Privacy Policy

This Privacy Policy explains how The Royal Sydney Golf Club Limited (ACN 000 872 542) (Club, we, us) collects, uses, stores and discloses your personal information, including in relation to our website located at www.rsgc.com.au (Website).

The Club complies with the Privacy Act 1988 (Cth) (Privacy Act), the applicable Australian Privacy Principles under the Privacy Act and any other applicable privacy laws when handling personal information. We take the protection of your personal information seriously.

In this Privacy Policy, personal information means any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not.

Consent
By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with and for the purposes specified in this Privacy Policy. You are not required to provide personal information to us.  However, if you do not provide us with all the information we request, the services we provide to you may be affected.

What kinds of personal information do we collect?
The kind of personal information we collect about you depends on your relationship with us – whether you are a member, a prospective member (or their close family member), a guest of a member, a member of a club with whom we have a special relationship or their guest, a contractor, an employee, or prospective employee or someone with whom we do business.

The kinds of information that we may collect include:

• your name, contact details (email address, telephone number and residential address), occupation, payment details (such as a credit card number), date of birth, driver’s licence or other form of identification, photograph, golf handicap, competition results, feedback and complaints, information about the time you spend at the Club, persons you contacted while at the Club and incidents at the Club for the management of the Club and safety of our members, health information (such as medical history and vaccination status), health insurer, emergency contact information (and next of kin);
• for prospective employees – your resume, employment history, qualifications, and other information required during the application or recruitment process. This may also include information arising from a police background check and working with children check; and
• when you use our Website – device and browsing information from session cookies.

We may also collect sensitive information about you or a member of your family (such as your child or grandchild). For example, when you attend the Fitness Centre or use the Fitness Centre Child Minding Service we may collect information about you or your child or grandchild’s health, or when you book or attend a function at our premises we may collect dietary information from you.

How do we collect personal information?
We may collect personal information:

• directly from you when you provide it to us or when you communicate with us. For example, when you, apply to become a member, complete forms or provide information to us by telephone, email or via our Website;
• when you register your details and sign in via a registration terminal when entering our premises;
• when you apply for a contract or a job with us; and
• via cookies on our Website.

For children aged under 18 years old, we may collect their personal information from a grandparent, parent or legal guardian.

In some circumstances, we may also collect information from third parties.  This will occur for example when we receive references from members nominating a candidate to become a member, or provide an opinion about a prospective member’s candidacy and where we receive personal information about the prospective member’s family; or for guests that attend our premises through their connection to one of our members, or where information is sought or provided by another registered club.  We also operate CCTV cameras on our premises for the safety of our members.  These CCTV cameras are operated and hosted internally by the Club.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy.

Why do we collect your personal information?
We collect personal information for the purpose of:

• establishing and administering your membership with us;
• arranging bookings for our sporting and dining facilities;
• conducting sporting competitions;
• managing, conducting, providing, assessing and improving our services;
• communicating with you about products and services which we think may be of interest to you;
• enhancing your browsing experience on our Website;
• considering and assessing your application for a role as a contractor or employee, and engaging or employing you; and
• complying with our legal obligations, including under the Corporations Act 2001 (Cth) (Corporations Act) and the Registered Clubs Act 1976 (NSW) (Registered Clubs Act).

We may also collect personal information for related purposes that would be reasonably expected by you.

To the extent that we collect government related identifiers (as defined in the Privacy Act), we will only use or disclose such information in accordance with the Australian Privacy Principles, for example to establish the identity of the individual or principal place of residence, or for employees to record a tax file number.

Who is your personal information disclosed to?
We may disclose your personal information to: sporting associations;

• other clubs with which we have a reciprocal or special relationship;
• our agents, contractors and suppliers who perform obligations on our behalf or provide services to us, such as accountants, auditors and lawyers, our insurers, website managers and software and other technology, social media and business service providers;
• the public to the extent that information is about the Club’s activities and is provided for inclusion in Club publications;
• anyone required or authorised by law; and
• anyone for whom you provide us with consent to disclose your personal information.

