Dee Why RSL Club Ltd ACN 002 318 836 (DYRSL, Club, we or us) is a registered club under the Registered Clubs Act 1976 (NSW).
This policy applies to all Club members, members’ guests, and other customers of the Club (you), and to all the activities of the Club. By using our website at www.deewhyrsl.com.au (Website) and/or providing your personal information to us, you consent to us handling your personal information in accordance with this policy.
DYRSL is strongly committed to protecting your privacy. Our policy follows the principles set out by the Office of the Australian Information Commissioner. Our objective is to provide you with gaming, hospitality and entertainment services that meet your satisfaction. In the process of you interacting with us on our Website, we do collect some information on all our customers.
DYRSL will be open and transparent about how and why we collect information and how we might use the information. In some cases, if you do not want us to collect or use your information in a particular way, then you will be given an opportunity to say so.
The purpose of this policy is to ensure that the Club complies with the Privacy Act 1988 (Cth) (Privacy Act) (including any amendments to the Privacy Act) and the Australian Privacy Principles (APP), which govern the way that APP entities must manage personal information (as defined in the Privacy Act), and to protect your personal information, which we take very seriously. Specifically, we intend to explain:
– how this policy will apply to our members, guests and visitors;
– what kind of information DYRSL may collect about you, how we collect it and how we might use the information;
– how we may disclose that information;
– how you can access the information that we hold about you;
– when we might use your information to contact you;
– how we protect your personal information;
– how and why we collect additional information to improve our services.
We encourage you to check our Website regularly for any updates to this policy. We may update this policy whenever we consider appropriate, for example, to reflect changes to the law or to our business.
Types of Information Collected
As a registered club, we may collect and hold personal information about you, that is, information that can identify you such as your name, street address, mailing address, email address, phone number, occupation, date of birth, proof of age, photograph, faceprint, other contact details and the extent of your use of (and preferences in relation to) products and services offered by, or available at or from the Club, and other information relevant to providing you with the services you are seeking.
In addition to this information we request for optional additional information that might help us constantly improve our service offerings, in the interest of our members and guests.
Purpose of Collection
In general, we collect personal information so that we can perform our business activities and functions and to provide best possible quality of customer service.
We will collect, hold and use your personal information for one or more of the following purposes:
– To identify you and process an application you have made for membership or renewal of membership, or to admit you to the Club’s premises;
– To identify individuals who have been suspended, banned or self-excluded from the Club’s premises;
– To establish and manage your membership of the Club, including providing you with newsletters, magazine and annual reports;
– To contact you to advertise and market events, promotions, competitions, activities and offers provided or procured by the Club, or by a company in which the Club has an ownership interest (if any), (including by direct mail, telephone, email, SMS and MMS), and to register you for such events, promotions, competitions, activities and offers;
– To provide products and services to you, and to administer any benefits to which you may become entitled;
– To provide you with information about other products and services that may be of interest to you;
– To provide you with promotional information about us;
– To facilitate our internal business operations, including without limitation the fulfilment of any legal enquiries, addressing security concerns and training our employees and contractors;
– To analyse usage of products and services offered by the Club and customer needs;
– To develop new and/or improved products and services;
– To monitor gaming machine operations to ensure Responsible Conduct of Gambling;
– To comply with statutory requirements under legislation relating to registered clubs, liquor, gaming, anti-money laundering, counter-terrorism and other legislation which may apply to the Club; or
– To analyse usage and performance of our Website.
