The Privacy Act 1988 (Act) regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information, and access to and correction of that information. The Act binds certain entities including the Central Coast Leagues Club Limited ABN 83 001 036 068 (Club) and (we) and establishes 13 Australian Privacy Principles (APP) that apply to the handling of personal information by the Club.
This policy applies to all Central Coast Leagues Club Directors, employees, contractors and consultants of the Club.
The types of information that we collect and hold about you could include:
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect licensed clubs, including the Corporations Act, Registered Club’s Act and Anti-Money Laundering & Counter-Terrorism Financing Act, which require us to collect personal information. For example, we require personal information to permit you to join the Club or to use the Club’s premises of you are not a member. Sometimes, we may be required to verify your identity under the Anti-Money Laundering & Counter-Terrorism Financing Act also.
How we collect and hold your information
We understand that your personal information needs to be looked after. We appreciate that such information is generally not available to the public to view. For this reason, unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.
There are many ways we seek information from you. We might collect your information when you fill out a membership application form to join the Club as a member, when you enter the Club as a temporary member of guest of a member or if you’ve given us a call. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances are where:
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
Because we are a big Club with thousands of members, people often share information with us we haven’t asked for (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
Notifying you that we have received your personal information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
How do we take care of your personal information?
We store information in many different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
The Club is committed to ensuring the safe storage and management of your personal information. However, the Club has a policy in place in relation to any inadvertent disclosure of personal information, in accordance with the Privacy Amendment (Notifiable Data Breaches) Act 2017. The Club will act in accordance with its’ Data Breach Policy & Response Plan where necessary. You will be informed if a data breach occurs where it is likely to result in serious harm to you through unauthorised access or disclosure of personal information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act and Gaming Machines Act for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
What are the main reasons we collect, hold and use your information?
Because we hold a Club Licence and have members, the Registered Clubs Act and Corporations Act require us to collect your personal information to allow us to let you use the facilities and amenities of the Club. This allows us to use your personal information to:
Can we use your information for marketing our products and services?
The Club exists to provide products and services to our members. For that reason, we like to share information about those products and services with you as often as we can. We may use or disclose your personal information to let you know about products and services offered or promoted by the Club that might better serve your needs as a member, including running competitions or promotions, upcoming events and functions and other opportunities which may be of interest to you.
We may conduct these marketing activities via email, telephone, SMS, iM, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites), or based on your use of the Club programs. We will always let you know that you can opt out from receiving our third party or the Club program marketing offers.
With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation outside of the Club.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from the Club. Just drop in to one of the Club’s sites and inform our reception staff. We will process your request as soon as practicable.
Using your Personal Information?
We’ve set out above some of the main reasons why we collect your personal information. So here we set out some of the ways we use your personal information:
Protecting your privacy while attending the Club
For the security of all that enter the Club a CCTV system is operated in the club premises.
This vision is not shared with any organisation outside the Club except the Police and other agencies that may require it for security purposes.
The Club does not permit video recording in the clubs without express permission and pre-approved authority from anyone that may be videoed.
Who do we share your personal information with?
To make sure we can meet your specific needs and for the purposes described in ‘Using your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing at your request
We may need to share your personal information with your representative or any person acting on your behalf (for example, lawyers, accountants, executors, administrators, trustees, brokers or auditors).
Sharing with third parties
We may disclose your personal information to third parties outside of the Club, including:
How you generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us to access your personal information that we hold by attending reception at a Club site. You may be required to complete a Personal Information Access Form before we can assist you. In some cases we may be able to deal with your request over the phone or immediately at reception.
We will give you access to your information in the form you want it where it’s reasonable and practical (such as a copy of your membership details – we can print it out for you). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain.
How do you correct your personal information?
Contact us if you think there is something wrong with the information we hold about you and we’ll tryto correct it if it’s:
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
Helping you manage corrections
Whether we made the mistake or the mistake has been made by someone else, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five (5) business days of forming that view. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing. We will try to do this within five (5) business days of making this decision. If you have any concerns, you can make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within thirty (30) days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within thirty (30) days or the agreed time frame, we must:
How do you generally make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by:
We are committed to resolving your complaint and doing the right thing by our members. Mostcomplaints are generally resolved quickly, and you should hear from us within ten (10) business days.
If you have contacted us by phone, post, email or in person and feel your issue still hasn’t been resolved, the next step is then you can raise your concern with the Office of the Australian Information Commissioner:
Anonymity or use of a Pseudonym
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you, but that will generally depend on the nature of the questions being asked. As a public company with lots of members we are sometimes restricted in the information we can discuss with people who are unknown to us. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website at https://www.cclc.com.au/. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement
The Leadership Team & CCLC Board of Directors.
This policy and procedures will be constantly monitored to ensure compliance and reviewed to ensure ongoing effectiveness and relevancy. This policy will be communicated by email to all staff and a complete folder of all CCLC policies will be stored in the Staff Room and Board Room.
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