Privacy Policy - Holman Barnes Group

Approved by Board of Directors: 20 December 2024

Western Suburbs Leagues Club Ltd ABN 69 000 154 736 (‘Club’, ‘we’, ‘us’) and our related entities appreciate that privacy is very important to people. The Club has adopted this members and visitors privacy policy (Policy) to better protect the privacy of the personal information that we collect and hold whilst carrying out our activities. ‘Personal information’ in this Policy means information or an opinion about an identified person, or a person who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not, as defined in the Privacy Act 1988 (Cth) (Privacy Act).

This Policy has been developed as part of the Club’s efforts to comply with its obligations under the Australian Privacy Principles (APPs) established under the Privacy Act, and applies to personal information collected from and about staff, members, guests, other customers, suppliers and any other person whose personal information the Club may collect from time to time. Wests Ashfield Leagues will review and update this Policy whenever we consider appropriate.

By visiting our website at https://www.holmanbarnesgroup.com.au (Website), attending our premises, using our goods and/or services or by otherwise providing your personal information to us or to our third party contractors, you confirm your acceptance of the terms of this Policy and consent to the handling of your personal information as set out in this Policy. If you do not agree with the terms of this Policy, please do not attend the Club’s premises, use or products, services, Website or otherwise provide us with your personal information.

The Kinds of Personal Information the Club Collects

As a registered club, the Club will collect a wide range of personal information about you that is reasonably necessary for our activities – that is, information that can identify you such as your name, street and/or mailing address, email address, phone number, occupation, date of birth, gender, proof of age, photograph, affiliations, memberships of other organisations (including other clubs), live or recorded CCTV or video or audio, biometric data, internet protocol address (IP address), other contact details and the extent of your use (and preferences in relation to) products or services offered by the Club. We may also collect this and other types of personal information, such as your membership number, during the course of dealing with you.

Some of the information the Club collects is ‘sensitive information’ (a subset of personal information that is defined under the Privacy Act), such as information about your health. The Act requires the Club only to collect sensitive information:

from you where you consent and it is reasonably necessary for our activities; or
if the collection falls under one of the established categories under the Privacy Act (for example, if the collection is required by law or a court or tribunal order, or if the collection relates to our Club activities and you are a Club member or have regular contact with us in connection with our activities)

Sometimes, if you do not provide us with the information that we request, we may not be able to do business with you. For example, the Club is unable to admit you as a member unless you provide the information required by law. You have the option of not identifying yourself or using a pseudonym when dealing with us. However, this will be limited to enquiries of a very general nature and usually only over the telephone or by email. You may also be able to visit our Website anonymously. In most circumstances, you will be unable to deal with the Club anonymously or with a pseudonym because of our obligations under liquor and gaming law.

How the Club Collects and Stores that Information

General
Where possible, we will collect your personal information from you in a number of ways.
Your personal information is typically 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, membership of the Club or request to use our services;
purchase goods or services from us;
use your membership card or any other card issued by the Club;
access or use our on-premises Wi-Fi from any of your personal devices;
use our gaming machines or request to be excluded from using our gaming machines;
attend a function or show at the Club;
plan a function to be held at the Club;
participate in the activities offered by the Club including raffles, competitions and promotions;
visit our Website or one of the social media sites used by the Club;
are banned or removed from the Club or the gaming area;
use your Club membership card or another card issued by the Club in the Club;
receive or request sponsorship through programs such as ClubGRANTS;
are involved, witness or are connected to an incident at the Club or disciplinary proceedings of the Club; and/or
obtain, apply for, or renew membership of a sub-club of the Club or participate in the activities of a sub-club of the Club.

Collecting your information from third parties
Whilst we strive to only collect your personal information from you, there may be circumstances where 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:

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;
the Police, a regulatory authority, a local liquor accord or another club industry organisation;
another member of the Club; or
your representative(s).

Types of personal information required or authorised by law
As a registered club, we have a legal responsibility to collect certain information about our members and guests pursuant to state and federal legislation including without limitation 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 (Cth).

For example, when a person applies for membership of the Club we must collect details including their name and address. We must your name on the Club’s notice board before the Board is able to consider the application for membership. We may also need to provide this information (and such other details as contained in the Club’s membership register) to other members if a due request is made under 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 license or passport) to gain entry into the licensed premises. If you elect to use our electronic ID scanner, we collect information from your ID at the time you enter the Club.

Our Website
When you visit our Website, the server records your visit and logs general information such as your IP address, search terms, your operating system and browser software, and the data downloaded (such as web pages or document files). This information does not identify the user personally. Our website may include links to other organisations. We are not responsible for linked websites, so before you disclose your personal information to any linked website you should check their privacy policy.