How we collect information DYRSL may collect personal information from you in a number of ways. These include, but are not limited to you:
– Verifying your identity to gain entry into the Club’s premises (for example, by scanning your membership or other ID card or by inserting your details into our system manually);
– Requesting to receive products or services;
– Purchasing food, beverage or other products;
– Using a credit card or EFTPOS card for purchases;
– Using the Website or our on-premises Wi-Fi;
– Signing up to the Club’s newsletter via the Website;
– Entering a competition or voting forum;
– Using, completing or lodging our standard forms including for membership application or competition entry;
– Updating your membership details;
– Participating in the Club’s membership loyalty program;
– Using your membership card at sign in terminals, point-of-sale terminals or gaming machines;
– Using the Club’s services;
– Purchasing gift cards;
– Commenting in or contributing to our social media sites;
– Dealing with us (in writing, by telephone, by email or in person); and
– Completing a survey or questionnaire issued in relation to the Club.
DYRSL publishes various newsletters and marketing material. You may need to agree that you would like to receive one or all of the material that DYRSL makes available to its members and guests.
By entering in any promotions and competitions offered by the Club, you confirm that you agree with the terms and conditions of that promotion or competition (or if required, may need to further confirm that you agree with such terms and conditions). All terms and conditions are available upon request from the Club’s reception.
Information received from other parties
Sometimes, a third party may provide us with your personal information, with or without your direct involvement. For example, we might collect personal information from:
– another organisation of which you are a member, such as a local sporting club using our facilities, or community organisation;
– a related body corporate of the Club;
– a regulatory authority, a local liquor accord or another club industry organisation; or
– another member of the Club, such as through our sub-clubs or when another member provides a reference to nominate you for membership; or
– your representative(s).
Information about third parties
Job applicants, staff, contractors, suppliers and volunteers
We also collect personal information about job applicants, Club staff, volunteers who work with us, and details of other people who come into contact with the Club such as contractors and suppliers for the primary purpose of assessing and engaging or employing the person. The Club also holds and uses such personal information for managing the employment or engagement of such persons to meet its legal obligations.
USE AND DISCLOSURE
We only use and disclose personal information about you for the purpose for which it was collected, or for a related purpose as permitted by the Privacy Act or for uses for which you have given consent (which may be express or implied). We may disclose personal information about you:
– To service providers who assist us in operating our business, perform functions on our behalf or provide services to us;
– To other sporting associations or clubs with which we have an alliance relationship;
– To other organisations in which the Club has an ownership interest, for the purpose of them marketing their products and services to you;
– To an actual or prospective purchaser of the assets and/or operation of our business, or an actual or prospective amalgamation partner (if we engage in an amalgamation process with another registered club);
– To market research agencies for conducting research;
– To anyone to whom we are required or authorised by law to do so;
– To relevant authorities when the Club believes that unlawful or undesirable activity is being or has been conducted; or
– To anyone authorised by you to receive your personal information (your consent may be express or implied, and can be withdrawn at any time).
Other than the above, we will generally disclose your personal information (including sensitive 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). The Club will otherwise only disclose personal information to a third party where the Club has a belief that its use and/or disclosure is necessary:
– to lessen or prevent threats to an individual’s life, health or safety;
– to investigate any unlawful or undesirable activity or serious misconduct which is being or has been conducted;
– to assist enforcement bodies 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.
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. You can withdraw your consent at any time by informing us in writing (except where we are authorised or required by law to disclose the information).
In the interest of safety for our members, guests and visitors, DYRSL has installed a network of CCTV cameras. The cameras are not intrusive and are carefully managed and supervised. Relevant footage is provided to the Police or regulatory bodies such as Liquor & Gaming NSW or the Independent Liquor & Gaming Authority upon specific requests and is subject to a procedure where the request is identified.
Facial recognition technology
DYRSL has introduced facial recognition technology to consolidate the Club’s security systems and to assist the Club in identifying individuals who are suspended, banned, self-excluded or a person of concern from our premises.
There are designated security cameras throughout the DYRSL premises which use facial recognition technology to collect and analyse faceprints of selected individuals. A faceprint is a digitally recorded representation of an individual’s face based on the location, size and shape of an individual’s facial features.
