class or group, allergies, medical or dietary notes, and the names and contact details of the parents or guardians authorised to collect the child | Children’s Church registration and check-in |
| Volunteer and departmental information, including your service area, availability and any screening or reference checks required for work with children | Volunteer forms and interviews |
5.2 Information we collect automatically or by observation
| What we collect | How |
|---|---|
| Images and audio of you and, where consent is given, of your children | Photography, video recording and live streaming of services and events |
| CCTV images | Cameras at entrances, exits, car parks, corridors and cash-handling areas |
| Device and usage information — IP address, device type, operating system, app version, pages viewed, approximate location derived from IP, crash reports | Our website and the Wolim Connect app |
| Cookies and similar technologies | Our website (see section 12) |
5.3 Information from other people
Occasionally we receive information about you from someone else — for example, when a family member submits a prayer request on your behalf, when a member refers a friend for a pastoral visit, or when a branch passes on your details because you have relocated. Where the Act requires it, we will tell you that we hold your information, why, and what your rights are, as set out in section 16 of the Act.
6. Why we use your information, and our lawful basis
Under the Act we may only process your information where it is necessary, fair and lawful, and for a specified, explicit and legitimate purpose. The table below sets out what we do and why we are allowed to do it.
| What we do | Why | Our lawful basis under the Act |
|---|---|---|
| Keep a register of partners, members and regular attendees | To pastor and care for our people, and to run the Ministry | Your consent (s.10(1) and s.11(1)); and s.11(5)(c), which permits a non-profit organisation with a religious purpose to process sensitive data about its members and about people in regular contact with it in connection with those purposes |
| Receipt, record and account for your contributions and offerings | To keep accurate financial records and satisfy audit, tax and charity-law requirements | Compliance with a legal obligation (s.10(3)(b)) |
| Contact you about services, events, ministry news and invitations | To invite you and keep you informed | Your consent (s.10(1)); you may withdraw it at any time, free of charge |
| Follow up with you after a first visit or a commitment to Christ, by phone or a home visit | To welcome you, answer your questions and help you grow in your faith | Your written consent (s.11(1)) |
| Pray over the requests you send us | To fulfil the pastoral purpose you gave the information for | Your consent (s.11(1) and, where the request concerns health, s.12(1)) |
| Run Children’s Church safely — registration, check-in, allergy and collection records | To keep your child safe and release them only to an authorised adult | The consent of the parent or guardian as a competent person (s.10(1)), and the protection of the child’s vital interests (s.10(3)(c)) |
| Photograph, record and live stream our services | To make the ministry available to those who cannot attend, and to keep a record of the life of the church | Your consent, given by entering an area we have signposted as filmed, and separately in writing for children (s.10(1) and s.10(2)); and our legitimate interests as a Ministry (s.10(3)(e)) |
| Operate CCTV | To protect the safety of people on our premises and to prevent and investigate crime | Protecting vital interests (s.10(3)(c)) and our legitimate interests in safety and security (s.10(3)(e)) |
| Run our website and mobile app, keep them secure and fix faults | To provide the service you asked for and keep it working | Our legitimate interests (s.10(3)(e)) |
| Respond to a legal obligation, a court order or a lawful request from an authority | Because we must | Compliance with a legal obligation (s.10(3)(b)); evidence in proving an offence (s.10(3)(a)) |
We do not use your information for any purpose that is incompatible with the purpose for which you gave it to us. We do not sell your personal information, and we do not rent, trade or share it with third parties for their own marketing.
7. Automated decisions and profiling
We do not make decisions about you by automated means alone that produce legal effects or that significantly affect you. You have the right under section 25 of the Act not to be subject to such a decision.
8. Children’s information
We take particular care with children, whom the Act defines as anyone under the age of eighteen.
- We collect a child’s information from a parent or legal guardian, or with their authority.
- Under section 26 of the Act, a child’s rights under the Act are exercised by the child’s parent or legal guardian, and a parent or guardian may ask us at any time to show, correct or delete what we hold about their child.
- We collect only what we need to keep the child safe and to run the class: name, age or date of birth, group, allergies or medical and dietary notes, and the adults authorised to collect them.
- We do not photograph, film or live stream children in Children’s Church, and we do not include identifiable images of children in our streams, social media or publications, unless a parent or guardian has given separate written consent for that specific use. A parent or guardian may withdraw that consent at any time.
- Children’s registration and check-in records are kept for as long as the child participates in the ministry and for twelve months afterwards, and are then securely destroyed, except where a safeguarding or incident record must be kept for longer.
- The Wolim Connect app and our online services are not directed at children under thirteen, and we do not knowingly collect their information online without parental consent.
9. Photography, video recording and live streaming
Our services are photographed, video recorded and live streamed. We put up clear signs at every entrance to the areas where this happens, so that you know before you enter.
How you can attend without being filmed. We want everyone to be able to worship freely, including those who cannot or would rather not appear on camera. At every branch:
- there is a designated camera-free seating area, clearly marked, which our camera operators are instructed never to frame or capture;
- a “Please Do Not Film Me” identifiable tag — a lanyard, badge, wristband, sticker or whatever identifier your branch uses — is available free of charge from the welcome desk or from any usher, and our media team is trained to keep anyone wearing one out of shot;
- our camera operators are briefed before every service on where the camera-free area is and on the identifier in use that day;
- you may ask any usher to seat you away from a camera position at any time, without giving a reason.
