Privacy Policy

Privacy Policy

Ingleburn RSL Sub-Branch Club Limited (“Club”) is subject to the provisions of the Privacy Act 1988; the Act contains 13 Australian Privacy Principles that set standards for the handling of personnel information. Any personal information provided by our Members to this Club (e.g. Name, address, date of birth and contact details), including information collected as a result of a Membership Card being placed in a gaming machine or any other Club machine that is linked to a Member loyalty system that may provide a benefit or service to our Members, will be protected and used only in accordance with the terms of this privacy policy..

Ingleburn RSL Club will not disclose your personal information to any other party or organisation as set out in this privacy policy . Ingleburn RSL Club may disclose personal information to relevant authorities if they believe there is a threat to any Members life, health, or safety, or public health or safety.

If there is reason to suspect that unlawful activity has been, is being or maybe engaged in, personal information may be provided or disclosed as a necessary part of any investigation to relevant persons or authorities. If Ingleburn RSL Club is obliged to provide any information to a third party that provide services under contract to this Club, these contractors will be required to keep and maintain this information confidential and secure.

Your personal information, including information about you obtained via your Membership Card being placed in a gaming machine (not ATMs) may be used by the Club for the internal purposes of marketing and promotions, to provide and improve our services to our Members and to provide the latest information about those services and promotions. As a Member you have the right to access any personal information that the Club may hold about you, including the right of correction about that information, if you require any further information or clarification about the Privacy Policy please contact Administration. Contact details are at the end of this Policy.

This Privacy Statement has been unanimously adopted and endorsed by your Board of Directors

The Principles do not apply to employee records. As a result, this Policy does not apply to the Club’s treatment of employee records, where the treatment is directly related to a current or former employment relationship between the Club and an employee.
This Policy is available free of charge and can be accessed on the Club’s website at www.ingleburnrsl.com.au

AUSTRALIAN PRIVACY PRINCIPLES (APP) PRIVACY POLICY OF THE INGLEBURN RSL CLUB

This policy accords with the Australian Privacy Principles which became effective on 12 March 2014. The principal activities of the club are:-

 • Providing a venue for members and guests to engage in social activities
• Supporting the community in sporting events
• Providing members and their families access to a range of services
• Providing affordable meals
• Providing a safe friendly environment for locals to meet

APP 1 – Open and transparent management of personal information

(a) the kinds of personal information that the entity collects and holds;
The Club collects personal information from members including name, address, occupation, date of birth, proof of age and contact details.

(b) how the entity collects and holds personal information;

Members
One way we collect personal information from you is for you to lodge an application form approved under the Registered Clubs Act. We may also collect information from you when you complete other forms, participate in competitions and submit an application for employment. This personal information may include your full name, date of birth, phone and fax numbers, e-mail address, and street and postal address. In some occasions, a recognised form of identification i.e. passport or drivers license will also be required to confirm the personal details provided.
Ingleburn RSL Club requires supporting documentation to process application forms and the unique identification number is recorded on the application form.

Visitors and Guests
Under the Registered Clubs Act patrons visiting the club must produce a recognised form of identification i.e. passport, drivers license or proof of age card to gain entry to the premises. Ingleburn RSL uses terminals to gather this information and to protect the data collected i.e. addresses of patrons. Scanning of licenses is optional, and if preferred, use of manual sign-in, via the terminals is available for patrons once the form of identification has been sighted by an authorised officer of the club.(c)The Club collects personal information from individuals, including members, visitors and guests, by a variety of means including:

• membership application or renewal forms;
• competitions and promotions entries;
• sports registration forms;
• sign in terminals;
• automatically when you use your computer to access the Club website or any Club APP;
• automatically when you use your mobile device to access our websites or online resources;
• through you utilising the facilities of the Club such as booking a function, or receiving goods or services from the Club, or contacting the Club by telephone;
• through bookings and use of payment methods both electronically and otherwise with the Club;
• accessing publicly and commercially available personal, identity, geographic and demographic information;
• when you visit the Clubs website, or use our other online resources, the Club may use cookies, single pixels tags and similar tracking technologies including tools provided by third parties such as Google, to collect or receive personal information; and
• if you access the Club website or other online platform, or connecting wireless devices to a Club service or network, the information we collect may also include your IP address, type of operating system, browser type, domain name, date and time of interaction, pages you visit, location when accessing the website and your online behaviour; and
• video  surveillance (including information required to give effect to the screening technologies and video surveillance purposes set out below).

