Canterbury-Hurlstone Park RSL Club Ltd Privacy Policy

Canterbury-Hurlstone Park RSL Club Ltd ABN 56 000 967 199 (the Club, 'we' or 'us') aims to protect the privacy of the personal information that we collect and hold whilst carrying out our activities. Personal information is any information or opinion that is capable of identifying a person.

This statement applies to personal information collected from and about members and guests, other customers, staff, suppliers and any other person whose personal information the Club may collect from time to time. The Club is bound by the Australian Privacy Principles (Principles) established under the Privacy Act 1988 (Cth) (Act). This statement has been developed as part of the Club's efforts to comply with its obligations under that legislation.

This statement explains:

• what types of personal information we might collect;

• how we aim to use personal information;

• when we will disclose personal information to others;

• how we manage and secure personal information;

• how you can access and seek to correct personal information that we hold about you; and

• how you may make a complaint if you think that we have breached the Principles.

This statement does not form part of any contract.

From time to time, we may review and update this statement – for example, to reflect changes to the law or our company.

The Principles do not apply to employee records. As a result, this statement 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.

The separate privacy policy for Anytime Fitness can be found on the website: http://www.anytimefitness.com.au/gyms/AU-1271/hurlstone-park-nsw-21931. What types of personal information do we collect?

The Club aims only to collect 'personal information' (as defined under the Act) that is reasonably necessary for our activities. The types of personal information that we collect will depend on the nature of the interaction between you and the Club, and where and how we collect the information.

Personal information collected by the Club includes:

• information about members, guests, people attending club functions, and other customers including names, addresses, email addresses, telephone numbers, other contact details, information about their use of (and preferences in relation to) the Club's products and services, and information pertaining to membership records;

• information about applicants to, and individuals enrolled in, the Club's registered training organisation 'CHP School of Hospitality', including names, addresses, email addresses, telephone numbers, other contact details, information about their previous qualifications and education, and their enrolment in our programs; • information about job applicants, staff, and volunteers;

• information about other people who come into contact with the Club such as contractors and suppliers;

• transaction information – we collect transaction details related to your use of our services, including the type of services requested or utilised, order details, date and time services were provided, amounts charged and benefits received and your payment methods; • your bank, credit card or debit account details when you make a purchase;

• if you visit our websites or use our mobile device applications (Apps), your websites and App usage information such as your IP address, dates and times of access, App features, pages viewed or system activity;

• geolocation information - depending on your App settings or device permissions we may collect your precise or approximate location information as determined through data such as GPS, IP address and Wi-Fi, including when the App is running in the foreground (App open and onscreen) or background (App open but not onscreen) of your device;

• device information - information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information;

• App specific information – depending on the App, we may collect specific information for the use and operation and use of that App; and

• how often you use any one of our Apps, the events that occur within our Apps, aggregated usage, performance data and where the App was downloaded from. 

If some information that the Club requests is not provided, we may not be able to provide you with our goods and services, or engage you to work at the Club if you are a job applicant.

Some of the information we collect is 'sensitive information' (as defined under the Act), including information about your racial or ethnic origin, religious beliefs or affiliation, or health. The Act requires us only to collect sensitive information:

• from you where you consent and it is reasonably necessary for our activities;

• if the collection is required by law or a court or tribunal order; or

• if it relates to our Club activities and you are a Club member or have regular contact with us in connection with our activities. 

2. How do we collect your personal information?

We usually collect personal information directly from you, for example when you correspond with us by email or in writing, deal with us over the telephone or in person, use our facilities (such as food and beverage or sporting facilities), use our services (such as the member loyalty program), make an enquiry through our websites or use any of our Apps. The Club also collects CCTV footage in some areas of its premises for security purposes.

