1. how and when the club collects personal information;
2. how the club uses and discloses personal information;
3. how the club keeps personal information secure, accurate and up-to-date;
4. how an individual can access and correct their personal information; and
5. how the club will facilitate or resolve a privacy complaint.
1. Personal information
1.1 What is Personal Information?
- (a) Personal information is defined under the Privacy Act 1988 to mean information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.
- (b) Some examples of personal information are your name, residential address, email address, photos and opinions on your likes and dislikes that can identify you (see paragraph 3.2 below).
2. Collection of your personal information
2.1 We will only collect personal information that is necessary for us to provide our products and services to you. This depends ultimately upon the purpose of collection and we have set out the general purposes of collection at paragraph 3 below.
2.2 The type of information includes (but is not limited to) the following:
- (a) your contact information such as full name (first and last), e-mail address, current postal address, delivery address ( if different to postal address) and phone numbers;
- (b) details relating to your employment (if applicable) or your previous employment, which shall include, but is not limited to, obtaining your tax file number and superannuation details;
- (c) your date of birth;
- (d) proof of your identity (including, but not limited to, driver’s license, passport, birth certificate);
- (e) if applicable, emergency contact details;
- (f) details required as part of your club membership or visitation, including but not limited to the information required under the members and visitors registers;
- (g) whether you participated in any activity or event organized by the club;
- (h) photographs or video footage taken at our premises which may include you;
- (i) your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the products and services offered by the club; and
- (j) if you are requesting products or services from us or we are purchasing goods or services from you, then any relevant payment or billing information (including but not limited to bank account details, direct debit, credit card details, billing address, repayment information and invoice details).
3. Use and disclosure of your personal information
3.1 We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to and /or as set out below.
3.2 You consent to us using and disclosing your personal information to facilitate a purpose in connection with;
- (a) if required, the verification of your identity, including the verification of your date of birth, if applicable;
- (b) facilitating membership or visitation requirements (for example, entry into a Register of Members which is available for public inspection by other members);
- (c) provision of our products and services to you, which shall include but is not limited to:
- (1) the administration and management of our products and services, including charging and billing, fraud and collecting debts; and
- (d) to facilitate the administration, management and improvement of the club, including but not limited to:
- (1) the use of your personal information collected in accordance with paragraph 2.1 in the administration and management of the club;
- (2) communications between Member Clubs (being those clubs which are members of Clubs Queensland), including but not limited to reciprocal arrangements and sharing of industry news;
- (3) the management, governance and administration of the club, including but not limited to any management and governance meetings of the club;
- (e) if applicable, any requirement to include you in various registers maintained by the club including, but not limited to, the register of excluded persons;
- (f) facilitating medical assistance in the event of a medical emergency, or to provide you with medical treatment as requested by you;
- (g) your participation in any activity or event organized by the club or a third party organization;
- (h) your ability to attend other Member Clubs in Australia or New Zealand;
- (i) co-ordinating, managing and maintaining good order and security of the club and our premises, which shall include but is not limited to protecting the rights and safety of other parties on our premises;
- (j) investigating and reporting information to third parties regarding any accidents or incidents that may have occurred on our premises;
- (k) the improvement of our services (including to contact you about those improvements and asking you to participate in surveys about our products and services);
- (l) the maintenance and development of our products and services, business systems and infrastructure;
- (m) marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) such as our customer loyalty programs and newsletters;
- (n) to provide customer service functions, including handling customer enquiries and complaints;
- (o) to offer you updates, or other content or products and services that may be of interest to you
- (p) our compliance with applicable laws;
- (q) the transfer, and matters in connection with a potential transfer, of the club to another entity; and
- (r) any other matters reasonably necessary to continue to provide our products and services to you.
3.3 We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
- (a) when is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose (secondary use);
- (b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
- (c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
- (d) if it required or authorised by law or formally requested by a statutory or regulatory authority.
3.4 in the event we propose to use or disclose such personal information other than for reasons in 3.1, 3.2, 3.3 above, we will first seek your consent prior to such disclosure or use.
4. The types of organizations to which we may disclose your personal information.
4.1 We may disclose your personal information to other organisations. Examples of organisations and or parties that your personal information may be provided include;
- (a) other member Clubs;
- (b) Clubs Queensland and its related bodies;
- (c) if applicable, Clubs Australia and New Zealand, and member clubs of Clubs Australia and Club New Zealand;
- (d) offshore service providers, if any;
- (e) related entities and subsidiaries of the club;
- (f) third parties, such as trade suppliers and club sponsors; and
- (g) our contractors and agents, including but not limited to our professional advisors such as accountants, solicitors and auditors or other companies who assist us in providing our products and services to you.
5.1 As indicated in paragraph 2.2 (h), we may take photographs of you attending our premises, and we may wish to use them for marketing and advertising purposes. Unless you advise us otherwise you expressly agree and consent to the use of any photographs, which may include you, for the aforementioned purposes, without compensation.
6. Direct Marketing
6.1 You expressly consent to us using your personal information, including any email address you give to us, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which may be of interest to you.
6.2 Without limitation clause 6.1, if it is within your reasonable expectations that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we may consider may be of interest to you.
6.3 You expressly consent to us disclosing your personal information to other organisations (including but not limited to organisations such as those listed in paragraph 4.1) that may also use your personal information for sending you Direct Marketing Communications.
6.4 If at any time, you do not wish to receive any further Direct marketing Communications from us, or others under paragraph 6.3, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose.
You may do this any time by contacting us via the details set out at the end of this document.
7. Data quality and security
7.1 We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the internet is involved.
7.2 Notwithstanding the above, we will take reasonable steps to;
- (a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
- (b) protect your personal information from misuse, loss, unauthorised access, modification or or disclosure both physically and through computer security methods; and
- (c) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
7.3 However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
- (a) let us know if there are any errors in you personal information; and
- (b) keep us up to date with changes to your personal information (such as your name and address)
8. Access to and correction of your personal information
8.1 You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law (e.g. secrecy provisions under the Anti Money Laundering and Counter Terrorism Financing Laws). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
8.2 If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the end of this document,
10. Resolving Privacy Complaints
10.1 We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
10.2 If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, you can tell us by contacting us.
Telephone: (07) 33961829
Post: 1 Bridge St Wynnum Qld 4178
Please mark your correspondence to the attention of the Secretary.
10.3 In order to resolve a complaint, we:
- (a) will liaise with you to identify and define the nature and cause of the complaint;
- (b) may request that you provide the details of the complaint in writing;
- (c) will keep you informed of the likely time within which we will respond to your complaint;
- (d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.
10.4 We will keep a record of the complaint and any such action taken in a privacy register.