Issue Date: [12 May 2023]
This policy sets out how Commercial Club (Albury) Ltd (ACN 000 941 908) and its related entities (“Club”, “we”, “us” or “our”) collect, use, disclose and hold “personal information”.
“Personal information” means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Please note that the Club and its related entities operate several clubs and businesses under a number of different trading names and brands, including the Commercial Club Albury, Albury Commercial Golf Club, Albury Commercial Golf Motel and the Albury Brewhouse. Those operations are also covered by this policy, as explained in the FAQ section below.
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.
We may collect and hold a wide range of personal information, and in some cases sensitive information, including:
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.
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:
In general, if you contact us, we may keep a record of that correspondence.
We may also use the information we collect about you, including your use of our products and services, to keep you informed about our products and services where they are relevant to your continued use of those products and services or your preferences.
When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure that you are aware) of the following:
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.
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 (NSW) (Registered Clubs Act), Corporations Act 2001 (Cth) (Corporations Act), Gaming Machines Act 2001 (NSW), Liquor Act 2007 (NSW), Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Work Health and Safety Act 2011 (NSW).
For example, when a person applies for membership of the Club, we must collect details including their name and address. We must display a person’s name on the Club’s notice board before our Board 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 licenced premises.
If you elect to use our electronic ID scanners, we will collect information from your ID at the time you enter the Club. More information about our electronic ID scanners appears in our Frequently Asked Questions section below.
We collect, hold, use and disclose your personal information to operate the Club and its various businesses, 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:
If you don’t give the Club your personal information, you may not be able to become a member of the Club, use the Club’s services or facilities, or access the Club’s premises and other venues.
If you provide us with some but not all of the information sought, then, depending on the information withheld, we may be able to provide you with certain goods and services but only to a limited extent. For example, if you disable cookies on our websites, certain features and functions on our websites may not work.
You have the option of not identifying yourself, or of using a pseudonym, when dealing with us. However, this will be limited to enquiries of a very general nature and only over the telephone or by email.
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.
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 or licensed premises from which you also want to be excluded, we may disclose your personal information to the exclusion program operator (if any) and/or to the clubs and licensed premises that you have nominated directly to the extent necessary to assist those clubs and licensed premises to comply with your self-exclusion.
To the extent that the Club collects health information from you, the Club will treat that information as confidential and only ever handle your health information in accordance with the Club’s policies, the Privacy Act and the Health Records and Information Privacy Act 2002 (NSW).
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 opting out of direct marketing material on your membership application form, by updating your preferences on your account, by selecting unsubscribe on any marketing emails from the Club to you or by otherwise contacting our Privacy Officer.
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 Club members.
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 to send direct marketing information (usually via email or SMS), carry out mail services, and provide IT storage and other services.
A third party 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 Communities and Justice and the Australian Taxation Office.
The Club will never disclose your health information to a third party without your express consent, except in the event of a medical emergency or as otherwise permitted by law.
The Club operates other clubs and businesses which trade under different names and brands, including but not limited to the Albury Commercial Golf Club, the Albury Commercial Golf Motel, Commercial Club Gym & Fitness Centre and the Albury Brewhouse.
The Club also operates a number of sub-clubs that form part of the Club.
For the purposes of the Privacy Act, a collection, use, disclosure or storage of your personal information by one of the Club’s businesses which trades under a different business name or by one of the Club’s sub-clubs is the Club’s collection, use, disclosure or storage of your personal information.
If a business of the Club which trades under a different business name or a sub-club (being part of the Club) collects, uses, discloses or stores your personal information, it will comply with this policy when doing so.
The Club may have one or more related entities, also known as “related bodies corporate”.
These related entities are separate legal entities to the Club, but are related to the Club in some way (e.g. the Club owns the related entity, or the related entity owns the Club).
The Privacy Act permits related entities to share personal information in certain circumstances.
All venues operated by the Club are subject to video and audio surveillance for security reasons, including to monitor the safety of members, guests and employees and to protect the Club’s assets.
The footage and audio recordings may be used in disciplinary proceedings and/or to investigate incidents and may be disclosed to our legal representatives, our insurers and/or law enforcements agencies.
The electronic scanners used by the Club may scan a full copy of your ID.
Where this applies, the Club may collect all of the information recorded on your ID (which may include your ID number and expiry date).
