WHO DOES THIS POLICY APPLY TO AND WHAT DOES IT COVER?
Western Suburbs (Ncle) Leagues Club Limited (“Wests” or “We/we” or “Our/our” or “Us/us”) operates the Western
Suburbs (Newcastle) Leagues Club and a number of related entities including but not limited to:
• Wests New Lambton Bowling Club;
• Wests Mayfield;
• Wests City;
• Wests Nelson Bay;
• Wests Cardiff;
• The Executive;
• The Gateway;
• The Anchorage Hotel & Spa;
• Balance Collective; and
• The Newcastle Exhibition & Convention Centre (NEX)
We also operate Knights Rugby League Club. However, the Knights Rugby League Club has its own privacy policy available here: www.newcastleknights.com.au/privacy-policy.
This policy sets out how we collect, use, hold and disclose “personal information”.
“Personal information” means information or an opinion about an individual (or an individual who is reasonably identifiable), regardless of whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are common examples of information which may constitute personal information.
OUR PRIVACY COMMITMENT TO YOU
At Wests, we are committed to respecting and safeguarding your privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise or unless required or permitted by law, we will only collect and use personal information as set out in this policy.
We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles. Where appropriate, we will handle your personal information relying on the employee records exemption (which applies to employee records related to current and former employment relationships) and the related bodies corporate exemption in the Privacy Act.
To keep up with changes in legislation and the club’s practices, we may revise this Privacy Policy at any time without prior notice.
We will notify you of any changes to this Policy by posting a notification and the updated Policy on our websites and on a noticeboard in the foyer of each club that we operate, being Wests New Lambton, Wests Mayfield, Wests Cardiff, Wests Nelson Bay or Wests City, so we encourage you to check our websites and our clubs’ noticeboards from time to time.
In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain information that we collect from you. If so, we will provide you with a supplementary collection notice at the time we collect that information from you. For example, if you apply for direct debit arrangement with us, the application form may contain additional provisions advising that we may collect information about your credit history by obtaining a credit report from a credit reporting body. You should carefully read any supplementary collection notices which are provided to you as their provisions will apply alongside this policy.
In the event of any inconsistency between the provisions of this Privacy Policy and the provisions of a supplementary collection notice, the provisions of the supplementary collection notice will prevail.
ANONYMITY AND PSUEDONYMITY
Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis, but this will usually be limited to enquiries of a general nature. Otherwise, we will seek the information identified in this policy. For example, it will not be practicable to deal with you on an anonymous or pseudonymous basis when we provide you with some goods or services because we are required to collect certain information about you in order to comply with our obligations under the Registered Clubs Act 1976, the Gaming Machines Act 2001, the Liquor Act 2007 and the AntiMoney Laundering and Counter-Terrorism Financing Act 2006.
Likewise, it is not practicable for us to deal with you anonymously in circumstances where the Club requires your contact details to send notices or other correspondence to you under the Registered Clubs Act or the Corporations Act or to correspond with you about other administrative matters. If you do not provide us with your personal information, you will not be able to become a member of our clubs and may not be able to use our services or facilities or access our premises.
If you provide us with your personal information but do not opt in to receive direct marketing material from us and our trusted third parties, we will be unable to provide you with information about certain promotions and products and services that we offer.
KINDS OF PERSONAL INFORMATION THAT WE COLLECT AND HOLD
We collect and hold a wide range of personal information, which may include:
• your personal details such as your full name, date of birth, gender, occupation, email address, telephone number,
residential address and postcode;
• your signature
• your contact preferences;
• information relating to your entry onto Wests’ premises;
• payment details including your credit card or bank account details;
• if required, credit information from you, credit reports and credit information from credit reporting bodies (for example, where you have applied for a direct debit or other financial arrangement with Wests;
• if required, health information, including information about your vaccination status, fitness levels and any medical conditions that you may disclose to us to enable us to provide our facilities and services to you;
• if you are seeking an exemption to any of our policies on grounds protected by law (including religious or political beliefs) information about the attributes and affiliations that you may disclose to us to enable us to consider your
request for an exemption;
• information about your preferences, interests, and experiences with our products or services, including your participation in any sporting and social activities and your preferences, interests, and experiences with any third-party products and services, this information is collected in order to tailor our communications to you and continuously improve our products and services;
• images or videos of you at any of our premises;
• information connected to your use of our gaming machines (including your player activity statements and any prizes you receive);
• information about you related to a liquor or gaming self-exclusion or banning order 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 us;
• information related to your use of our Wi-Fi at our premises;
• 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;
• if required, the contact details of third parties, including the name and contact details of your next of kin;
• any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy);
• any other personal information requested or required by a supplementary collection notice. When you use a website, we may also collect the following types of information:
• usage and preference information about how you interact with our websites, including the pages you visit, your preferences and settings that you choose;
• information about your device, such as the hardware model, operating system, preferred language, unique device
identifier and mobile network; and
• other information such as your IP address, access dates and times, browser type and pages visited when you interact with one of our websites.