Sometimes, someone else may provide us with personal information about you, with or without your direct involvement. For example, we might collect personal information from:

• a related body corporate of the Club;

• a local liquor accord, a regulatory authority, or another industry organisation such as ClubsNSW;

• another organisation of which you are a member, such as a sporting club which uses our facilities;

• in relation to our registered training organisation, another educational institution that you have attended; or

• a representative of yours. 

3. How do we use your personal information?

 Information of customers and suppliers The purposes for which the Club uses a person's personal information include:

• to verify your identity;

• creating and updating your account;

• processing or facilitating payments for services;

• to provide them with our services and/or products, for our activities (such as registered club community, social, sporting and recreational activities), and to answer enquiries about these functions;

• to communicate with them;  

• to provide information about other activities, products or services the Club considers would interest them (which they can tell the Club not to do at any time);

• improving our websites or Apps;

• to help the Club to properly operate its business, for example to improve its products or services, for security purposes, to train our staff and contractors, or to undertake marketing activities;

• to facilitate your participation in our member loyalty program; and

• to comply with our legal obligations (for example, liquor & gaming laws and Anti-Money Laundering & Counter Terrorism laws). If we collect your personal information for any other purpose, we will generally let you know that purpose at the time we collect the information. 

Information of job applicants, staff members and contractors

  The Club collects personal information of job applicants, staff and contractors for the primary purpose of assessing and (if successful) engaging or employing the person, as the case may be.

The purposes for which the Club uses such personal information include:

• managing the individual's employment or engagement;

• insurance purposes;

• ensuring that it holds relevant contact information; and

• satisfying its legal obligations. 

Information of volunteers

The Club also collects personal information about volunteers, to enable them to work with us.

4. When will we disclose your personal information to others?

The Club aims to confine its disclosure of personal information to the primary purpose for which it has been collected, or for a related purpose. This means the Club will usually only disclose personal information in connection with our business, our administrative functions, and our registered club community, social, recreational and sporting activities. This includes when disclosure is necessary to: provide you with a product or service that you have requested; help us with the running of the Club; or for compliance with our legal obligations (for example, disclosing information of prospective members on the Club's noticeboard).

Sometimes the Club may also disclose your personal information outside the Club for the purpose for which the information was collected, or for a related purpose – for example when disclosure is necessary to: provide you with a product, service or activity you have requested; help us with the running of the Club; or for security reasons.

We may provide your personal information to:

• outsourced service providers who perform functions on our behalf or provide services to us, such as providing security services, conducting market research, providing email and mail handling services, Apps related services and support, and providing professional advice to the Club;

• authorised representatives of the Club who sell products or provide services on our behalf;

• our related bodies corporate;

• anyone authorised by you to receive your personal information (your consent may be express or implied and can be withdrawn at any time);

• an actual or prospective amalgamation partner in the event we engage in an amalgamation process with another registered club, or, an actual or prospective purchaser in the event we sell any part of our business which is not a registered club operation; and

• anyone to whom we are required or authorised by law to disclose personal information. We generally require third parties only to use your personal information for the specific purpose for which it was given to us and to protect the privacy of your personal information. We will only disclose your personal information to third parties on the basis that they agree with us to keep your information confidential (except where we are authorised or required by law to disclose the information). Otherwise, the Club would only share personal information, including sensitive information, with a third party if the Club has a belief that its use and/or disclosure is necessary:

• to lessen or prevent threats to health, life or safety of any individual;

• to investigate unlawful activity or serious misconduct within the Club;

• to assist enforcement bodies, such as the police, with their activities;

• to assist in locating a missing person;

• to establish, exercise or defend a legal or equitable claim; or

• for the purpose of confidential alternative dispute resolution.

Consent

You consent to us disclosing your personal information to the third parties listed above, and similar organisations who may in turn provide your information to other third parties (for example, for marketing purposes). You can withdraw your consent at any time by informing us in writing that you withdraw that consent (except where we are authorised or required by law to disclose the information).

