COVID-19 PRIVACY NOTICE TO EMPLOYEES AND VISITORS REGARDING THE COLLECTION OF PERSONAL INFORMATION
Effective Date: May 20, 2021
The Rector, Church-Wardens and Vestrymen of Trinity Church, in the city of New-York, and its operating groups, subsidiaries and affiliates, (“Trinity,” “us” or “we”) is implementing health and safety measures as a result of the novel coronavirus (“COVID-19”), including (i) measuring the temperature of employees, contractors and visitors (collectively, “Individuals”), and/or (ii) asking Individuals screening questions (through an online questionnaire, or in person) regarding symptoms and potential COVID-19 exposure and contacts, in each case before they physically enter our premises and facilities (collectively, “Facilities”). We are committed to protecting the privacy and security of personal information that you provide to us in connection with these health and safety measures.
Any Individual who reports having or is observed to have any COVID-19 symptoms, or who has recently been in contact with anyone who has tested positive for COVID-19 or is symptomatic at a time when the Individual is not fully vaccinated against COVID-19, will not be allowed to enter our Facilities.
Please read this COVID-19 Privacy Notice (the “Privacy Notice”) to learn how we collect and process your personal information. You have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information. Trinity does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.
Categories of Personal Information Collected
In each case as permitted by applicable law, we collect the following categories of personal information for the purposes described below:
• Personal Identifiers, such as your name and the name(s) of your guest(s).
• Your telephone number.
• Sensory Data, such as audio and visual information. If you physically enter our Facilities, your entry and exit may be monitored by CCTV.
• Health Data, such as your body temperature, and symptoms of COVID-19, including, without limitation, fever, fatigue, shortness of breath, difficulty breathing, sinus congestion, runny nose, sore throat, muscle or body aches, loss of taste or smell, headache, loss of appetite, gastrointestinal discomfort, or persistent cough, and whether you have been told you have COVID-19 in the past 14 days or have been tested for COVID-19 in the past 10 days.
• Close Contact Information, such as information regarding whether you had close contact or high risk exposure to someone with an active or suspected case of COVID-19 while you were not fully vaccinated, in each case within fourteen (14) days prior to entering our Facilities.
• Other: Responses to screening surveys or questionnaires, test results, and any other information you provide in connection with our health and safety measures.
Sources of Personal Information
We collect personal information directly from you.
Use of Personal Information
We use the categories of personal information listed above for the following purposes:
• Health and safety purposes: We collect your personal information to maintain a safe environment for worship,
work and fellowship; help mitigate the risk of transmitting the virus and exposing Individuals to COVID-19; identify
Individuals who are displaying COVID-19 symptoms; communicate with Individuals who have tested positive for or are
suspected of having COVID-19; communicate with Individuals who have potentially been exposed to COVID-19; and help
support contact tracing efforts in connection with COVID-19. We use your body temperature for the limited purpose of
evaluating the risk your presence poses to other Individuals in the workplace as a result of COVID-19.
• Record-keeping: If you check in to our Facilities in person, we will keep records of your personal information for no longer than thirty (30) days after the date we receive it, as required by New York State law. If you complete the information requested by the online questionnaire but do not check in to our Facilities within 24 hours of completion, your personal information will be deleted.
• Meeting legal requirements and enforcing legal terms: We collect your personal information for purposes of fulfilling our legal obligations under applicable laws, regulations, court orders or other legal processes relating to COVID-19, and protecting the rights, property or safety of you, ourselves and other parties.
Disclosure of Personal Information
We may share your personal information as necessary for the purposes described in this Privacy Notice, including internally with personnel involved in the administration and implementation of our health and safety measures. In addition, we may disclose personal information in accordance with applicable laws, regulations, court orders or other legal processes relating to COVID-19 (e.g. to public health authorities).
Contact for Questions
If you have any questions or concerns regarding this Privacy Notice or the collection of your personal information, please contact us by mail at Trinity Church Wall Street, 76 Trinity Place, New York, NY 10006, or email us at firstname.lastname@example.org. Individuals who need assistance or accommodations to attend worship please email email@example.com or call 212.602.0800.