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.
SENSITIVE INFORMATION
We will only collect sensitive information about you from you directly and, where it is not reasonably practicable to do so, will only collect your sensitive information from a third party with your consent. Where you provide us with any sensitive information (including, but not limited to, credit information, health information, and information about any attributes protected by law, such as your religious beliefs), we will only use this information for the purposes stated at the time of collection and will treat that information as confidential. Wests will keep any sensitive information which it holds about you secure and only accessible by those staff who require access to that information in order for Wests to provide goods and services to you. Wests will not disclose sensitive information without your express consent to anyone other than our related entities and advisers, except as permitted or required by law.
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
Wests; 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.
HOW WESTS COLLECTS AND HOLDS PERSONAL INFORMATION
Your personal information is collected whenever you visit or deal with Wests and its related entities. We will only collect and handle any personal information about you with your consent including as provided in this Privacy Policy or where it is otherwise lawful to do so. Information is collected by recording information that you provide to us by written means, by electronic means and by the observations of our staff.
ACTIVE INFORMATION COLLECTION
Personal information may be collected when you:
• enter, visit or engage with Wests;
• apply for, or renew, your membership of Wests ;
• apply for, or renew, your membership of a sub-club of Wests or participate in the activities and social events of a subclub of Wests;
• purchase merchandise from Wests, including purchasing tickets and merchandise through the Newcastle Knights club shop or website;
• use or request to use our services and purchase goods and services from us;
• attend a function or show at a venue we operate;
• plan an event to be held with us;
• participate in surveys and other types of research (including ‘Customer Comment Cards’);
• participate in any offers or marketing activities; enter a promotion, sweepstake, or contest hosted by Wests and/or our
partners;
• provide a service to us;
• contact us directly for information about Wests and its services;
• submit a credit account application form with Wests;
• attend an event where we are an exhibitor;
• book accommodation at our hotels including but not limited to The Executive, The Gateway and The Anchorage Hotel & Spa;
• book treatments at our spa at The Anchorage Hotel & Spa;
• join as a member or promotional member of any of our gyms;
• join or use or agree to update any of our apps;
• use our gaming machines (including the membership card based member loyalty system attached to gaming machines) or request to be excluded from our gaming machines;
• register your details on, interact with or browse any websites or social media pages operated by or under the control
of Wests;
• subscribe to any newsletters, updates, alerts or news and media releases, or request information or express interest about our products or services;
• have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
• complete and submit any forms to us;
• access or use our Wi-Fi from any of your personal devices;
• use your membership card or another card issued by Wests in any of Wests’ premises;
• receive or request sponsorship through programs such as ClubGRANTS;
• apply to become an employee of Wests;
• are involved in, witness or are connected to an incident, occurrence or disciplinary proceedings at or in connection with Wests;
• are suspended, banned or removed from any part of Wests’ premises; or
• do any of the above in relation to our related entities, including the Newcastle Knights.
You are not obligated to provide Wests with the abovementioned personal information. However, failure to do so may result in Wests being unable to facilitate or provide you with certain products or services, information about its product and services or the opportunity to participate in any upcoming promotions, competitions, offers or events.
Where it is not reasonably practicable to collect information from you directly, we may also obtain your personal information from legitimate third party sources and platforms including the NRL and the Rugby League Exchange, as well as other social media channels, commercial data providers, referral agents, marketing companies, targeting companies, list brokers, credit reporting bodies and other data providers or organisations that share data in circumstances where
it is lawful and/or you have given permission for them to do so, including our service providers and retail partners. We may also collect information about you from other clubs and industry bodies if you have excluded yourself from Wests’ premises under a multi-venue self-exclusion program.
CHILDREN
Personal information will not be collected about any person who is known by Wests to be under the age of fifteen (15) years without the consent of a parent or legal guardian. Persons under the age of fifteen (15) years may only use our websites with the involvement and consent of a parent or legal guardian.
