Australian Ladies Professional Golf
ALPG Privacy Policy

Australian Ladies Professional Golf Incoporated is committed to protecting the privacy of individuals on whom it collects Personal Information.

This Privacy Policy covers Australian Ladies Professional Golf Incorporated (ABN 61 069 266 590) (ALPG). ALPG recognises that privacy is important and that an individual has the right to control his or her Personal Information.

ALPG’s Privacy Policy is based on the Australian Privacy Principles (NPPs) in the Privacy Act 1988 (Cth) and governs how ALPG handles the Personal Information ALPG collects, uses, discloses and stores on:

(a) Players and Officials (Participants);
(b) persons other than Participants that enter professional or amateur golf competitions owned, sanctioned or supported by ALPG;
(c) persons who register to any ALPG membership program or newsletter; and
(d) persons who purchase ALPG products or services, including raffle tickets or other promotions,
(collectively referred to as Members).

 

1. COLLECTION

1.1 ALPG will not collect Personal Information from a Member unless the information is necessary for one or more of ALPG’s functions or activities.

 

1.2 ALPG collects Personal Information about a Member for the following primary purposes:

(a) direct communication to a Participant, including for compliance with Regulations, registration, event or competition management and administration and development purposes;

(b) direct communication by ALPG to a Member, including for customer service, support, research and surveys, and product improvement;

(c) direct marketing (unless a Member has indicated that he or she does not want to receive any direct marketing communication from ALPG);

(d) disclosure to Partners (unless a Member has indicated that he or she does not want to receive any communication from Partners); and

(e) any other use that is obvious at the time the information is collected.

 

1.3 Where it is reasonable and practicable to do so, ALPG must collect Personal Information about Members only from the Member. If that Member is a Minor, ALPG may collect Personal Information from that Minor’s parent or legal guardian.

 

1.4 ALPG must collect Personal Information from a Member only through relevant forms approved by ALPG from time to time.

1.5 If ALPG collects Personal Information about a Member from someone other than the Member (or the Member’s parent or legal guardian), ALPG must take reasonable steps to ensure the Member is made aware of the matters listed in clause 1.6, except to the extent that making the individual aware of those matters would pose a serious threat to the life or health of any individual.

1.6 Before or at the time of collection of Personal Information (or if that is not practicable, as soon as practicable after), ALPG must take reasonable steps to ensure that the individual is aware of:

 

(a) the identity of ALPG and how to contact it;

(b) the fact that the Member can gain access to the information held on him or her;

(c) the purposes for which the information is collected;

(d) the organisations (or types of organisations) to which ALPG usually discloses information of that kind;

(e) any law that requires the information to be collected; and

(f) the main consequences (if any) for the Member if all or part of the information is not provided.

For the purposes of assisting compliance with this requirement, ALPG may keep a register of standard forms containing the required notice for the particular purpose for which the information is collected.

 

2. USE AND DISCLOSURE

2.1 ALPG will not use or disclose Personal Information about a Member for a purpose other than the primary purpose of collection (the secondary purpose) unless:

 

(a) the Member has consented to the use or disclosure;

(b) both of the following apply:

(i) the secondary purpose is related to the primary purpose of collection and, if the Personal Information is Sensitive Information, directly related to the primary purpose of collection; and

(ii) the Member would reasonably expect ALPG to use or disclose the information for the secondary purpose;

(c) ALPG reasonably believes that the use or disclosure is necessary to lessen or prevent:

(i) a serious and imminent threat to an individual’s life, health or safety; or

(ii) a serious threat to public health or public safety;

(d) ALPG has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the Personal Information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities;

(e) the use or disclosure is required or authorised by or under law; or

(f) ALPG reasonably believes that the use or disclosure is reasonably necessary for one or more of the purposes specified in NPPs by or on behalf of a law enforcement body. If ALPG uses or discloses Personal Information on this basis, it must make a written note of the use or disclosure.

 

2.2 ALPG may disclose Personal Information to advertising agents, ticketing agents, mailhouses or other similar organisations for the purpose of implementing the primary purposes. ALPG requires these organisations to keep contact details confidential and only use them for the designated purpose.