When you are at our premises, the Club’s designated security cameras will capture a photo of your face and then generate a faceprint of your face based on that photo. Your faceprint will then be compared against a database maintained by DYRSL that contains the faceprints of individuals who have been suspended, banned or self-excluded from our premises. Faceprints of any such suspended, banned or self-excluded individual from the Club’s premises are initially collected through photographic images the Club holds of that individual (for example, from that individual’s membership card). If your faceprint matches the faceprint of any individual in this database, our staff will be alerted and you will be removed from our premises. Your faceprint will be deleted after 30 days if it does not match the faceprint of any person whose faceprint is contained in the database.
DYRSL stores the faceprints of those persons who have been suspended, banned, self-excluded or are a person of concern from our premises for such time until the suspension, ban or self-exclusion ceases, or are no longer a person of concern.
Using your personal information to contact you
DYRSL will not send you any unsolicited commercial messages or material that does not relate to DYRSL and its promotions, entertainment or service offerings.
We may use information to determine your likes and interests to send you information about our entertainment programs, promotions or dining offers. This information will be determined from the information you might have provided, from your activity history or from your browsing history. You always have the option of opting out of receiving such information.
Personal Information and Security
DYRSL is committed to keeping your personal information secure, and we will take reasonable precautions to protect your personal information from unauthorised access, loss, release, misuse or alteration.
Your personal information may be stored in hard copy documents, but is generally stored electronically on DYRSL’s software or systems.
DYRSL maintains physical security over its paper and electronic data stores, such as locks and security systems. We also use computer and network security technologies such as firewalls, intrusion prevention software, antivirus software, external email filtering and passwords to control and restrict access to authorised staff for approved purposes, and to secure personal information from unauthorised access, modification, disclosure, misuse and loss.
We are required by law to keep some types of information for certain periods of time. If we no longer require your personal information, we will generally destroy or de-identify it. We reserve the right to retain information for longer than the minimum period required under any applicable law if we consider that it is appropriate, but we will hold it in accordance with this policy.
If the Club receives personal information about you which it did not request and which it does not reasonably require, we may take reasonable steps to destroy or de-identify this information where appropriate.
Whilst DYRSL takes all reasonable steps to secure your personal information from loss, misuse and unauthorised access, you acknowledge that all activities in which you intentionally or unintentionally supply information to DYRSL carries an inherent risk of loss of, misuse of, or unauthorised access to such information.
Generally, the Club will not disclose personal information to overseas recipients except with your consent or where we are required or authorised to do so by law. As far as the Club is aware none of its contractors transmit or store data overseas.
If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals. In such a situation we will comply with the requirements of the Privacy Act which may require notification to the Office of the Australian Information Commissioner (OAIC) and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk-mitigation and notification activities as required.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
If you need to access your personal information that is held by DYRSL, you will be required to make a request to the Club in writing, which can be given physically to Club reception, sent by mail to the Club or by email to firstname.lastname@example.org. We will provide you with access to the information requested within a reasonable period after the request is made, not exceeding 30 days. We may charge you a reasonable fee for processing your request. We may decline a request for access to your personal information if the Privacy Act prohibits it or does not require us to provide access.
DYRSL encourages its members to update or correct personal information, so that the information is accurate and up-to-date. You may lodge a request to correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading, in which case please contact the Club. This can be done via the reception front desk, via mail or email. We will deal with your request in accordance with the Privacy Act.
If you wish to make a privacy complaint, please put your complaint in writing with as much detail as possible and send it to us by letter or email using the details listed below:
Chief Executive Officer
Dee Why RSL Club Ltd
PO Box 1546
DEE WHY NSW 2099
The CEO or another representative of the Club, will consider (and may investigate) the complaint and provide you with a written response within a reasonable timeframe (taking into consideration the nature of your complaint).
FEEDBACK AND OTHER QUERIES
If you believe the club has not adequately dealt with your complaint, you may forward your complaint to the OAIC whose contact details are as follows:
Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
GPO Box 5218 Sydney NSW 2001