The Purposes for which the Club Collects, Holds, Uses and Discloses that Information

In general, the Club will collect, hold, use and disclose personal information to operate the Club, perform our business activities and functions, provide products and services to members and guests and provide the best possible customer service.
Generally, we will only collect, hold, use and disclose your personal information to undertake one or more of the following purposes:

to process membership applications and renewals;

to identify who comes into the Club and verify their details;
to establish and maintain your membership to the Club, including displaying in the Club and in some cases disclosing your name and address (as required by law) and providing you with newsletters, quarterly magazines, notices of general meetings, annual reports and other information necessary to allow you to play an active role in the Club;
to provide the products or services you have requested from the Club and to administer any benefits to which you may become entitled;
to answer your enquiries;
to register you for events, promotions or competitions;
to assist us to make the Club’s Website, services and products more valuable to our members and guests;
for direct marketing of products or services to keep you informed of new developments we believe may be of interest to you (you will be given the opportunity to opt out of all direct marketing channels, upon your written, verbal or electronic request);
to third parties where we have retained those third parties to assist us to operate the Club and provide the products or services you have requested, such as marketing consultants and promotions companies, catering and event coordinators, businesses operating from our premises, website hosts and IT consultants, electronic gaming organisations, and our professional advisers such as management consultants, lawyers and accountants;
to help the Club operate its business;
to different parts of the Western Suburbs Leagues Club Group to enable the development and marketing of other products and services and to improve our customer service in general; and
to comply with our legal obligations.

If we collect your personal information for another purpose, we will generally let you know at the time we collect the information.

How we hold/store your personal information

General
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 secure storage of confidential paper records and password access rights to computerised records.

Your personal information is held securely on our on-site servers and on cloud storage servers and is restricted, password protected and only accessible to relevant employees and third-party IT service providers.

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 us promptly.

Surveillance and facial recognition

In the interests of security and safety, and the comfort of members and guests, the Club also operates video cameras within the Club’s premises. Video surveillance is stored on our digital recorders which are maintained in a restricted access area and password protected.

The Club has introduced facial recognition technology to consolidate the Club’s security systems and to assist us in identifying individuals who are suspended, banned or self-excluded from our premises.

There are designated security cameras throughout the Club’s 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 the Club 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 if it does not match the faceprint of any person whose faceprint is contained in the database. If your faceprint does not match the faceprint of any individual in this database, it may be stored on our on site servers and deleted after 28 days.

The Club stores the faceprints of those persons who have been suspended, banned or self-excluded from our premises for such time until the suspension, ban or self-exclusion ceases.

Unsolicited personal information
If we receive personal information about someone that we did not solicit (either directly or by facilitating the provision of that information to us) then within a reasonable period after receiving the information we aim to destroy the information, or if destruction is not possible in the circumstances, to ensure the information is identified.

How 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 or when permitted under the Privacy Act.

The Club may also use the personal information we collect from you for direct marketing (e.g. via direct mail, telephone, email or SMS) of products and services to you including from third party suppliers. Such products and services may include the provision of newsletters, competitions, announcements, campaigns or information about entertainment at the Club or services offered by the Club. You always have the option of opting out of receiving any direct marketing by contacting us.

When we will disclose your personal information

General
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, and recreational activities. This includes when necessary to provide you with a product/service, to help us in running the Club, and to comply with our legal obligations.

Sometimes the Club may disclose your personal information outside the Club for the purpose for which the information was collected or for a related purpose. For example, we may provide your personal information to:

employees, third party service and content providers, dealers and agents, contractors and advisors, in order to provide products and/or services to you or to market their products and/or services to you;
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 if we engage in an amalgamation with another registered club, or, an actual or prospective purchaser if 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 disclose your personal information to third parties on the basis that they agree with us to only use your personal information for the purpose for which it was provided and to protect the privacy of your personal information (except where we are authorised or required by law to disclose the information).

The Club may also share your 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.

If we disclose personal information for enforcement related activities by an enforcement body (e.g. the Police), the Club will make a written record of that disclosure.

Consent
You consent to us disclosing your personal information to the third parties referred to above, and similar organisations, who may in turn provide your information to others (for example, for marketing purposes). 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).

Sending information overseas
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.

Data Breach

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), the Police 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.

How a person may access and ask for correction of their personal information

You can request access to the personal information that the Club holds about you by contacting the Club’s Privacy Officer as set out below. We will provide you with access to your personal information requested within a reasonable period after the request is made, usually not exceeding 30 days. However, in some circumstances we are legally authorised to refuse your request (for example, if providing access would impact unreasonably on the privacy of others). If we do refuse access, we will generally let you know the reasons. The Club will not charge any amount for providing access to this information.

The Club will take reasonable steps to keep secure any personal information which we hold and to keep this information accurate, complete and up to date. If you wish to change personal information that is out of date or inaccurate at any time please contact us. After notice from you, we will take reasonable steps to correct any of your information which is inaccurate, incomplete or out of date. This can be done via the reception front desk, via mail or email, or by contacting the Chief Executive Officer. We will deal with your request in accordance with the Privacy Act. We will take reasonable steps to correct Club records appropriately and within a reasonable time frame except where the Privacy Act prohibits it or does not require it.

The Club is 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 that information. The Club reserves the right to retain information for a period longer if the Club considers that it is necessary, and as long as it is in accordance with the APPs.

The Club may amend this Privacy Policy from time to time by posting the amended version in the Club or on our website at https://holmanbarnesgroup.com.au. We suggest that you visit our website regularly to keep up to date with any changes.

How we deal with questions or complaints

If you have a question about privacy or a complaint regarding the Club’s compliance with the APPs, please contact the Club’s Chief Executive Officer in writing. The Chief Executive Officer, or an authorised delegate, 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 Club’s response, you may contact the Office of the Australian Information Commissioner.

Contact Us

Simon Cook
Chief Executive Officer
115 Liverpool Road
ASHFIELD NSW 2131
P: (02) 8752 2000
E: info@holmanbarnesgroup.com.au