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A business that can be defined as an organisation, which consists of an individual, a company, a partnership, a trust, an incorporated association, or any other unincorporated association, is required to comply with the Privacy Act 1988. The Privacy Act 1988 exempts: – employee records – related companies – individuals in a non-business capacity – registered political parties – acts and practices of media organisations carried out in the course of journalism – a small business with a $3 million turnover (or less), unless it: – provides a health service – sells personal information – purchases personal information – is related to a business that is not a small business – is an operator of a residential tenancy database – is a reporting entity for the purposes of the Anti-Money Laundering and Counter- Terrorism Financing Act 2006 – contracts as a service provider to the Commonwealth. POLICY The Privacy Act 1988 provides extensive regulations about the collection, storage and use of information relating to individuals. It also contains some specific exemptions for organisations that have a need to collect, store and use information about individuals, one of which is to exempt the “acts and practices of employers in relation to employee records”. To be exempt, an act or practice relating to the employee record must be directly related to the employment relationship. This means that acts or practices of an employer that are outside the scope of the employment relationship are not exempt. For example, Glenelg Golf Club could not sell details of employees to another organisation. The act or practice must also be directly related to a current or former employment relationship. This does not cover future employment relationships. This means that personal information collected from prospective employees who are subsequently not employed, such as unsuccessful job applicants, are not covered by the employee records exemption. Once an employment relationship is formed with an individual, the record Glenelg Golf Club holds relating to that individual’s pre-employment checks then become exempt. Glenelg Golf Club is also covered by the 13 Australian Privacy Principles, as set out in the legislation, which cover all aspects of dealing with personal and sensitive information, not only those relating to employees. Glenelg Golf Club recognises the importance of protecting personal information, which it may be required to collect from individuals who become associated with its business. The purpose of this Privacy Policy is to ensure that any individual who provides information to Glenelg Golf Club is protected according to the requirements of the Privacy Act 1988. For the purpose of this Privacy Policy, information is described as: Personal information means information relating to an individual, including an opinion, which may be provided to Glenelg Golf Club as part of its business requirements either in material form or not, and whether true or not. Such information may personally identify an individual or make the person’s identity reasonably apparent Sensitive information means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual practices, criminal record or health information. Glenelg Golf Club takes its obligations under the Privacy Act 1988 seriously, and as such, takes all reasonable steps in order to comply with the Act and protect the privacy of personal information that it holds. PURPOSE This policy is in place to establish the standards that Glenelg Golf Club (GGC) will employ in relation to privacy: Glenelg Golf Club (GGC) is committed to protecting the privacy of its Members and other individuals who we deal with. This privacy policy explains how we collect, use, and disclose personal information from time to time. When you provide us with your personal information, you consent to GGC collecting and handling your personal information in accordance with this policy and any other arrangements between us. SCOPE This policy applies to Glenelg Golf Club (GGC) Members, visitors, employees, suppliers, contractors and prospective contractors, and other individuals who come in contact with us. DEFINITIONS For this policy, the following definitions apply: Glenelg Golf Club workforce GGC workforce includes GGC board Members, employees, and volunteers. Members & Visitors Includes all past and present Members and visitors of GGC. Collection and Use of Information Personal Information Glenelg Golf Club may require the collection of personal information from individuals where it is reasonably necessary for the purposes of carrying out its business and operations as a golf club. The reasons for the collection of personal information include, but are not limited to: Maintaining employee records and administering employment; for membership management purposes; for our normal functions and activities; salary and superannuation; human resources processes; data analysis; quality assurance; improving promotional and online services; accounting, billing and other internal administrative purposes; distributing, or facilitating club memberships; where required or permitted by law, including for purposes related to the purpose of collecting of personal information (or purposes directly related to the purpose of collecting your sensitive information). Glenelg Golf Club may collect and hold personal information, such as, but not limited to, names of employees, members and proprietors of organisations, addresses, telephone numbers, facsimile numbers, email addresses, titles and professional affiliations, bank account details, credit and debit card details, guardians/emergency contacts, occupation, and information obtained when you use our website, including which of our pages you have accessed. In the event that sensitive information is collected by Glenelg Golf Club, it is not used for any purpose without the express permission of the individual. The collection, use and disclosure of information is in accordance with the Glenelg Golf Club Collection Statement. Where we collect unsolicited information, such as information contained in an email sent to us in error, we will destroy or de-identify the information as soon as practicable, if it is lawful and reasonable to do so or we would have been entitled to collect the information if we had solicited it. If we do not destroy or de-identify the information, it will be handled in accordance with this privacy policy. We will generally collect personal information about you directly by way of forms and other documents submitted to us by you, correspondence you provide to us and telephone calls/meetings with you. We may also collect information through the use of CCTV or other monitoring used in our premises, photography or videography. With your consent, and in accordance with our Social Media policy we may share photographs or videos on our social media platforms for promotional purposes. Occasionally, we may collect personal information about you from third parties. For example, we may collect personal information about Members from relatives or other authorised