PASSIVE INFORMATION COLLECTION
We may also collect information which tells us about visitors to our websites. For example, we may collect information about the date, time and duration of visits and which pages of a website are most commonly accessed. This information is generally not linked to the identity of visitors and so is not personal information, except where a website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a website.
By accessing a website via links in an email we have sent and/or by accessing a website generally, you consent to the collection of the information identified in this Policy. When you receive newsletters or promotional emails from Wests, we may use web beacons (described below), customised links or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other
information.
As you navigate through our websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (“UDI”), cookies, internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). Depending on the device you use and how you connect to the internet, this information may be considered anonymous information or
personal information under the Privacy Act 1988 (Cth). Your Internet browser automatically transmits to the website certain information, such as the URL of the website you just came from, the Internet Protocol (“IP”) address, the UDI (if applicable) and the browser version your device is currently using. Our websites may also collect information from your device through cookies and internet tags or web beacons. You may set your browser to notify you when a cookie is sent
or to refuse cookies altogether, but certain features of a website might not work without cookies and this may limit the services provided by a website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
Our websites may use and combine such passively collected information and may combine this information with other personal information collected from you to provide better services to you, customise a website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a website or a third party website, and otherwise administer and improve a website for your use. We may combine your visitor session
information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing our websites, you consent to information about you being collected, compiled and used in this way.
For more information about cookies and how you can opt out, you can visit www.oaic.gov.au/privacy/yourprivacy-rights/advertising-and-marketing/targeted-advertising or www.youronlinechoices.com.au
IS WESTS REQUIRED BY LAW TO COLLECT PERSONAL INFORMATION?
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 the avoidance of doubt, these obligations apply to all our registered clubs.
For example, when a person applies for membership with us, we must collect details including their name and address. We must display this information 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 our clubs 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 scanner, we will collect information from your ID at the time you enter our clubs. More information about our electronic ID scanners appears below.
PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We collect, hold, use and disclose your personal information to operate Wests, 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. Personal information will be collected to undertake one or more of the following primary purposes:
• for the purposes stated in a privacy collection statement on a particular Collection Channel;
• to consider applications and renewals of membership at Wests or any of our clubs, including Newcastle Knights;
• to identify who comes onto our premises and to verify their details, including age and address;
• to increase membership of our clubs;
• to identify individuals who have been suspended, banned or self-excluded from our premises;
• to investigate an incident or conduct disciplinary proceedings at or in connection with Wests;
• provide a safe environment for you, other members and guests and our staff;
• to operate functions at our venues and allow you to hire our facilities;
• to offer dining options and other entertainment;
• to process bookings at our hotels, restaurants and spas;
• to allow you to purchase show tickets;
• to process gym membership applications and manage your membership;
• to perform gaming operations;
• for the organisation, conduct and promotion of NRL competitions and matches (including for the purpose of providing information and making ticket offers to you);
• to assist the Newcastle Knights and the NRL comply with the NRL Rules, including the administration and development of Rugby League (if you are a participant in the game of Rugby League including as players and officials);
• to process NRL match tickets and to provide you with merchandise including NRL and Newcastle Knights merchandise
• to operate, maintain the functionality of and improve a website, including to provide you with information about the content available on a website and to provide you with relevant advertising when you use our website;
• to complete a transaction, to consider whether to extend credit to you;
• to facilitate or provide you with certain products or services, and information about such products or services;
• to publish and distribute newsletters; electronic newsletters (e-newsletters) and news and media releases;
• to assist with your queries or customer service issues promptly. We may also keep information on your communications with our customer service representatives;
• to keep you up-to-date with products, services, events or promotions we think would be of particular interest through a variety of channels. You are able to “opt-out” from this activity at any time;
• for planning, product development or research purposes;
• to contact you in relation to employment opportunities and, if you apply for a position with us, to assess your suitability for employment;
• to maintain our relationship with you;
• to enter you into and administer competitions and promotions;
• to send you any technical, administrative or legal notices important to our websites;
• to provide you with information about your transactions (including uploading, access to, and receipt of content on a website), content, services and products;
• to provide direct marketing materials, events, special offers, competitions and promotions in person and via any
medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel;
• to respond to enquiries and resolve complaints;
• to improve our system administration;
• to obtain opinions or comments about products and/or services and to conduct other research and development;
• to record statistical data for marketing analysis and to conduct market research;
• to share personal information with our related entities, our promotional partners and other trusted third parties in the manner described below;
• to fulfil our obligations under either the Registered Clubs Act 1976 (as amended), including our obligation to create registers and display information;
• to comply with our obligations with any public health orders and any other laws in place from time-to-time;
• to carry out accounting and finance requirements and legal and administrative reporting requirements;
• to operate our sub-clubs, including publishing contact details of committee members;
• to offer and manage sponsorships including by supporting community sports and social events;
• to conduct elections of the Board; and/or
• to fulfil our obligations under the Constitution and By-laws of Western Suburbs (N’cle) Leagues Club Limited.