Personal information, including information about you obtained as a result of you placing your membership card in a gaming machine or other Club outlet that is linked to a member loyalty system, may also be used by the Club for marketing and promotional purposes. You may receive marketing material by way of telemarketing, targeted digital advertising, post, email, SMS, MMS messages,  notifications and alerts to your mobile device or by any other electronic means available to the Club from time to time.  You may elect not to participate in the loyalty program at any time.  The terms of the loyalty program govern the operation of the loyalty program and may change from time to time.

The Club premises are subject to screening technologies and  video  surveillance at all time including:

(i)                  Collecting information from your driver’s licence or other identification card when you enter the premises; 

(ii)                Collecting your car number plate details when you park in the car park of our premises;

(iii)              Using information from your driver’s licence or other identification card or from your car number plate details, to match the personal information we hold about you; 

(iv)              Monitoring member and guest behaviour in Club venues including with respect to the reasonable consumption of alcohol; and

(v)                Using facial recognition technology to collect information about your facial features for comparison against lists of self-excluded persons, suspended members and individuals and barred members and individuals. 

When visiting the Club a guest must provide either their Driver’s License, Passport or other recognised and acceptable form of identification to gain entry to the premises.

The Club uses terminals, or other means, to gather this information including by way of scanning your drivers licence.

 

(d)  Use and Disclosure of Personal Information.

The Club is careful about how it uses your personal information. The Club will only use or disclose your personal information for the purpose for which you have provided it, for purposes as permitted by the Privacy Act or for the purposes that are set out in this Privacy Policy.

The Club collects personal information in order to use it and disclose it as follows:

a)     To know who you are, verify your age, identify you and process your membership applications and renewal;

b)     comply with requirements under the Registered Clubs Act, Corporations Act, Anti – Money Laundering and Counter Terrorism laws, Income Tax Assessment Act and other relevant legislation;

c)      comply with obligations relating to the responsible provision of gaming services,

d)     contact members and guests to advertise and market events, activities, opportunities, offers and the goods and services provided by the Club including without limitation with respect to food and beverage, promotions, entertainment, gaming, wagering, gaming machines, sporting events, KENO, TAB, functions and venue hire;

e)     send notices as required by the Club’s Constitution, the Corporations Act, the Registered Clubs Act and or other law;

f)       analyse usage of food and services offered by the Club;

g)     provide you with goods or services you are receiving or utilising as offered by the Club;

h)     provide any benefits you become entitled to in relation to that product or service you have received or purchased from a Club;

i)       analyse website and other online resources usage;

j)       respond to your submissions, questions, comments, requests and complaints;

k)     conduct our internal business and management processes, for example accounting or auditing purposes;

l)       for any other purposes that would reasonably be expected by you as a result of disclosing your information to the Club or by being a Club Member;

m)   the collection and use of the physical location of your mobile device for security purposes and to provide you with alerts, notifications and other information related to our products or services;

n)     complying with obligations that we may have under laws that apply to our business or to meet reasonable requests from regulatory bodies which regulate our business, such as preparing player activity statements and monitoring the responsible provision of gambling services in our Club, including the exclusion of patrons from our Club.;

o)     when our facial recognition technology scans your facial features (collecting relevant biometric data) on entry to our club premises we use that information to check your facial features against the facial biometric data held by with Club with respect to excluded, barred or suspended persons or members;

p)     we use your biometric data from photos from your identification previously provided to us, supplied to us by third parties, or from your member card photo, but only if you are an excluded, barred or suspended person or member, to inform our facial recognition technology to identify when you are entering our premises;

q)     for Club disciplinary charges and hearings; and

r)      to monitor your use of the Club services and facilities.

 

Details of suspected or actual illegal activities on our premises may be shared with other clubs, law enforcement and regulatory bodies such as Liquor and Gaming New South Wales  and the Independent Liquor and Gaming Authority.

From time to time, we may wish to carry out a voluntary survey for feedback. Before collecting survey results, we will advise you of the purpose of the survey e.g. to gain information for the club to improve services etc. Participation in surveys is optional.

(d) how an individual may access personal information about the individual that is held by the entity and seek the correction of such information;
Individuals may access and alter records containing their personal information. To change your name on the membership database supporting documentation from a government source is required. Change of addresses can be done by completing a “Change of Address” form, by letter or by use of the internet. (e) how an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint;

 Club must comply with the Privacy Act and the Australian Privacy Principles which regulates, among other things, the collection, storage, quality, use and disclosure of personal information.