representatives (and vice versa). For job applicants, contractors or prospective contractors, volunteers we may collect details of your criminal record (if any) from police agencies or agencies who complete police checks and working with children checks on our behalf. We will only use sensitive information for the following purposes unless otherwise permitted or required by law or we obtain your consent: to assess whether it is appropriate for certain volunteers, students, job applicants and potential contractors to be on our premises or interact with customers from time to time. DISCLOSURE OF PERSONAL INFORMATION We may disclose personal information about you to the following types of persons or entities if required in connection with the purposes listed above: your relatives or authorised representatives; any industry body, tribunal, court or otherwise in connection with any complaint made about us by you or on your behalf; Your referees (if you have provided us with referees to assist with a job application, the assessment of a potential contract between you and us or for any other purpose); various membership, accounting software and events software providers who perform functions or provide services on our behalf; government departments or funding agencies, police agencies and agencies who complete police checks; other entities with your consent or as permitted or required by law. Storage, Access and Retention of Personal Information We hold personal information in paper form and electronic form. Our electronic records are stored using local and/or cloud storage. Our cloud storage providers are subject to contractual obligations to strictly limit handling of personal information. The data is not made available to a third party, unless it is legally required and verified, without the authority of the individual who provided the personal information. Glenelg Golf Club takes all reasonable steps to protect the security of the personal information that it holds. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy as follows: strong policies and procedures to ensure GGC workforce and our contractors follow appropriate security protocols. secure storage facilities for physical files. limiting access to personal information, particularly sensitive information, to such members of the GGC workforce and contractors. using secure networks or encryption when transmitting information electronically (although it is important to note that transmission over the internet can never be made completely secure); protecting our devices and networks using authentication, firewalls, intrusion detection, virus scanning and other security systems. data breaches (including notifying affected individuals of any such breach) will be dealt with in accordance with our Data Breach Response Plan Procedure and the law. We retain personal information for as long as it is required for our functions and activities or as required by law or an order of a court/tribunal. Generally, we retain information about Members for at least the tenure of their active membership. Information that is no longer required is securely destroyed or de-identified. HOW TO OBTAIN ACCESS TO YOUR PERSONAL INFORMATION You may obtain access to personal information which we hold about you at any time, with access via the Members login and “my information” section of the website. If you request that we provide you with copies of your personal information, we may require you to verify your identity and specify what information you require. If you make a request for copies of your personal information held by us we will endeavour to provide you with such personal information as soon as reasonably practicable. Where you ask for copies of your personal information, we may at our discretion charge you a fee to cover our reasonable costs incurred in providing you with those copies. You will not be charged to update or change your personal information. There may be occasions when access to personal information we hold about you is denied, including where the release of the requested information would have an unreasonable impact on the privacy of others or because we are otherwise prevented by law from releasing the information. ACCURACY OF PERSONAL INFORMATION While we will endeavour to ensure that the personal information collected from you is up to date, accurate and complete, we will assume that any personal information provided by you is free from errors and omissions. DIRECT MARKETING COMMUNICATIONS From time to time we may use your personal information to provide you with marketing materials in relation to offers and services that we have available. We may use various means of communication to do so, including email, SMS and targeted or behavioural online advertising. If you would not like to receive direct marketing materials from us through some or all of those channels you may notify us using the contact details set out below or, for email and SMS, by using the unsubscribe option. COOKIES AND THIRD-PARTY WEBSITES A cookie is a data file that a website transfers to your computer. This enables the website to track the pages you have visited. A cookie only contains information you supply. It cannot read data on your computer. Our website uses cookies. You can set your browser to refuse cookies; however, this may mean you are unable to take full advantage of our website. Third party websites, platforms or applications that our website provides links to, or that GGC maintains a presence on, are not subject to our privacy policy or GGC control. We recommend you ensure you are familiar and comfortable with the privacy policy of any such website, platform or application prior to use. Certain third party websites, platforms or applications may provide you with options through their settings or other tools to control your privacy and to opt out of personalised advertisements. Compliance: If you are of the view that we have breached the APPs, the Privacy Act or any related privacy code in dealing with your personal information, you may make a complaint verbally, using one of the feedback forms provided by GGC or in writing to the General Manager. When we receive a complaint, we will endeavour to provide you with confirmation as to how we propose to deal with the complaint as soon as reasonably practicable. Please direct all enquiries or complaints regarding your personal information or privacy to the General Manager at reception@glenelggolf.com If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner by visiting the following website and following the steps: http://www.oaic.gov.au/privacy/privacy-complaints. Further information can be obtained by contacting Glenelg Golf Clubs nominated privacy officer. A copy of the Australian Privacy Principles can be accessed at http:/ / www.oaic.gov.au/ privacy/ privacy-resources/ privacy-fact-sheets/ other/ privacy-fact-sheet-17-australian-privacy-principles. VARIATION OF POLICY: We may vary the terms of this privacy policy from time to time to take account of new laws and technology, changes to our functions and activities and to make sure it remains appropriate.