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.
In carrying out these activities and functions, there may be times we need to share some of your personal information with our related entities (including the Newcastle Knights), our sponsors and promotional partners, including the NRL, Clubs, States and Rugby League Partners, and third parties we engage to provide services to us.
Wests engages third-party contractors to perform a variety of functions, such as legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites.
Wests will only disclose your information to a third-party if it is necessary for them to perform such functions and Wests will always require that those entities comply with the Privacy Act when dealing with your information.
Our sponsors and promotional partners may also send you information about products and services that they believe will be of interest to you. If you do not wish to receive information from these entities, please opt out from such promotional and marketing information as part of the relevant organisation’s preference centre and/or contact the NRL’s Privacy Officer in accordance with the NRL Privacy Policy located at https://www.nrl.com/privacy-po....
If you have self-excluded yourself from Wests’ premises and nominated other clubs from which you also want to be excluded, we may disclose your personal information to those clubs and the operator of the relevant multivenue selfexclusion program to the extent necessary to assist those clubs to comply with your self-exclusion.
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.
HOW WE SHARE YOUR INFORMATION AS PART OF THE RUGBY LEAGUE EXCHANGE
If you have any dealings with the Newcastle Knights, we will share with your personal information through the “Rugby League Exchange”, which is an established data storage architecture for processing personal information, and an initiative of the National Rugby League, the Newcastle Knights, other clubs, Queensland Rugby League, New South Wales Rugby League, Country League of NSW and selected third parties. In this Privacy Policy, we use the following terms as
defined:
• “NRL” means the Australian Rugby League Commission Limited, National Rugby League Limited and each of their associates, related entities and subsidiaries
• “Competition” means any competition, tournament or league registered or carried out by the NRL or States including the pre-season, season proper, finals series and any post season tournament or knockout cup competition and any other football competition or tournament.
• “Competition Administrator” means the entity responsible for the conduct and staging of a Competition and includes (without limitation) the NRL and States (including the divisions and associations that make up the States).
• “Clubs” means any club registered with the NRL or States from time to time.
• “States” means any of Queensland Rugby League, New South Wales Rugby League, Country Rugby League of New South Wales, NRL Victoria, NRL South Australia, NRL Northern Territory, NRL Western Australia and NRL Tasmania.
• “NRL Rules” means NRL’s constitution, rules, regulations, policies and procedures and any other ancillary document that governs the NRL in administering the game of Rugby League, as promulgated and amended from time to time
• “Rugby League Partners” means any entity that has a commercial agreement or arrangement with the NRL, States, Competition Administrator or Club (as the case may be), including Ticketek and Ticketmaster, and which you may also have a direct relationship with (including by participation in a Competition).
Generally speaking, where you provide information to Wests or the Newcastle Knights in relation to your engagement with the Newcastle Knights, including, for example, where you buy a ticket or membership to a club match, buy merchandise or by entering a club promotion, then your information may be shared as part of the Rugby League Exchange.
The NRL is responsible for the maintenance and administration of the Rugby League Exchange. Newcastle Knights and Wests will share your Personal Information with the NRL as part of the Rugby League Exchange in order to facilitate analysis of fan behaviour and preferences to improve fan support, fan offerings, provide more targeted content and products and any other purposes described in this Privacy Policy or the NRL’s Privacy Policy. We encourage you to read
the NRL’s Privacy Policy to understand how your Personal Information will be handled in relation to the Rugby League Exchange. The NRL’s Privacy Policy is located at www.nrl.com/privacy-policy
CONTACTING YOU
Wests and its related entities (and their directors, servants and agents), our promotional partners or trusted third parties (and other selected service providers and other non-Wests companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email or post using the contact details that you have provided to us in connection with any of the primary purposes for collection of personal information as stated above.
We do not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or if it is otherwise lawful to do so. If, for any reason, you would like to be removed from our mailing lists, please complete one of the following:
• Choose to “Opt-Out” from our Privacy Officer;
• Select ‘Unsubscribe’ on electronic communications; or
• Email privacyofficer@westsnewcastle.com.au
Please allow up to 30 days for this request to be processed.