Removal from a recording. If you appear in a photograph, a recording or an archived stream and you would rather not, write to privacy@wolim.org with enough detail for us to find it (the date, the service and roughly where in the recording you appear). We will remove or blur the material we control, and where a recording sits on a third-party platform such as YouTube or Facebook we will remove or replace it there. Where a recording is a continuous live broadcast that has already gone out, we cannot recall the broadcast itself, but we will edit or take down the archived copy.
Live streaming is public. Once a service is streamed, it can be seen anywhere in the world, and viewers may be in countries whose data protection laws differ from Zimbabwe’s. Please bear this in mind before coming forward at the front of the auditorium, giving a testimony, or bringing a child to the platform.
Filming by members of the congregation. Please respect one another. Do not photograph or film other people, and never children who are not your own, without their agreement. Recording or distributing images of another person without consent may be a criminal offence under the Criminal Law (Codification and Reform) Act as amended by the Act.
10. CCTV
We operate CCTV at our premises for the safety of people and property and for the prevention and detection of crime. Signs are displayed at the entrances to the areas covered.
- CCTV images are held for 30 days and then automatically overwritten, unless an image is needed for an ongoing investigation, an insurance claim or legal proceedings, in which case it is preserved separately for as long as necessary.
- Access to CCTV is restricted to the small number of authorised staff who need it, and every viewing is logged.
- We do not use CCTV to monitor the work of staff or volunteers, and we do not place cameras in toilets, changing areas, nursing rooms or prayer rooms.
- CCTV images are released outside the Ministry only to the police or another authority acting under lawful powers, or where a court orders it.
- You may ask for a copy of CCTV images of yourself under section 14(b) of the Act. Where other people appear in the same footage we will obscure them before releasing it.
11. Prayer requests and pastoral confidence
A prayer request is often the most sensitive thing a person shares with us. We handle it as follows:
- prayer requests are seen only by the pastoral and prayer team members who need to see them in order to pray and to respond;
- they are not read aloud, published, posted or shared outside the Ministry without your specific agreement;
- written prayer requests on forms and envelopes are held securely and destroyed twelve months after they are received;
- where a request reveals information about your health, we treat it as health data under section 12 of the Act and rely on the written consent you gave when you submitted it.
Please do not write anything on a form that you would not wish anyone else in the prayer team to read. If a matter is very private, ask to speak to a pastor directly.
12. Our website and mobile app
Cookies. Our website uses cookies that are strictly necessary for it to work, and — only where you agree — cookies that help us understand which pages people find useful. You can accept or reject non-essential cookies when you first visit, change your mind at any time, and block or delete cookies in your browser settings.
Analytics. Where you consent, we use analytics to count visits and see which content is helpful. Analytics data is kept for 14 months.
The Wolim Connect app. The app may ask your permission to use your device’s location so that it can show you the nearest branch. Location is used on your device to find that branch and is not stored by us as a record of your movements. You can refuse this permission and still use the app, and you can withdraw it at any time in your device settings.
Links to other sites. Our website, app and social media pages link to services we do not control, such as YouTube, Facebook and payment providers. This Policy does not cover them; please read their own privacy notices.
13. Who we share your information with
We share personal information only where it is necessary, and only with:
| Recipient | Why |
|---|---|
| WOLIM branches, departments and ministry teams | So that the branch or team caring for you has what it needs |
| Service providers acting as our data processors — website and app hosting, email and SMS providers, bulk messaging services, cloud storage, church management software, IT support | To run the systems the Ministry depends on |
| Banks, mobile money operators and payment processors | To receive and receipt your contributions |
| Our auditors, accountants, insurers and legal advisers | To meet our accounting, audit and legal obligations |
| The police, a court, a regulator or another authority | Where the law requires it, or to protect someone’s life or safety |
Every data processor we use is engaged under a written contract that requires it to act only on our instructions and to maintain appropriate security measures, as sections 17, 18(4) and 18(5) of the Act require. Our processors may not use your information for their own purposes.
14. Sending information outside Zimbabwe
WOLIM has branches in several countries, and some of the services we use — cloud storage, email, video platforms — store information on servers outside Zimbabwe. Section 28 of the Act allows us to transfer personal information out of Zimbabwe only where the recipient ensures an adequate level of protection, and only so that we can carry out the work of the Ministry.
Before we transfer information abroad we consider the nature of the information, the purpose and duration of the processing, who the recipient is, the data protection law in force where they are, and the security measures they apply. Where a country does not assure an adequate level of protection, we transfer information only in one of the situations section 29 of the Act allows — most often because you have unambiguously consented to the transfer, or because the transfer is necessary to perform a contract with you or to protect your vital interests.
If you live outside Zimbabwe and give your details to a WOLIM branch, please note that they may be transferred to our head office in Harare for the purposes described in this Policy.
