Western Bulldogs - Privacy Policy
1. INTRODUCTION
The Western Bulldogs (WB) operates as an elite Australian Football Club governed by the Australian Football League (WB). The WB compete within the AFL competition in Australia. Through varied operations, the WB from time to time gathers information from Members and other parties with whom we deal for a variety of reasons including, in particular, to enable us to improve the nature of the services we provide. WB understands individuals’ concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers. To safeguard that information, WB has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the National Privacy Principles (“NPPs”). This Privacy Policy outlines how WB deals with Personal Information.
2. WHY WESTERN BULLDOGS COLLECTS PERSONAL INFORMATION
2.1 Nature of Information
The information WB collects in most cases relates to Members but can relate to suppliers, sponsors and other parties we deal with (for the purposes of this Privacy Policy all such people are described as “Members”). Information is gathered for a range of purposes, including the provision of ongoing Members support and the compiling of Member databases to enable us to provide you with the services you request and helps us plan to improve the level of our services. The type of information we collect includes such things as contact details, opinions and transactional details and may include your name, date of birth, current and previous address, telephone and facsimile number, e-mail address, bank account or credit card details and occupation. We also hold details of WB services you hold or join including their status. WB treats all such information which is collected and identifiable as relating to an individual as Personal Information. It is this information which is described as “Personal Information” for the purposes of this Privacy Policy.
2.2 Collection of Information
In accordance with the NPPs, where practical, Members of WB may deal with WB on an anonymous basis. However, as a provider of a wide range of services, WB frequently finds that it is necessary to collect Personal Information during the course of transactions. Personal Information may be collected about Members via the following means:
(a) competition entry forms;
(b) application forms;
(c) email;
(d) websites (including in some instances cookies);
(e) online transactions;
(f) networking functions (eg: business cards);
(g) over the phone;
(h) credit card details via credit card purchases; and
(i) information collected from third parties.
2.3 Information given to Members .
Where WB collects Personal Information about a Member from a third party, and the Member has not previously consented to that third party providing the information to WB,WB will, where reasonable and practical, provide the Member with the following information about that third party:
(a) the third party’s contact details;
(b) the purpose of collection;
(c) the fact that the Member can gain access to the Personal Information;
(d) the types of organisations to which their Personal Information may be disclosed by that third party;
(e) any law that requires the Personal Information to be collected; and
(f) the key consequences if all or some of the information cannot be collected.
2.4 ‘sensitive information’
WB will not ask a Member for information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation, unless:
(a) the Member provides their consent;
(b) the collection of that information is specifically authorised by law;
(c) the collection is necessary to lessen a serious or imminent threat to the health or safety of a person; or
(d) the collection of the information is necessary for the establishment, exercise or defence of a legal claim.
2.5 Member consent
Wherever practical, WB will obtain the express consent of Members to the collection of Personal Information.
In some situations, WB will interpret a Member’s actions as indicating that a Member consents to the collection of Personal Information. This may occur where the Member has provided Personal Information for a particular purpose and that purpose cannot be achieved without WB making use of the Member’s Personal Information.
2.6 What happens if Personal Information is not provided
Where relevant, WB will endeavour to make Members aware that WB may not be able to provide a proper service to them if Personal Information is not provided upon request.
3. MAINTENANCE AND MANAGEMENT OF PERSONAL INFORMATION
3.1 Who may view Personal Information
In general, only officers, employees or contractors of WB may view Personal Information. WB will only grant access to parties other than WB’s officers, employees and contractors to view Personal Information where WB believes that access is necessary to achieve the purpose for which the Personal Information was collected.
WB will only disclose Personal Information to parties other than WB’s officers, employees and contractors if:
(a) that disclosure is required to give effect to the purposes for which WB collected the Personal Information;
(b) the Member has consented to that disclosure;
(c) WB believes that the disclosure may lessen a risk of harm to the health or safety of any person;
(d) WB believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of WB’s investigation into this activity;
(e) WB is required by law to disclose the Personal Information; or
(f) the disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue.
3.2 Identification
WB does not use any prohibited identifiers (such as a tax file number) to identify its Members.
3.3 Storage and Security
Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password protected.
Where possible and practical, WB will endeavour to comply with recognised Australian and international standards relating to information security.
WB regularly deletes and de-identifies Personal Information if the information is no longer needed by WB.
3.4 Updating Personal Information
WB regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis.
Members can update their Personal Information at any time by contacting WB’s Privacy Officer.
4. MINORS
WB has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed.
Where WB is aware that it is gathering information from a minor, WB will obtain consent from a legal guardian for the collection of the information. Where this is not possible, WB’s staff will make a determination as to the minor’s understanding of why the Personal Information is being collected, before deciding to collect that information.
5. COMPETITIONS
Personal information gathered during competitions run by WB will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.
6. DIRECT MARKETING
Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Member as provided for in this Privacy Policy.
In circumstances where WB cannot practically obtain the consent of a Member, then WB may still engage in direct marketing to that Member, but will:
(a) advise the Member that he or she can be taken off the mailing list at any time; and
(b) display its contact details clearly in each direct marketing publication.
Members may be taken off any mailing list by contacting WB’s Membership Services.
7. ACCESS TO PERSONAL INFORMATION
Members may access their Personal Information by contacting WB’s Membership Services. Access is generally granted within 30 days of that request.
WB may impose a reasonable charge for access.
8. WHEN WESTERN BULLDOGS MAY WITHHOLD ACCESS TO PERSONAL INFORMATION
8.1 When access can be withheld
Access to Personal Information may be withheld in a number of circumstances. These include where:
(a) providing access would pose a serious and imminent threat to the life or health of a person;
(b) providing access would have an unreasonable impact on the privacy of others;
(c) the information is subject to confidentiality where the person who provided the information to WB did so expressly on the condition that it remains confidential;
(d) the request is vexatious or frivolous;
(e) the information relates to current or anticipated legal proceedings between WB and the person and the information would not be required to be discovered to a court;
(f) WB is in commercial negotiations with the person and the information would reveal WB’s intentions;
(g) providing access would be unlawful or WB is required by a law to withhold access; or
(h) providing access could prejudice the investigation or detection by WB or by a government body of an unlawful activity or some serious or improper misconduct.
Where WB does withhold Personal Information, WB may instead choose to give the Member a summary of that information.
8.2 Written reasons
If WB does withhold Personal Information, WB will provide written reasons.
8.3 Third party intermediary
If WB withholds access to Personal Information, WB will consider whether the provision of access to an independent third party will meet WB’s and the relevant Member’s needs.
9. CONTRACTORS
WB may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy Policy applies equally to those subcontractors.
10. SPONSORS
WB may enter sponsorship agreements with sponsors. In these situations, Personal Information may be collected about those sponsors. This Privacy Policy applies equally to those sponsors.
11. WHO TO CONTACT
If you have any queries with respect to this Privacy Policy please contact Membership Services at Western Bulldogs, PO Box 417 DC Footscray West Victoria 3012.
12. MODIFICATIONS TO THIS DOCUMENT
WB may modify this Privacy Policy and the way it handles Personal Information at any time in its sole discretion.
13. FURTHER INFORMATION
Further information on privacy can be obtained from the Privacy Commissioner at www.privacy.gov.au.
