PRIVACY POLICY

Who does this policy apply to and what does it cover?

This policy sets out how Engadine Bowling and Recreation Club Limited ABN 96 744 536 639 and its related entities (“Club”, “we”, “us” or “our”) collect, use, disclose and hold “personal information”.

What is our privacy commitment to you?

We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) by protecting the privacy and confidentiality of your personal information. When we collect, use, disclose, store, access or correct your personal information, our actions will comply with the Privacy Act and the Australian Privacy Principles. Where appropriate, we will handle your personal information relying on the employee records exemption and the related bodies’ corporate exemption in the Privacy Act.

What kinds of personal information does the Club collect and hold?

We collect and hold a wide range of personal information, and in some cases sensitive information, including:

• personal details, including your full name, residential address, email address, other contact details, date of birth and occupation;
• your signature;
• information related to your entry to the Club’s premises;
• a photo of you for your membership card;
• an image of your driver’s licence or other identification if you choose to scan your ID when entering the Club (you have the option not to have your ID scanned);
• details of your membership of the Club, including any positions held by you at the Club or any complaints made by you or against you in connection with the Club;
• information about what goods or services you buy or receive from the Club;
• details of your activities at or in connection with the Club, including your participation in social or sporting activities;
• the name and contact details of your next of kin;
• information connected to your use of our gaming machines (including your player activity statements and prizes you receive);
• information about you related to a liquor or gaming self-exclusion or banning order about you from yourself, other clubs, ClubsNSW, a Liquor Accord or Liquor & Gaming NSW;
• things you say or do (or things said about you) in connection with an incident or disciplinary proceedings at or in connection with the Club;
• bank account details and credit card details;
• information related to your use of our Wi-Fi from any of your personal devices;
• surveillance images or videos of you at the Club’s premises; and
• if you apply for a job with us, the information in your resume and other information that you or your referees provide to us and notes of our interactions with you and/or others in relation to your prospective employment.

From time to time, we may collect additional information about you related to surveys, promotions and particular services or activities at or in connection with the Club. Wherever practicable, we will advise you of the information being collected about you and provide you with an opportunity to refuse the collection of that information.

How do we collect your personal information?

Your personal information is collected as a result of your visits to, or dealings with, the Club. Information is collected by recording information that you provide to us, by electronic means, and by the observations of our staff. We collect personal information when you:

• enter, visit or deal with the Club;
• apply for, or renew, your membership of the Club or request to use our services;
• use your membership card or other issued cards at or in connection with the Club;
• purchase goods or services from us;
• use our gaming machines or request to be excluded from using our gaming machines;
• access or use our Wi-Fi from any of your personal devices;
• attend a function or show at a venue we operate;
• plan an event to be held with us;
• participate in activities offered by the Club, including competitions and promotions;
• visit one of the websites or social media pages operated by the Club;
• are suspended, banned or removed from any part of the Club’s premises;
• receive or request sponsorship through programs such as ClubGRANTS;
• are involved in, witness or are connected to an incident or disciplinary proceedings at or in connection with the Club; and/or
• apply for, or renew, your membership of one or more of the Club’s sub-clubs or participate in the activities of those sub-clubs.

In general, if you contact us, we may keep a record of that correspondence. We only collect personal information about you from you, unless it is unreasonable or impractical to do so. For example, it may be unreasonable or impractical to collect information from you when the information is provided by other members, our staff or the Police. We may also collect information about you from other clubs and industry bodies if you have excluded yourself from the Club’s premises (including in relation to ClubNSW’s “ClubSAFE” self-exclusion system).

Will I be notified that my personal information is being collected?

When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure that you are aware) of the following:

• our identity and contact details;
• the facts and circumstances of the collection;
• details of any laws that require or authorise the collection;
• the purposes of collection;
• the consequences if we do not collect the information;
• that this policy contains information about how you can access or correct your information or make a complaint about the Club; and
• whether we are likely to disclose the information overseas (and, if so, to which countries).

One way we notify you of the above is by making you aware of this policy.

If you give us personal information about others, we expect that you will tell them about this policy.

Is the Club required by law to collect personal information?