If you do not permit the disclosure of some personal information as the Club requests, then the Club may not be able to meet its legal obligations and may not be able to do business with you or engage you to work at the Club. If this is the case, we will let you know.

Sending information overseas

The Club is not likely to send personal information outside Australia. 

5. The Club's websites and use of our Apps

When you visit the public pages of our websites or one of our Apps, we may record your websites visit and App use and log the following information:

• your IP ('Internet Protocol') address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);

• search terms used;

• the operating system and Internet browser software you are currently using; and

• the data that you download, and the time that you download it. This information may be used to identify you and is only used for statistical purposes to help us identify what parts of our websites our users visit the most, which assists us to determine how to improve our services. We do not collect personal information from visitors on our websites other than what is supplied to us on a voluntary basis. We use 'cookies' on our websites, which are a mechanism to keep track of certain information and make the browsing experience more responsive. However, this information does not identify the user, so our obligations in relation to personal information do not apply to the information that we collect via cookies.

If you contact us through our websites or email us, the Club will only use your personal information to respond to your request or answer your queries. We will not add your email address to our mailing list without your consent. 

Other websites or apps

To the extent that our websites or Apps contain links to sites or apps operated by third parties, including other organisations, those linked websites or linked apps are not controlled by us and we are not responsible for the privacy practices of the site operators. Before you disclose your personal information to any linked websites or Apps, we advise you to examine their privacy policies and terms and conditions of use

6. How we manage and secure personal information

We have appointed a Privacy Officer to be responsible for the management of personal information that we collect. The Club's staff are required to respect the confidentiality of all personal information and the privacy of individuals, and we have directed our staff that personal information must be dealt with in accordance with this statement.

The Club has security systems in place which are intended to protect your personal information from misuse, loss, unauthorised access, modification or disclosure by the use of various methods including locked storage of paper records and passworded access rights to computerised records (depending on the nature of the information that we are holding).

If the Club receives personal information about you which it did not request and which it does not reasonably require, the Club may destroy or de-identify this information where appropriate. If you reasonably believe that there has been an unauthorised use or disclosure of your personal information, please contact our Privacy Officer whose contact details are at the end of this statement.

7. Updating personal information that we hold about you

The Club aims to keep all personal information that we hold accurate, complete and up-to-date. We encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us - our contact details are at the end of this statement. 

8. How you can access personal information that we hold about you

Under the Act, an individual generally has the right to obtain access to any personal information which the Club holds about him/her and to advise the Club of any perceived inaccuracy in that information. There are some exceptions, and in some circumstances the Act entitles the Club to deny access. For example if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which we are involved. If we do refuse access, we will generally let you know the reasons for our refusal.

If you are a Club member who participates in our Insignia membership program, we will give you a player activity statement regarding your player card on request.

If you make a request for access to your personal information, we may ask you to verify your identity and specify what information you require. The Club may charge a fee to cover our costs of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, the Club will generally advise the likely cost in advance. To make a request to access any information that the Club holds about you, please contact us – our contact details are at the end of this statement. 

9. Data breach

The Club has in place a data breach policy as required by the Privacy Act. Data breaches will be investigated and reported in accordance with that policy and the requirements of the Privacy Act. Please contact us if you have reason to believe that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk-mitigation and notification as required.

10. Questions or complaints

If you have a question about this statement, or a complaint about the Club's compliance with the Principles, please contact the Privacy Officer in writing - our contact details are at the end of this statement. The Privacy Officer will investigate your complaint and respond to you within a reasonable period, depending on the nature of your complaint. If you are not happy with the Privacy Officer's response, you may contact the CEO Mr Dean Thomas on (02) 9559 0000 or the Office of the Australian Information Commissioner.

11. Contact us

For CHP School of Hospitality:

Phone: (02) 9559 0025

Email: rto@chprsl.com.au 

For all other enquiries please contact our Privacy Officer:

Damian Hughes

Phone: (02) 9559 0000

Email: chprsl@chprsl.com.au