1. Personal information
What is Personal Information?
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.
Some examples of personal information are your name, residential address, email address, bank details, photos and opinions on your likes and dislikes that can identify you (see paragraph 3.2 below).
2. Sensitive Information
What is Sensitive Information?
Sensitive information is a subset of personal information.
It means information or opinion about an individual's racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
Collection of Sensitive Information
In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you.
The type of sensitive information we may collect from you or record about you is dependent on the services provided to you by the club and will be limited to the purpose(s) for which it is collected.
We do not use sensitive information to send you Direct Marketing Communications (as defined in paragraph 7 below) without your consent.
We will not collect sensitive information from you without your consent.
Consent to Collection of Certain Types of Sensitive Information
We may collect certain types of sensitive information where you have consented and agreed to the collection of such information.
We will obtain your consent at (or around) the point in time in which we collect the information.
The main type of sensitive information that we may collect (if any) will usually relate to your:
but only if the sensitive information is necessary for, or incidental to, the purposes of collection set out in paragraph 4.
3. Collection of Your Personal Information
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 4.
The type of information includes (but is not limited to) the following:
When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback, we may ask you to provide certain information, which you may withhold or provide at your own discretion. It is optional for you to engage in these activities.
Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to provide or effectively provide our services to you.
If you use our website, we may utilise "cookies" which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our website. A cookie does not identify you personally but may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
4. Use and Disclosure of Your Personal Information
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.
You consent to us using and disclosing your personal information to facilitate a purpose in connection with:
a. the administration and management of our products and services, including charging, billing, credit card authorisation and verification, checks for financial standing, credit-worthiness (including but not limited to undertaking an assessment for credit loss and obtaining credit references, if applicable), fraud and collecting debts; and
b. to offer you updates, or other content or products and services that may be of interest to you;
a. the use of your personal information collected in accordance with paragraph 1 in the administration and management of the club;
b. communications between reciprocal Clubs;
c. the management, governance and administration of the club, including but not limited to any management and governance meetings of the club ;
a. when it 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 is required or authorised by law or formally requested by a statutory or regulatory authority.
In the event we propose to use or disclose such personal information other than for reasons in 1, 4.2, and 4.3 above, we will first seek your consent prior to such disclosure or use.
5. The Types of Organisations to Which We May Disclose Your Personal Information
We may disclose your personal information to other organisations. Examples of organisations and/or parties that your personal information may be provided include:
6. Photographs and Closed Circuit Television
We use closed circuit televisions (CCTV) at certain locations throughout our premises (e.g. entry and exit) and surrounding areas. The CCTV is integral to our security system and CCTV images are stored for a minimum “retention period" of 28 days (unless an incident is identified, in which case the images are archived and retained for a minimum period of one year after the retention period unless they are given to the relevant authority (e.g. police or OLGR investigator). The CCTV footage must be archived if requested by the relevant authority.
As indicated in paragraph 2(i), we may take photographs of you attending our premises or club sanctioned events held off 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.
(Note: If an incident occurs at the venue, CCTV footage for the period leading up to, during and following the incident must be archived and where no incident has been identified, the CCTV footage is automatically deleted within 30 days after the retention period.)
7. Direct Marketing
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) (Direct Marketing Communications) which we consider may be of interest to you.
Without limitation clause 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 consider may be of interest to you.
If at any time, you do not wish to receive any further Direct Marketing Communications from us, or others under paragraph 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 at any time by using the “unsubscribe" facility included in the email or by contacting us via the details set out at the end of this document.
8. Cross Border Disclosure
Any personal information that you provide to us may be transferred to, and stored at, a destination outside Australia, where we may utilise overseas data and website hosting facilities or have entered into contractual arrangements with third party service providers to assist us with providing our goods and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
If you do not agree to the transfer of your personal information outside Australia, please contact us by via the details set out at the end of this document.
9. Data Quality and Security
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.
Notwithstanding the above, we will take reasonable steps to:
However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
10. Access to and Correction of your Personal Information
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.
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.
12. Resolving Privacy Complaints
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 time-frame 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.
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.
The Brisbane Club
GPO Box 2431
Brisbane, QLD, 4001.
Please mark your correspondence to the attention of the Chief Executive.
In order to resolve a complaint, we:
We will keep a record of the complaint and any action taken in a privacy register.
Date of Effect: 12 March 2014