 

2.3 Despite clause 2.1, ALPG may disclose Health Information about a Participant to a person who is responsible for that Participant if:

 

(a) the Participant:

(i) is physically or legally incapable of giving consent to the disclosure; or

(ii) physically cannot communicate consent to the disclosure;

(b) a natural person (the carer) providing a health service for ALPG is satisfied that either:

(i) the disclosure is necessary to provide appropriate care or treatment of a Participant; or

(ii) the disclosure is made for compassionate reasons;

(c) the disclosure is not contrary to any wish:

(i) expressed by a Participant before a Participant became unable to give or communicate consent; and

(ii) of which the carer is aware, or of which the carer could reasonably be expected to be aware; and

(d) the disclosure is limited to the extent reasonable and necessary for a purpose mentioned in paragraph (b).

 

2.4 For the purposes of clause 2.3, a person is responsible for a Participant if the person is in relation to that Participant:

(a) a parent or guardian;

(b) a child or sibling and at least 18 years old;

(c) a spouse or de facto spouse;

(d) a relative, at least 18 years old and a member of the Participant’s household;

(e) exercising an enduring power of attorney granted by the Participant that is exercisable in relation to decisions about the Participant’s health;

(f) a person who has an intimate personal relationship with the Participant; or

(g) a person nominated by the Participant to be contacted in case of emergency.

 

In this clause:

child includes an adopted child, a step child and a foster child.

parent includes a step parent, adoptive parent and a foster parent.

relative means a grandparent, grandchild, uncle, aunt, nephew or niece.

sibling includes a half brother, half sister, adoptive brother, adoptive sister, step brother, step sister, foster brother and foster sister.

spouse includes a partner in a marriage, civil union, domestic partnership or common law marriage.

 

3. DATA QUALITY

ALPG will take reasonable steps to make sure that the Personal Information it collects, stores, uses or discloses is accurate, complete and up to date.

 

4. DATA SECURITY

4.1 ALPG will take reasonable steps to protect the Personal Information it holds from misuse and loss and from unauthorised access, modification or disclosure.

4.2 Whilst acknowledging that data transmission over the internet cannot be guaranteed as totally secure, ALPG does periodically review and update its security measures in light of new technology.

4.3 Where ALPG enters into a contract with any person and ALPG’s Personal Information about Members could be disclosed to or otherwise accessed by that contractor, ALPG must include provisions protecting privacy of that information in the contract. ALPG Executive Director must be consulted for more specific contractual provisions contemplating the disclosure of ALPG’s Personal Information on Members to contractors.

4.4 ALPG will take reasonable steps to destroy or permanently de identify Personal Information if it is no longer needed for any purpose for which the information may be used or disclosed under clause 2.

 

5. OPENNESS

5.1 On a Member’s request, ALPG will take reasonable steps to let that Member know, generally, what sort of Personal Information it holds, for what purposes, and how it collects, holds, uses and discloses that information. Generally, all such requests by Members should be directed to the ALPG Executive Director.

 

5.2 ALPG may set out in a document clearly expressed policies on its management of Personal Information.


6. ACCESS AND CORRECTION

6.1 ALPG will provide a Member with access to the Personal Information it holds on that Member on request by that Member, except to the extent that ALPG is not required to do so under NPPs.

6.2 In some cases, a Participant may access and edit his or her Personal Information by logging in to his or her ALPG account at any time.

6.3 All requests for access to and/or correction of Personal Information by a Member must be immediately directed to the ALPG Executive Director. In assessing the request for access and/or correction, the ALPG Executive Director must observe and comply with the procedures in clause 6 of this policy.

6.4 Before supplying any Personal Information to a Member ALPG must be reasonably satisfied as to the identity of the Member (for example, by asking to see the Member’s passport or driver’s licence).

 

7. IDENTIFIERS

7.1 ALPG will not adopt as its own identifier an identifier of a Member that has been assigned by a Commonwealth government agency or any person on behalf of a Commonwealth agency.

identifier includes a number assigned by an organisation to uniquely identify a Member for the purposes of the organisation’s operations. However, a Member’s name is not an identifier.

 

8. ANONYMITY

Wherever it is lawful and practicable, a Member will have the option of not identifying himself or herself when entering transactions with ALPG (other than as required for registration or competition administration purposes).

