Issue Date: 28th May 2014
Who does this policy apply to and what does it cover?
We, Katoomba RSL All Services Club (“Club”) operates the following licensed premises:
- Katoomba RSL located at 82 – 86 Lurline Street, Katoomba; and
- Wentworth Falls Bowling Club located at the corner of the Great Western Hwy and Falls Road, Wentworth Falls.
We operate a website www.katoombarsl.com.au and social media associated with our venues and services.
This policy describes how we handle the “personal information” collected from members, guests and others.
Personal information means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
What is our privacy commitment to you?
We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”) by protecting the privacy and confidentiality of your personal information and the personal information of all our members, guests and others.
When we collect, use, disclose, store, access or correct your personal information, our actions will comply with the Privacy Act and the Australian Privacy Principles.
Where appropriate, we will handle personal information relying on the employee records exemption and the related bodies corporate exemption in the Privacy Act.
What kinds of personal information does the Club collect and hold?
We collect a wide range of personal information, and in some cases sensitive information, which includes:
- A photo of you for your membership card;
- your contact details including your occupation and date of birth;
- details of your membership with us including any positions held by you at the Club or any complaints made by you or against you;
- information about what goods or services you buy or receive from us;
- details of your activities with us, including your participation in social or sporting activities or your involvement with our sub-clubs;
- health information including any medical conditions you may have or assistance you may need when using our facilities or services;
- information connected to your use of our gaming machines (including your player activity statements, amounts you spend and prizes you receive);
- information about you related to a liquor or gaming self-exclusion or a banning order whether from yourself, other clubs, ClubsNSW, a Liquor Accord, the Independent Liquor Gaming and Racing Authority or Office of Liquor Gaming and Racing;
- things you say or do (or said about you) in connection with an incident or potential disciplinary proceedings;
- images or video of you at our premises; and
- if you apply for a job with us, the information in your resume and other information that you or your referees provide to us, including notes of our interactions with you and/or others in relation to your prospective employment.
From time to time, we may collect additional information related to surveys, specific promotions, services or activities. Wherever practicable, we will advise you of the information being collected and provide you with an opportunity to refuse the collection of information.
How do we collect your personal information?
Your personal information is collected as a result of your visits to (or dealings with) us. Information is collected by recording information that you provide to us, by electronic means, and the observations of our staff. We collect personal information when you:
- visit any of our venues;
- apply for, or renew, your membership with us or request to use our services;
- purchase goods or services from us;
- use our gaming machines or request to be excluded from using our gaming machines;
- plan or attend a function, conference or show at a venue operated by us;
- participate in activities offered by us including competitions and promotions;
- visit any of our websites or social media sites;
- are banned or removed from our premises or the gaming area;
- use your Club membership card or another card issued by us;
- receive or request sponsorship through programs such as ClubGRANTS;
- are involved in, witness, or are connected to an incident at our premises or disciplinary proceedings of the Club; and/or.
- obtain or apply for membership of a one of our sub-clubs or participate in the activities of one of sub-clubs.
When we collect information from you we will take reasonable steps to notify you (or otherwise ensure that you are aware) of the following:
- our identity and contact details;
- the facts and circumstances of the collection;
- details of any law that require or authorize the collection;
- the purposes of collection;
- the consequences if we do not collect the information;
- that this policy contains information about how you can access or correct your information or make a complaint about the Club; and
- whether we are likely to disclose the information overseas (and if so to which countries).
We only collect personal information about you from you unless it is unreasonable or impractical to do so. For example, it may be unreasonable or impractical to collect information from you when the information is provided by other members, patrons, our staff or the police.
As a registered club, we have a legal responsibility to collect certain information about our members and guests pursuant to the Registered Clubs Act, the Corporations Act, Gaming Machines Act, Liquor Act, Anti-Money Laundering and Counter-Terrorism Financing Act and Work Health Safety Act.
For example, when a person applies for membership with us we must collect details including their name and address. We must display this information on the club’s notice board before our Board is able to consider the application for membership. We may also need to provide this information to other members if a request is made under the Corporations Act.
Temporary members, guests of members and other visitors to the Club may be required to produce a recognised form of identification (such as a drivers licence or passport) to gain entry into the licensed premises.
For what purposes does the Club collect, hold, use and disclose your personal information?
We collect, hold, use and disclose personal information to operate the Club, carry out certain activities, provide products and services to members and guests and other members of the public and comply with our legal obligations. The purpose of collecting personal information is to:
- consider applications and renewals of membership;
- identify who comes to our premises and verify their age and address;
- provide a safe environment for you, other patrons, visitors and our staff;
- provide services to members and their guests and other members of the public;
- carry out accounting and finance requirements and legal and administrative reporting requirements;
- operate functions and conferences at our venues;
- carry out competitions and promotions;
- perform gaming operations;
- publish and distribute newsletters;
- carry out marketing (including direct marketing);
- offer and manage sponsorships, including supporting community, sports and social events;
- provide ticketing services, offer dining options and other entertainment including shows;
- operate and support our sub-clubs;
- conduct elections of the Board;
- conduct disciplinary proceedings;
- resolve a complaint;
- assess an applicant’s suitability for employment; and
- increase membership of the Club.