Despite removing your name from the database from receiving future advertising and marketing information, we may send you non-commercial “Administrative Emails”. Administrative Emails relate to a user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular user account.
ABILITY OF OTHERS TO VIEW INFORMATION
We may provide areas on a website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our websites. We are not responsible for the conduct of others who may read, collect and use this information.
YOUR RIGHT OF ACCESS
You have the right to access and review your personal information that may be recorded on our database. Information may be reviewed by contacting our Privacy Officer at the contact details located at the end of this Policy. Please allow 30 days for this request to be processed. 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
Wests. If we are not able to provide access, we will provide you with written reasons.
CHANGING AND CORRECTING THE INFORMATION WE HAVE ABOUT YOU
Wests’ goal is to ensure that your personal information is accurate, complete and up-to-date. To assist us with this, please contact our Privacy Officer if any of the details you have provided change. Further, if you believe that the information we have about you is not accurate or is misleading, please contact us and we will use all reasonable efforts to correct the information. No fee applies to correction of personal information. Please allow up to 30 days for this request to be
processed.
As with a request to access your information, we may need further information from you to verify your identity and evidence of your new details. If we refuse to correct or amend your personal information, we will give you written reasons for our decision.
STORAGE AND SECURITY OF PERSONAL INFORMATION
We may store your personal information electronically and/or in hard copy at our premises. The information is also storedon secure and password protected servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. Video and audio surveillance is stored on our digital recorders, which are maintained in a restricted access area and password protected.
We do not keep your bank account or credit card details. You have the option of making payments to Wests via direct debit or credit card. If you set up a direct debit or process a credit card payment online, you will be redirected to a page to provide your payment details to our third-party payment system provider directly. If you authorise a direct debit or credit card payment in person at any of our premises, we will enter your payment details with our third-party payment system provider and store a hard copy of your completed direct debit form (with your payment details redacted) securely at our premises.
Wests is committed to ensuring the security of your personal information and takes all reasonable precautions to protect this information from unauthorised access, loss, misuse or alteration. We take all reasonable steps to keep your personal information secure and to ensure this information accurate, up to date, complete and relevant. We ensure that only those members of staff who need to have access to your personal information are able to access that information.
Your personal information is securely destroyed when it is no longer needed or when it is out of date.
NOTIFIABLE DATA BREACHES SCHEME
Wests 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 unlikely event that the Wests’ security measures are compromised, and your information is the subject of a notifiable data breach, Wests will comply with its obligations for responding to data breaches outlined in the Privacy Act. Upon becoming aware of a data breach, we will take urgent steps to contain the breach, mitigate any risk of harm and determine who may have been affected.
We 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 we have reasonable grounds to believe that the breach is likely to result in serious harm to you, we will notify you of the breach as soon as possible. We will also notify the Office of the Australian Information Commissioner.
Following a breach, Wests will conduct a review of its security measures and implement any additional measures it considers necessary to enhance the security of your information.
LINKS TO OTHER WEBSITES
Our Websites may, from time to time, contain links to the websites operated by third parties which may be of interest to you. Any such links are provided for reference only and we do not endorse the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. We do not have control over websites operated by third parties and are not responsible, nor do we accept
any liability, for the conduct of companies linked to our websites.
We may use third party advertisements on our websites. All third party advertisements are not recommendations or endorsements by us or any of our affiliates. We are not responsible for the content (including representations) of any third party advertisement on a website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to, or control of, cookies placed by third parties on their websites.
SALE OF THE COMPANY
If Wests merges with, or is acquired by, another entity, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets transferred. However, personal information will remain subject to this Privacy Policy.
Our Websites may, from time to time, contain links to the websites operated by third parties which may be of interest to you. Any such links are provided for reference only and we do not endorse the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. We do not have control over websites operated by third parties and are not responsible, nor do we accept
any liability, for the conduct of companies linked to our websites.
We may use third party advertisements on our websites. All third party advertisements are not recommendations or endorsements by us or any of our affiliates. We are not responsible for the content (including representations) of any third party advertisement on a website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to, or control of, cookies
placed by third parties on their websites.
FREQUENTLY ASKED QUESTIONS
How does this policy apply to Wests’ sub-clubs and its related entities?
Wests’ clubs operates a number of sub-clubs that form part of Wests’ clubs.
For the purposes of the Privacy Act, a sub-club’s collection, use, disclosure or storage of your personal information is Wests’ collection, use, disclosure or storage of your personal information.