As a registered club, we have a legal responsibility to collect certain information about our members and guests pursuant to legislation, including the Registered Clubs Act 1976 (Registered Clubs Act), Corporations Act 2001 (Corporations Act), Gaming Machines Act 2001, Liquor Act 2007, Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and Work Health and Safety Act 2011.

For example, when a person applies for membership of the Club, we must collect details including their name and address. We must display this information on the Club’s notice board before our Board of Directors is able to consider the application for membership. We also may need to provide this information to any member of the general public who makes a request under certain legislation, including the Corporations Act. Temporary members, guests of members and other visitors to the Club may be required to produce a recognised form of identification (such as a driver’s licence or passport) to gain entry into the Club’s licenced premises.

If you elect to use our electronic ID scanner, we will collect information from your ID at the time you enter the Club. More information about our electronic ID scanners appears below.

For what purposes does the Club collect, hold, use and disclose your personal information?

We collect, hold, use and disclose your personal information to operate the Club, carry out certain activities, provide products and services to you, other members and guests and other members of the public, and comply with our legal obligations. The purpose of collecting your personal information is to undertake one or more of the following activities or functions:

• consider applications and renewals of membership;
• identify who comes to the Club and verify their details, including age and address;
• identify individuals who have been suspended, banned or self-excluded from the Club’s premises;
• create registers and display information as required by the Registered Clubs Act;
• provide a safe environment for you, other members and guests and our staff;
• provide services to you, other members and guests;
• carry out accounting and finance requirements and legal and administrative reporting requirements;
• provide Wi-Fi at the Club;
• provide an events management service;
• operate functions at our venues;
• carry out competitions and promotions;
• perform gaming operations;
• publish and distribute newsletters;
• carry out marketing (including direct marketing);
• offer and manage sponsorships including by supporting community sports and social events;
• provide ticketing services;
• offer dining options and other entertainment, including shows;
• operate the Club’s sub-clubs, including publishing contact details of committee members;
• conduct elections of the Club’s Board of Directors;
• investigate an incident or conduct disciplinary proceedings at or in connection with the Club;
• resolve a complaint;
• assess an applicant’s suitability for employment; and
• improve our services and increase membership of the Club.

What happens if you don’t provide your personal information?

In most circumstances, you will be unable to deal with the Club anonymously or with a pseudonym because of our obligations under the Registered Clubs Act and the Privacy Act.

How do we use your personal information?

We use your personal information primarily to allow us to carry out the activities and functions listed above. We also use your personal information for secondary purposes related to those activities and functions, or when permitted under the Privacy Act.

If you have self-excluded yourself from the Club’s premises and nominated other clubs from which you also want to be excluded, we may disclose your personal information to those clubs to the extent necessary to assist those clubs to comply with your self-exclusion. The Club may also use the personal information we collect from you for direct marketing of products and services to you, including from third parties. Such products and services may include the provision of newsletters, competitions, announcements, campaigns or information about shows and entertainment at the Club or services offered by the Club.

You can refuse any direct marketing by contacting our Privacy Officer or unsubscribing from any emails using the functionality provided.

Does the Club disclose my personal information to others?

There may be times when we may need to disclose your personal information to third parties that we engage to provide services to or in connection with the Club, including our related entities, our insurers, ClubsNSW, our sponsors, our legal or financial advisers and other members of the Club. Your personal information will only be disclosed to third parties for a purpose permitted by the Privacy Act and/or this policy and, where required, after obtaining your consent.

We may need to disclose your personal information to third parties for the purposes of allowing us to carry out the activities and functions mentioned in this policy.

For example, from time to time, the Club engages external companies inside and outside of Australia to send direct marketing information (usually via email or SMS), carry out mail services, and provide IT storage and other services. A third party service provider will only receive your personal information from the Club where that information is necessary for that third party to provide services to or in connection with the Club and the Club will always require that the third party comply with the Privacy Act when dealing with your personal information.

We will also disclose your personal information to third parties if we are required or authorised to do so by law, including to law enforcement agencies, the Office of the Australian Information Commissioner, the Australian Electoral Commission, the Department of Family and Community Services and the Australian Taxation Office.

Frequently Asked Questions