 

9. TRANSBORDER DATA FLOWS

9.1 ALPG may transfer Personal Information about a Member to someone who is in a foreign country only if:

 

(a) that Member consents to the transfer;

(b) the transfer is necessary for the performance of a contract between that Member and ALPG, or for the implementation of pre contractual measures taken in response to a Member’s request;

(c) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of that Member between ALPG and a third party;

(d) all of the following apply:

(i) the transfer is for the benefit of a Member;

(ii) it is impracticable to obtain the consent of a Member to that transfer; and

(iii) if it were practicable to obtain such consent, a Member would be likely to give it; or

(e) ALPG has taken reasonable steps to ensure that the information that it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the NPPs (for example, by adopting appropriate contractual clauses).

 

9.2 Clause 9.1 does not apply to ALPG clients based overseas or to the transfer of Personal Information in accordance with Regulations, including to facilitate the registration of a Participant by an international sports association or to an international competition.

 

10. SENSITIVE INFORMATION

10.1 ALPG will not collect Sensitive Information about a Member who is not also a Participant.

 

10.2 ALPG will not collect Sensitive Information about a Participant (except as permitted under NPPs), unless:

 

(a) specifically permitted to do so under Regulations, including for health, medical and anti-doping testing purposes and investigation of disputes or grievances;

(b) that Participant has consented;

(c) the collection is required by law;

(d) the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where that Participant:

(i) is physically or legally incapable of giving consent to the collection; or

(ii) physically cannot communicate consent to the collection; or

(e) the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

 

11. INQUIRIES PROCEDURE

11.1 All complaints and inquiries concerning Personal Information of a Member must be directed to gameon@alpg.com.au. This will ensure that all such matters will be dealt with:

 

(a) consistently across ALPG (rather than having a series of different approaches across ALPG); and

(b) in accordance with applicable law, including the Privacy Act.

 

12. DEFINITIONS AND INTERPRETATION

12.1 In this Policy:

Club means a club or team that is registered to, or affiliated with, a Competition or ALPG.

Club Official means any person involved with the administration, management or organisation of a Club (whether paid or unpaid), including employees, contractors, consultants, officers and directors and representatives.

Health Information means:

 

(a) information or an opinion about:

(i) a Member’s health or a disability (at any time);

(ii) a Member’s expressed wishes about the future provision of health services to a Member; or

(iii) a health service provided, or to be provided, to a Member,

that is also Personal Information;

(b) other Personal Information collected to provide, or in providing, a health service; or

(c) other Personal Information about a Member collected in connection with the donation, or intended donation, by that Member of his or her body parts, organs or body substances.

 

Official means:

 

(a) a Club Official or Team Official;

(b) an employee, consultant, officer or director of a Club; or

(c) a member of a council, committee, panel or body constituted by ALPG.

 

Partner mean any entity that has a sponsorship, advertising or other commercial relationship with ALPG from time to time.

 

Personal Information means information or an opinion (including forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

 

Player means any person who is, from time to time, registered to APLG as a professional female golfer.

 

Regulations means regulations as promulgated by ALPG or a Competition from time to time, including its constitution and by-laws, rules and regulations and policies and procedures.

 

Sensitive Information means:

 

(a) information or an opinion about a Member’s:

(i) racial or ethnic origin;

(ii) political opinions;

(iii) membership of a political association;

(iv) religious beliefs or affiliations;

(v) philosophical beliefs;

(vi) membership of a professional or trade association;

(vii) membership of a trade union;

(viii) sexual preferences or practices; or

(ix) criminal record,

that is also Personal Information; or

(b) Health Information.

 

Team Official means any personnel involved with the management, preparation or participation of a Player (whether paid or unpaid), including the coach, manager, medical and fitness staff, physiotherapists, and other support staff.

 

Tournament means any competition, championship, tournament, league or event that is either owned, sanctioned, affiliated or supported by ALPG.

 

12.2 Any terms or definitions used but not defined in this Policy have the meaning given to them in the Privacy Act 1988 (Cth).

 

12.3 ALPG will interpret all terms of this Privacy Policy and any such interpretation will be final and binding on every person.

 

12.4 This Privacy Policy is designed to safeguard privacy and to comply with the law and so may need to be varied or changed by ALPG from time to time. The most recent version is as notified on the ALPG website.

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