If you wish to register a complaint about a breach of these principles, you may do so by contacting the Chief Operating Officer at the Club who will thoroughly and fairly review the complaint. If a breach is found to have occurred, immediate action will be taken to rectify the problem to ensure a similar breach does not re-occur.

(e) Third Party Disclosure.

(A)The Club may share your information with other parties who provide services to us, including organisations, agents, facial recognition technology suppliers, partners and contractors that assist us with providing our business processes and products and services. These contracts with third parties will require the third party to keep your personal information confidential and secure. The Club will as required by law, or upon reasonable request, disclose personal information to government departments, statutory bodies, authorities and law enforcement. These third parties may include (but are not limited to):

 

(i)             employees, third party service and content providers, dealers, agents, contractors, suppliers, business support services, payment processors, website hosting service providers, rewards and loyalty service providers, cloud storage providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors and professional advisors such as accountants, solicitors, business advisors and consultants;

(ii)           law enforcement bodies, courts of law or as otherwise required or authorised by law;

(iii)          regulatory or government bodies;

(iv)         any organisation for any authorised purpose with your express consent.

 

(B)                Where authorised by law or by a reasonable request, or for any of the purposes outlined in this Privacy Policy, the Club may disclose personal information to to government agencies including:

(a)     The Australian Taxation Office

(b)    Australian Securities and Investments Commission

(c)     Centrelink

(d)    Child Support Agencies

(e)     Australian Financial Security Authority

 

(C)                Before personal information about you is disclosed to a contracted third party, the Club will take steps as are reasonably practicable and appropriate in the circumstances to ensure that the third party does not breach the Australian Privacy Principles in relation to the information.

(f) whether the entity is likely to disclose personal information to overseas recipients;
The Club is not likely to disclose any personal information to overseas recipients.

APP 2 – Anonymity and pseudonymity

(a) Under some circumstances, individuals may have the option of not identifying themselves, or of using a pseudonym, when dealing with the Ingleburn RSL Club in relation to a particular matter.

(b) However, the Club’s obligations to identify members, temporary members and guests overrides this option, so we are obliged to ensure we collect the true identity of patrons as they enter our premises.

(c) We will also not accept anonymity or use of a pseudonym where it is impracticable for us to deal with individuals who have not identified themselves or who have used a pseudonym.
APP 3 – Collection of solicited personal information

(a) The Club will only collect personal information that is reasonably necessary for, or directly related to one or more of the Club’s functions or activities.

(b) The Club will not solicit, collect or usesensitive personal information other than a collection of your facial biometric data upon your entry to the Club where it will be compared against facial biometric data held by the Club in connection with excluded, suspended and barred persons. 

The Club considers the collection of such sensitive as being appropriate to achieving the legitimate interests of  the Club in working towards ensuring that excluded patrons do not enter the Club contrary to an exclusion order and that barred or suspended individuals, who may be current or former members, or guests, are not permitted to enter the Club premises in breach of the law or the constitution of the Club.  The use of facial recognition technology is promoted by Liquor & Gaming New South Wales as a legitimate strategy to identify if an excluded person is attempting to enter the Club premises contrary to an exclusion order. 

The Club includes on its sign in terminals and signage located at the entry to the Club notices advising members and guests that facial biometric data is being collected from persons who are entering the Club.  If your facial biometric data does not match biometric data on the Clubs excluded, suspended or barred person lists then your facial biometric data will be disposed of by the Club and not retained or used for any other purpose.   If you facial biometric data is a match for facial biometric data on the excluded suspended or barred persons list then your sensitive information will be used to remove you from the premises of the Club.APP 4 – Dealing with unsolicited personal information
If:

(a) the Club receives personal information that has not been solicited, we must, within a reasonable period after receiving the information, determine whether or not we could have collected the information under Australian Privacy Principle 3 if we had had solicited the information.

(b) If the Club determines that we could not have collected the personal information; and the information is not contained in a Commonwealth record, we will, as soon as practicable, destroy the information or ensure that the information is de-identified.

APP 5 – Notification of the collection of personal information

(a) At or before the time or, if that is not practicable, as soon as practicable after, the Club collects personal information about an individual, we will take such steps (if any) as are reasonable in the circumstances:

(i) to notify the individual of such matters referred to in subclause 5(b) below as are reasonable in the circumstances; or

(ii) to otherwise ensure that the individual is aware of any such matters.