The Club is also required to maintain and retain registers relating to members and guests in accordance with the requirements of the Corporations Act and Registered Clubs Act. We also publish our members’ names and phone numbers on our website, which is updated annually and is made available to all of our members. If you do not wish to have your name published on our website, we request that you inform the Club in writing.

Where a member is a proposer or seconder for a prospective member, that member’s name is also included on scrutiny and election lists distributed to other members for comment. The election list is also posted on the Club’s Notice Board.

We may use your personal information to provide you with marketing information regarding services and offers that we think may be of interest to you. For example, this may include communications regarding wines at the Cellar Door, specials on sporting equipment and upcoming events. If you do not wish to receive communications from us, please follow the ‘unsubscribe’ instructions on the particular communication, or contact our Privacy Officer using the details listed in the ‘Contact Us’ section below.

Is your personal information disclosed overseas?
We may disclose your personal information to recipients located overseas where it is necessary for you to take advantage of the benefits offered by reciprocal clubs and other clubs with which we have a special relationship (such as when the Club sends a letter of introduction to an overseas club), or when we use an overseas provider to store employee information. It is not practicable to identify the countries in which recipients are likely to be located.

How is your personal information stored?
The Club stores your personal information on our servers, which includes an internal membership system with a Website interface (which is externally hosted with a web provider). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. Our precautions include:

• restricting access to personal information stored on the Club’s system;
• imposing confidentiality requirements on our employees;
• requiring that our contractors and agents take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure;
• implementing electronic security systems, such as firewalls and data encryption on our website;
• ensuring that servers containing our financial information have security measures such as password protection; and
• providing only controlled access at our offices.

The Club takes such steps as are reasonable in the circumstances to delete or de-identify personal information that is no longer needed.

How can you access and correct your personal information?
Subject to the exceptions set out in the Privacy Act, you have a right to access and seek correction of personal information that the Club holds about you.

We may recover from you reasonable costs of supplying you with access to your personal information. However, the Club will not charge you for the making of the request or to correct or update your personal information.

If you would like to access or correct your personal information, you may contact our Privacy Officer using the details listed in the ‘Contact Us’ section below. Your request will be addressed as soon as reasonably practicable.

If the Club refuses to provide you with access to, or to correct your personal information, it will generally notify you of the reasons for refusal to the extent required and explain how you can complain about the refusal.

How to complain about a privacy breach?
If you believe the Club has breached the Australian Privacy Principles or have any other privacy related concerns, you may contact our Privacy Officer using the details listed in the ‘Contact Us’ section below. We may request that you put your complaint in writing. We will then endeavour to resolve your complaint within 30 days.

If we are unable to satisfactorily resolve your concern or complaint, you can contact the Office of the Australian Information Commissioner (OAIC). To make a query concerning your privacy rights, or to lodge a complaint with the OAIC about how we have handled your personal information, you can contact the Commissioner’s hotline on 1300 363 992. The OAIC has the power to investigate the matter and make a determination.

GDPR
If you are a member or reciprocal club member who resides in the European Union (EU) (including the European Economic Area), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (GDPR). In providing our services to you, we may collect and process personal information as outlined in this Privacy Policy. Otherwise, including for individual users of our services, we will be a data controller for the purposes of the GDPR and this Privacy Policy includes information that must be provided to you when we collect your personal information.

Changes to this Privacy Policy
We may, from time to time, amend this Privacy Policy, in whole or part, in our sole discretion.  Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on the Website or by email to members.  However, in any event, by continuing to access our services following any changes, you will be deemed to have agreed to such changes.

Contact Us
Our Privacy Officer can be contacted by mail, phone, or email:

Office of the CEO
The Royal Sydney Golf Club
Kent Road
Rose Bay, NSW 2029
Australia
Attention: The Privacy Officer

Phone: +61 8362 7000
Email: privacy.officer@rsgc.com.au

Last updated on: 21st December 2021