1. Purpose
Cabra-Vale Diggers is committed to providing exceptional customer service. Cabra-Vale Diggers recognises that protecting an individual’s privacy and making them aware of this privacy policy is part of this commitment.
The Cabra-Vale Diggers Group provide premium hospitality and entertainment venues to members and guests. This policy sets out the approach which the Cabra-Vale Diggers group takes in relation to the treatment of Personal Information. This includes Campbelltown RSL and Cabra-Vale Diggers.
This policy includes information on how Cabra-Vale collects, uses, discloses and keeps secure, individuals’ personal information. It also sets out how Cabra-Vale Diggers makes the personal information it holds available for access to and correction by the relevant individual.
2. Personal Data
Personal data refers to any information or opinion relating to an identified or identifiable natural person. This includes personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or any further categories as defined by Article 9 of the EU General Data Protection Regulation.
3. How Cabra-Vale Diggers collects and stores personal information
Cabra-Vale Diggers only collects and stores personal information where it is necessary to do so in order to perform one or more of its functions or activities, and in accordance with this Privacy Policy.
Cabra-Vale Diggers collects information from individuals by various means including, without limitation, by individuals completing membership application or renewal forms, mailing subscription, entry into competitions and promotions and via access to our websites, in venue Wi- Fi and social media pages.
Cabra-Vale Diggers collects personal information primarily to supply individuals who obtain products or services with information and details of our products and services. The Group also collects and uses personal information for the secondary purpose of:
- provision of products and services.
- accounting purposes; and
- business planning as well as product and service development.
Cabra-Vale Diggers is also required to collect and store certain member information in accordance with the Registered and Licensed Clubs Act 1976 (NSW). Cabra-Vale Diggers is unable to allow individuals to join the club or to be a temporary member, unless they have provided the required personal information.
4. Use of personal information
Cabra-Vale Diggers uses personal information primarily for the purposes listed above.
Where Cabra-Vale Diggers utilises direct marketing to individuals it will ensure that individuals are clearly notified of their right to opt out from further direct marketing.
We will not use personal information without taking reasonable steps to ensure that the information is accurate, complete, and up to date.
Cabra-Vale Diggers has a designated data protection officer, being the IT Manager in conjunction with the Marketing Manager, who are responsible for the protection and monitoring of the use of personal data held by Cabra-Vale Diggers.
5. Disclosure of personal information
From time to time, Cabra-Vale Diggers may disclose personal information to related or unrelated third parties.
Cabra-Vale Diggers may disclose personal information to unrelated third parties to enable outsourcing of functions where that disclosure or use is for a related secondary purpose and has been notified to individuals or where such disclose is within the individual’s reasonable expectations.
Cabra-Vale Diggers will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclose requirements of the Privacy Act 1988 (Cth).
In the rare event that Cabra-Vale Diggers is required to disclose personal information to law enforcement agencies, government agencies or external advisors, Cabra-Vale Diggers will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
Individuals have the right to request that their personal data is only used or disclosed in limited circumstances, including where the individual’s consent is provided explicitly.
6. Information Quality
Cabra-Vale Diggers reviews, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
We will take steps to de-identify or destroy personal information that is no longer needed for a primary or secondary purpose after a maximum of seven years, unless the law requires otherwise.
7. Security of personal information
Access to personal information in electronic or hard copy form is provided to a limited number of Cabra-Vale Diggers staff whose roles require access to such information.
Cabra-Vale Diggers will review, on a regular and ongoing basis, its information security practices to ascertain how compliance with its ongoing responsibilities are maintained.
Cabra-Vale Diggers will ensure that it only uses third party data processors who provide sufficient guarantees that they implement technical and organisational measures to ensure compliance with the EU General Data Protection Regulation thereby protecting the rights of all individuals of which personal information is held.
8. Access and correction of personal information held by Cabra-Vale Diggers
Cabra-Vale Diggers will allow its records containing personal information to be accessed by the individual concerned in accordance with the Privacy Act.
Cabra-Vale Diggers will correct its records containing personal information as soon as practically possible, at the request of the individual concerned, in accordance with the Privacy Act.
Individuals wishing to lodge a request to access and/or correct their personal information should do so by contacting a member of the Membership Team.
Subject to State and Federal legislation reporting and data retention requirements, individual also have the right to erasure (i.e. having their details removed from Cabra-Vale Diggers systems) where the information is no longer necessary for the purpose for which it was collected, or where the individual withdraws their consent and there is no longer a legal ground for processing their data.
9. Complaints
Contact with Cabra-Vale Diggers’s membership team via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
Any formal privacy related complaints should be directed in writing to Cabra-Vale Diggers’s. Such correspondence will be responded do within 7 business days.
The contact details for Cabra-Vale Diggers’s are as follows:
Cabra-Vale Diggers Club Ltd
1 Bartley Street, Canley Vale NSW 2126
Ph: 02 9727 3600 Email: mail@cabravale.com
10. Transferring personal information overseas
Cabra-Vale Diggers generally does not send personal information overseas.
However, from time to time, Cabra-Vale Diggers may send your information overseas to service providers or other third parties who operate or hold data outside Australia. Where this occurs, Cabra-Vale Diggers will make sure that appropriate data handling and security arrangements are in place. Please note that Australian law may not operate to some of these entities.
11. Suspected Data Breaches
Cabra-Vale Diggers takes unauthorised access or disclosure of personal information very seriously and uses its best endeavours to ensure that a data breach does not occur.
In the event of a suspected data breach, Cabra-Vale Diggers has an established Data Breach Response Plan in place in accordance with the Privacy Amendment (Notifiable Data Breaches) Act 2017.