(b) The matters for the purposes of subclause 5(a) are as follows:

(i) the identity and contact details of the Club;

(ii) if:

(ii.1) the Club collects the personal information from someone other than the individual; or

(ii.2) the individual may not be aware that the Club has collected the personal information;

(ii.3) the fact that the Club so collects, or has collected, the information and the circumstances of that collection;

(c) if the collection of the personal information is required or authorised by or under an Australian law or a court/tribunal order— the fact that the collection is so required or authorised (including the name of the Australian law, or details of the court/ tribunal order, that requires or authorises the collection);

(d) the purposes for which the Club collects the personal information;

(e) the main consequences (if any) for the individual if all or some of the personal information is not collected by the Club;

(f) any other Club, body or person, or the types of any other APP entities, bodies or persons, to which the Club usually discloses personal information of the kind collected by the entity;

(g) that the APP privacy policy of the Club contains information about how the individual may access the personal information about the individual that is held by the entity and seek the correction of such information;

(h) that the APP privacy policy of the Club contains information about how the individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint;

(i) whether the Club is likely to disclose the personal information to overseas recipients;

(j) if the Club is likely to disclose the personal information to overseas recipients—the countries in which such recipients are likely to be located if it is practicable to specify those
countries in the notification or to otherwise make the individual aware of them.

APP 6 – Use or disclosure of personal information

(a) If the Club holds personal information about an individual that was collected for a particular purpose (the primary purpose), we must not use or disclose the information for another purpose (the secondary purpose) unless:

(i) the individual has consented to the use or disclosure of the information; or

(ii) subclause (b) below applies in relation to the use or disclosure of the information.

(b) This subclause applies in relation to the use or disclosure of personal information about an individual if:

(i) the individual would reasonably expect the Club to use or disclose the information for the secondary purpose and the secondary purpose is:

(i.1) if the information is sensitive information—directly related to the primary purpose; or

(i.2) if the information is not sensitive information—related to the primary purpose; or

(ii) the use or disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order; or

(iii) a permitted general situation exists in relation to the use or disclosure of the information by the Club; or

(iv) a permitted health situation exists in relation to the use or disclosure of the information by the Club; or

(v) the Club reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
Written note of use or disclosure

(c) If the Club uses or discloses personal information in accordance with paragraph (b)(sub clause v) above, the Club must make a written note of the use or disclosure.
Exceptions

(d) This principle does not apply to the use or disclosure by the Club of:

(i) personal information for the purpose of direct marketing; or

(ii) government related identifiers.

APP 7 – Direct Marketing

(a) If the Club holds personal information about an individual, it must not use or disclose the information for the purpose of direct marketing.

Exceptions—personal information other than sensitive information

(b) Despite subclause (a), the Club may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:

(i) the Club collected the information from the individual; and

(ii) the individual would reasonably expect the Club to use or disclose the information for that purpose; and

(iii) the Club provides a simple means by which the individual may easily request not to receive direct marketing communications from it; and

(iv) the individual has not made such a request to the Club.

(c) Despite subclause (a), the Club may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:

(i) the Club collected the information from:

(i.1) the individual and the individual would not reasonably expect the Club to use or disclose the information for that purpose; or

(i.2) someone other than the individual; and

(ii) either:

(ii.1) the individual has consented to the use or disclosure of the information for that purpose; or

(ii.2) it is impracticable to obtain that consent; and

(iii) the Club provides a simple means by which the individual may easily request not to receive direct marketing communications from it, and

(iv) in each direct marketing communication with the individual:

(iv.1) the Club includes a prominent statement that the individual may make such a request; or

(iv.2) the Club otherwise draws the individual’s attention to the fact that the individual may make such a request; and

(v) the individual has not made such a request to the Club.

Exception—sensitive information

(d) Despite subclause (a), the Club may use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

Exception—contracted service providers
(e) Despite subclause (a), the Club may use or disclose personal information for the purpose of direct marketing if:

(i) the Club is a contracted service provider for a Commonwealth contract; and

(ii) the organisation collected the information for the purpose of meeting (directly or indirectly) an obligation under the contract; and

(iii) the use or disclosure is necessary to meet (directly or indirectly) such an obligation.

Individual may request not to receive direct marketing communications etc.