If a sub-club (being part of Wests) collects, uses, discloses or stores your personal information, it will comply with this policy when doing so.
Wests may have one or more related entities, also known as “related bodies corporate”.
These related entities are separate legal entities to Wests, but are related to Wests in some way (e.g. Wests owns the related entity).
The Privacy Act permits related entities to share personal information in certain circumstances.
If an entity related to Wests collects, uses, discloses or stores your personal information, it will comply with this Policy when doing so (unless that entity has its own privacy policy).
Why does Wests collect information about and relating to my vaccination status?
COVID-19 is a highly transmissible disease which can cause serious illness and, in the worst cases, death. Wests’ primary concern is the safety and wellbeing of its staff, members and the broader community. Wests is also required by law to take reasonable steps to provide a safe environment for its employees and members and to minimise the risk of transmission of COVID-19.
Wests believes that vaccination against COVID-19 is the best protection against the COVID-19 virus.
Wests will observe Government health orders, in addition we may introduce our own standards and practices which may vary from time to time. Members and guests may be required to produce evidence of their vaccination status or medical contraindication certificate.
Employees and other workers must observe and comply with Wests Vaccination Policy.
How does Wests handle information about and relating to my vaccination status?
Wests reserves the right to sight and retain your vaccination evidence or any medical contraindication certificates that you produce, in order to fulfil our employment and safety obligations.
Wests recognises that health information (including your vaccination status) is sensitive information. Wests will treat any sensitive information as confidential and will only handle that information in accordance with its policies, the Privacy Act and the Health Records and Information Privacy Act 2002 (NSW).
Wests will only ever collect information about your vaccination status from you directly and with your express consent. We will not disclose your sensitive information to a third party without your consent except to our advisers or except where we are required or authorised to do so by law. Wests will securely destroy any sensitive information it retains about you once that information is no longer reasonably required by us for the purposes set out in this policy.
Is there surveillance at Wests’ premises?
All venues operated by Wests are subject to video and audio surveillance for security reasons, including to monitor the safety of members, guests and employees and to protect Wests’ 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 law enforcements agencies.
Do I have to use the electronic ID scanner to enter our clubs’ premises?
No. You are not obliged to scan your identification to enter our clubs’ premises.
If you prefer, you can manually enter your name, address and signature (as required by the Registered Clubs Act) into the terminal and present your identification to staff who will confirm your details.
What information is collected from the electronic ID scanners?
The electronic scanners used by our clubs may scan a full copy of your ID.
Where this applies, we may collect all of the information recorded on your ID (which may include sensitive information).
Why does Wests use ID scanners?
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 any of our clubs’ premises. This information must be retained by us for at least three years.
ID scanners are a secure way for us to collect information about persons entering our clubs’ premises.
ID scanners are also environmentally friendly in that they have helped us reduce our paper usage and storage of certain hardcopy records.
The collection of personal and sensitive information of the individuals who choose to scan their identification is reasonably necessary for the activities and functions of Wests’ clubs.
Are we likely to disclose personal information overseas?
Wests will generally not disclose your personal information overseas. However, if you agree to information being put on our websites or social media pages then this could be accessed by other countries.
Some of Wests’ third-party suppliers may be located overseas. For example, we occasionally use secure cloud servers. This involves the use of servers that may be located in other countries and may constitute a disclosure under the Privacy Act. As noted above, Wests will only disclose what Information is necessary to its third-party suppliers to enable Wests to carry out its functions and activities and will require that its third-party contractors comply with the Privacy Act.
What does this Policy mean?
By entering, visiting or dealing with any of Wests’ venues, you consent to the terms of this Policy. 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 Wests, please contact our Privacy Officer.
PROBLEMS OR QUERIES
If you have any questions about our Privacy Policy, or any problems or complaints regarding a possible breach of the Privacy Act or the APPs or how we have collected, used, stored, handled and/or disclosed your personal information, please contact our Privacy Officer via one of the following channels:
ADDRESS:
The Privacy Officer
Western Suburbs (Ncle) Leagues Club Limited
88 Hobart Road, New Lambton, NSW 2305
TELEPHONE: 02 4935 1420
EMAIL: privacyofficer@westsnewcastle.com.au
When contacting our Privacy Officer, please give us enough details to be able to identify you, understand your issue or complaint and respond appropriately. Please allow up to 30 days for us to respond. On receipt of your complaint, we will conduct a review and respond appropriately. If you are not happy with how we handle your query, problem or complaint, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact
details listed at www.oaic.gov.au/about-us/contact-us-page.