What happens if you don’t provide your personal information?
If you don’t give us your personal information you may not be able to become a member of the Club or use our services or facilities.
In most circumstances you will be unable to deal with us anonymously or with a pseudonym because of our obligations under the Registered Clubs Act.
How do we use your personal information?
We use your personal information primarily to allow us to carry out the activities and functions listed above. We also use your personal information for secondary purposes related to those activities or when allowed under the Privacy Act.
The Club may also use the personal information we collect from you for direct marketing of products and services to you including from third party suppliers. Such products and services may include the provision of newsletters, competitions, announcements, campaigns or information about shows and entertainment at the Club or services offered by the Club.
You can refuse any direct marketing by contacting our Privacy Officer.
Does the Club disclose my personal information to others?
There may be times when we may need to disclose your personal information to third parties including our insurers, ClubsNSW, a Club sponsor, our legal or financial advisers or to other Club members. Personal information will only be disclosed to these parties for a purpose permitted by the Privacy Act and/or this policy and your consent will first be obtained where appropriate.
We may need to disclose your personal information to third parties for the purposes of allowing us to carry out the activities listed above. For example, from time to time, we engage external companies to send direct marketing including emails and sms, to carry out mail services, IT storage services and software related services. These external companies only have access to the information necessary to provide services to the Club. They are required to comply with the Privacy Act and must offer privacy standards comparable to those offered by us.
We will disclose your personal information if we are required or authorized to do so by law enforcement agencies, the Australian Electoral Office, the Department of Family Services or the Australian Taxation Office.
FREQUENTLY ASKED QUESTIONS
Is there surveillance at the Club?
All venues operated by us are subject to video and audio surveillance for security reasons including to monitor the safety of members, guests and employees and to protect the our assets. The footage and audio recordings may be used in disciplinary proceedings and/or to investigate incidents and may be disclosed to our legal representatives, our insurers and law enforcements agencies.
How do we hold and protect your personal information?
Personal information that is held by us is stored both electronically and by hard copy.
We take reasonable steps to ensure that your personal information is safe and secure from unauthorised use and disclosure whether such information is stored electronically or in hard copy.
Information that is stored electronically on our servers is restricted and password protected and only accessible to relevant employees.
Information from the guest and visitor sign in registers is initially stored in a restricted access area and then in a locked store room.
Video and audio surveillance are stored on our digital recorders which are maintained in a restricted access area and password protected.
Your personal information is securely destroyed when it is no longer needed or when it is out of date.
Are we likely to disclose personal information overseas?
It is unlikely that we will disclose your personal information overseas. However, if you agree to information being put on our websites then this could be accessed by anyone in Australia and by persons in other countries.
Using the Club’s websites
The websites and social media sites operated by us may contain hyperlinks to other websites including those operated by third parties.
The links are provided for reference only. We do not have any control over these external websites. We are not responsible for the content on these sites or the privacy practices adopted by these sites.
What does this policy mean?
By attending the Club or participating in an activity with us, you consent to the terms of this policy.
From time to time, your additional consent will be sought for the collection, use or disclosure of information for purposes other than as set out in this policy.
If you do not agree to any part of this policy or do not wish to receive direct marketing information from the Club, please contact the Privacy Officer listed in this policy.
How do I access, update or correct the personal information held by the Club about me?
You can request access the personal information we hold about you by contacting our Privacy Officer.
We will not charge you for making the request. However, we may need to charge you for our time to answer your request. We will advise you in advance if there are to be any charges associated with complying with your request.
We will respond to your request in a reasonable time frame (usually not more than 30 days). When you request access we may need further information from you to verify your identity.
There are a number of reasons why we may be unable to give you access to your information. If we are not able to provide access to your information we will provide you with our written reasons.
If you believe any of the personal information that we hold about you is incorrect you can ask us to correct it.
If asked to correct your personal information we will take reasonable steps to correct the information to ensure that it is accurate, up to date, relevant and not misleading. If we refuse to correct your personal information we will give you written reasons.
How do I make a complaint about privacy at the Club?
If you believe we have breached the Privacy Act or any of the Australian Privacy Principles or if you want to raise any issues you may have about privacy at the Club please contact our Privacy Officer.
In making a complaint to us about privacy, please give us enough details to be able to identify your concerns and respond appropriately. You must provide us with your name and contact details and a description of your complaint. We will respond to you in a reasonable time frame (usually not more than 30 days). If you are unhappy with how we handle the complaint you have a right to take the complaint to the Office of the Australian Information Commissioner.
How do I contact the Privacy Officer at the Club?
You can contact the Privacy Officer by:
|Phone:||02 4782 2624|
|Post:||P.O Box 820 Katoomba NSW 2780|