(f) If the Club (the first organisation) uses or discloses personal information about an individual:

(i) for the purpose of direct marketing by it; or

(ii) for the purpose of facilitating direct marketing by other organisations;

the individual may:

(iii) if paragraph (i) applies—request not to receive direct marketing communications from the Club; and

(iv) if paragraph (ii) applies—request the Club not to use or disclose the information for the purpose referred to in that paragraph; and

(v) request the Club to provide its source of the information.

(g) If an individual makes a request under subclause (f), the Club must not charge the individual for the making of, or to give effect to, the request and:

(i) if the request is of a kind referred to in paragraph (f)(iii) or (iv)—the Club must give effect to the request within a reasonable period after the request is made; and

(ii) if the request is of a kind referred to in paragraph (f)(v)—the Club must, within a reasonable period after the request is made, notify the individual of its source unless it is
impracticable or unreasonable to do so.

Interaction with other legislation
(h) This principle does not apply to the extent that any of the following apply:

(i) the Do Not Call Register Act 2006;

(ii) the Spam Act 2003;

(iii) any other Act of the Commonwealth, or a Norfolk Island enactment, prescribed by the regulations.

APP 8 – Cross-border disclosure of personal information

The Club will not disclose personal information to an overseas recipient.  The Club’s requires that any third party providers do not store personal information of Club members or guests overseas.

APP 9 – Adoption, use or disclosure of government related identifiers

The Club will not adopt a government related identifier of an individual as its own identifier under any circumstances.

APP 10 – Quality of personal information

(a) The Club will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that we collect is accurate, up to date and complete.

(b) The Club will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that we use or disclose is, having regard to the purpose of the use or
disclosure, accurate, up to date, complete and relevant.

APP 11 – Security of personal information

(a) If the Club holds personal information, we will take such steps as are reasonable in the circumstances to protect the information:

(i) from misuse, interference and loss; and

(ii) from unauthorised access, modification or disclosure.

(b) If:

(i) the Club holds personal information about an individual; and

(ii) we no longer need the information for any purpose for which the information may be used or disclosed by the entity; and

(iii) the information is not contained in a Commonwealth record; and

(iv) the entity is not required by or under an Australian law, or a court/tribunal order, to retain the information;

we will take such steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.

APP 12 – Access to personal information

Upon request by an individual, we are required to give that individual access to his or her personal information, except to the extent that:

(a) giving access would have an unreasonable impact on the privacy of other individuals; or

(b) the request for access is frivolous or vexatious; or

(c) the information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings; or

(d) giving access would reveal the intentions of the entity in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

(e) giving access would be unlawful; or

(f) denying access is required or authorised by or under an Australian law or a court/ tribunal order; or

(g) both of the following apply:

(h) the entity has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to the entity’s functions or activities has been, is being or may be engaged in;

(i) giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or

(jk giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(j) giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.

Dealing with requests for access
2. The Club must:

(a) respond to the request for access to the personal information within a reasonable period after the request is made; and

(b) give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.

APP 13 – Correction of personal information

(1) If:

(a) the Club holds personal information about an individual; and

(b) either:

(i) the Club is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading; or

(ii) the individual requests the Club to correct the information;
the Club must take such steps (if any) as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.
Notification of correction to third parties

(2) If:

(a) the Club corrects personal information about an individual that the Club previously disclosed to another APP entity; and

(b) the individual requests the entity to notify the other APP entity of the correction;
the Club must take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.

Refusal to correct information
(3) If the Club refuses to correct the personal information as requested by the individual, the Club must give the individual a written notice that sets out:

(a) the reasons for the refusal except to the extent that it would be unreasonable to do so; and

(b) the mechanisms available to complain about the refusal; and

(c) any other matter prescribed by the regulations.

Request to associate a statement
(4) If:

(a) the Club refuses to correct the personal information as requested by the individual; and

(b) the individual requests the Club to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading;
the Club must take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.

Dealing with requests
(5) If a request is made under subclause (1) or (4), the Club:

(a) must respond to the request within a reasonable period after the request is made; and

(b) must not charge the individual for the making of the request, for correcting the personal information or for associating the statement with the personal information (as the case may be).

Contact us
For privacy complaints, please contact the Chief Executive Officer:
Mr Glenn Cushion
Chief Executive Officer
Ingleburn RSL Club
70 Chester Road
INGLEBURN NSW 2565
e glenn@ingleburnrsl.com.au
p 02 9765 7700