The Club permanently deletes the full copy of your ID that it collects after 7 days, and will only hold the information it has recorded from your ID (excluding your ID number and expiry date) thereafter.
Under the Registered Clubs Act, we are required to maintain a register of the name, address and signature of temporary members and guests over the age of 18 who enter the Club’s premises. This information must be retained by us for at least three years.
We are also required to take steps to verify the identity of any members and guests who use our gaming machines under the Anti-Money Laundering and Counter-Terrorism Financing Act and its associated rules and regulations.
ID scanners are a secure way for the Club to collect information about persons entering the Club’s premises.
Personal information that is held by us is stored electronically and/or in hardcopy.
We take reasonable steps to ensure that your personal information is safe and secure from unauthorised access, use or disclosure.
Information that we store electronically is held in secure, encrypted and password protected databases.
Video and audio surveillance is stored on our digital recorders, which are maintained in a restricted access area and password protected.
The Club does not store your financial information unless you have submitted a hard copy direct debit form with us. Paper forms are kept secure on the Club’s premises.
Your personal information is securely destroyed when it is no longer needed or when it is out of date.
The Club has various security measures in place to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
In the event that the Club’s security measures are compromised and your information is the subject of a data breach, the Club will comply with its obligations for responding to data breaches outlined in the Privacy Act.
Upon becoming aware of a data breach, the Club will take urgent steps to contain the breach, mitigate any risk of harm and determine who may have been affected by the breach.
The Club will then assess the breach, including any potential for harm, and determine whether the breach is likely to result in serious harm to any person whose data was involved.
If the Club has reasonable grounds to believe that the breach is likely to result in serious harm to you, the Club will notify you of the breach as soon as possible. The Club will also notify the Office of the Australian Information Commissioner of the breach.
Following a breach, the Club will conduct a review of its security measures and implement any additional measures it considers necessary to enhance the security of your information.
If you are a member of the Club, you have the option of downloading our app onto your mobile phone or other compatible device to use in the Club as part of our members’ rewards scheme.
Our app is linked to your membership account and allows you to view your points balance, receive personalised offers and rewards and to make bookings at the Club.
The websites and social media pages operated by or in connection with us may collect personal information for the purposes outlined in this policy.
Any information collected by us as a result of your use of those websites and pages will be handled in accordance with this policy.
Any hyperlinks are provided for reference only. We do not have control over websites and pages operated by third parties and are not responsible for the content available on such websites or pages or the privacy practices of those third parties.
By entering, visiting, or dealing with the Club, you consent to the terms of this policy.
The Club will also seek your express consent for the collection, use or disclosure of your personal information for purposes set out in this policy wherever reasonably practicable.
From time to time, your additional consent will be sought for the collection, use or disclosure of your personal information for purposes other than as set out in this policy.
If you do not agree to this policy or do not wish to receive direct marketing information from or in connection with the Club, please contact our Privacy Officer.
You have a general right to access any personal information which we hold about you. You can request access to the personal information we hold about you by contacting our Privacy Officer.
We will not charge you for making the request. However, we may need to charge you for our time to answer your request. We will advise you in advance if there are to be any charges associated with complying with your request.
We will respond to your request within a reasonable timeframe (usually not more than 30 days).
When you request access, we may need further information from you to verify your identity.
There are a number of reasons why we may be unable to give you access to your personal information held by the Club. If we are not able to provide access, we will provide you with written reasons.
If you believe any of the personal information that we hold about you is incorrect or out-of-date, you can ask us to correct it and we will take reasonable steps to ensure that it is accurate, up-to-date, relevant and not misleading. To assist us to update your information, we may need you to provide us with evidence of your new details.
If we refuse to correct your personal information, we will give you written reasons.
If you believe we have breached the Privacy Act or any of the Australian Privacy Principles, or if you have any issues about the Club’s collection, use, disclosure or storage of your personal information, please contact our Privacy Officer.
When contacting our Privacy Officer, please give us enough details to be able to identify you, understand your issue or complaint and respond appropriately.
We will respond to you within a reasonable timeframe (usually not more than 30 days).
If you are unhappy with how we handle your issue or complaint, you are entitled to make a privacy complaint to the Office of the Australian Information Commissioner.
Please visit the Office of the Australian Information Commissioner’s website for contact details: https://www.oaic.gov.au/.