15. How long we keep your information
We keep personal information only for as long as we need it for the purpose we collected it, and no longer. Our standard periods are:
| Information | How long we keep it |
|---|---|
| Partnership and giving records, receipts, and the accounting records attached to them | 6 years after your final contribution, as financial, tax and audit rules require |
| Partnership Forms and Envelopes where consent has been declined | Destroyed as soon as the contribution has been receipted and accounted for |
| Membership and pastoral records for active members | For as long as you are a member, and 2 years afterwards |
| First-time visitor (yellow) brochure details | 24 months from your last contact with us, or sooner if you ask |
| Commitment Cards and follow-up notes | 24 months, after which they are either transferred to your membership record with your agreement, or securely destroyed |
| Prayer requests | 12 months from receipt |
| Children’s Church registration and check-in records | For as long as the child attends, plus 12 months |
| Safeguarding and incident records concerning a child | As long as the law and our safeguarding duties require, which may be many years |
| CCTV footage | 30 days, unless preserved for an investigation, claim or legal proceedings |
| Photographs, video and archived streams of services | Retained as a record of the life of the church, subject to your right to ask for removal (see section 9) |
| Website analytics | 14 months |
| Email and messaging subscriber lists | Until you unsubscribe or withdraw consent |
| Employment and volunteer records | As required by employment law in the country concerned |
When a retention period ends, paper records are shredded and electronic records are deleted or irreversibly anonymised.
16. Keeping your information safe
Section 18 of the Act requires us to take appropriate technical and organisational measures to protect your information. Ours include:
- locked cabinets and restricted-access rooms for paper forms, envelopes and cards, and sealed collection points for offerings;
- access to electronic records limited to the people whose role requires it, with individual accounts, strong passwords and two-factor authentication where available;
- encryption of information in transit, and of devices and backups where practicable;
- written confidentiality undertakings from staff, ministry leaders, volunteers and processors, and training for everyone who handles personal information;
- regular backups, tested restoration, and a written incident response procedure.
If something goes wrong. If a security breach affects your information, we will notify the Data Protection Authority within 24 hours of becoming aware of it, as section 19 of the Act and Statutory Instrument 155 of 2024 require. Where the breach is likely to put your rights at high risk, we will tell you within 72 hours what happened, what information was involved, what we are doing about it and what you can do to protect yourself, and we will complete our investigation and report to the Authority within the period the Regulations allow.
17. Your rights
Section 14 of the Act gives you the following rights, and we will honour them free of charge.
| Your right | What it means |
|---|---|
| To be informed | To know what we do with your information — which is what this Policy is for |
| To access | To ask for a copy of the personal information we hold about you |
| To object | To object to all or part of our processing of your information, including a complete and free right to object to direct marketing |
| To correction | To have false or misleading information about you corrected, without delay |
| To deletion | To have false or misleading information about you deleted |
| To withdraw consent | Where we rely on your consent, to withdraw it at any time, without giving a reason and free of charge (sections 11(2) and 12(2)) |
| Not to be subject to automated decisions | Not to have a decision that significantly affects you made by automated processing alone (section 25) |
| Representation | If you are a child, your parent or guardian may exercise these rights for you (section 26); if you are unable to exercise them yourself, a parent, guardian or person appointed by a court may act for you (section 27) |
How to exercise a right. Write to privacy@wolim.org, or to the Data Protection Officer at 4 Connaught Avenue, Newlands, Harare, Zimbabwe. Tell us who you are, what you want and, where it helps, which branch or which service you are asking about. We may ask you to confirm your identity so that we do not disclose your information to someone else. We will respond within 30 days. If a request is unusually complex we will tell you within that period and explain how much longer we need.
Withdrawing consent does not undo what was lawful before you withdrew it, and it does not affect records we are obliged to keep — for example the accounting record of a contribution you have already made.
18. Complaints
If you are unhappy with how we have handled your information, please tell our Data Protection Officer first at dpo@wolim.org. We would rather hear it from you and put it right.
You also have the right to complain directly to the Data Protection Authority:
Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ) 1110 Performance Close, Mount Pleasant Business Park, Harare (P.O. Box MP843, Mount Pleasant, Harare) Telephone +263 242 333032 | Toll-free 0800 4303 the.regulator@potraz.gov.zw | www.potraz.gov.zw
Under section 34 of the Act, a person aggrieved by a decision of the Authority may appeal to the Administrative Court. If you are outside Zimbabwe, you may instead complain to the data protection authority of the country where your branch is located.
19. Changes to this Policy
We review this Policy at least once a year and whenever the law or our practices change. The version number and effective date at the top of this Policy tell you which version you are reading. Where a change materially affects how we use your information, we will say so on our website and, where we rely on your consent, ask for it again.
20. How to contact us
Word of Life International Ministries 4 Connaught Avenue, Newlands, Harare, Zimbabwe Data Protection Officer: dpo@wolim.org Privacy requests: privacy@wolim.org Partnership: partner@wolim.org wolim.org/privacy
This Policy is issued under the authority of the Board of Trustees of Word of Life International Ministries and is binding on every branch, department, employee, minister and volunteer of the Ministry.