ATC ATC ATC ATC ATC

 

1.0 Policy Statement

Australian Turf Club (ATC) is a public company limited by guarantee with ASIC and a registered club governed by the Registered Clubs Act 1976. The Club is covered by the provisions of the Privacy Act 1998 (Cth).

The Club collects information in order to:

  • Process employee and potential employee information;
  • Process membership applications;
  • Meet statutory requirements under the Registered Clubs Act and other relevant legislation;
  • Contact members and guests about events and activities provided by the Club;
  • Promote its products, services and sponsors.

2.0 Purpose

The purpose of this Privacy Policy is to outline the way in which ATC collects, uses, discloses, stores and protects its stakeholder’s personal information.

For the purpose of this Policy, a ‘stakeholder’ is deemed to be any employee, contractor, member, guest or any other member of the general public.

ATC understands and appreciates that its stakeholders may be concerned about their privacy, the confidentiality and security of personal information including sensitive information ATC receives about them. ATC is committed to protecting all its stakeholders’ personal information including sensitive information and to comply with the Australian Privacy Principles in the Privacy Act 1988 (Cth). Information is known as “personal information” if the identity of the individual is apparent or can reasonably be ascertained. ‘ Sensitive information’ relates to information relating to health, racial or ethnic background, or criminal records.

Further information on privacy can be found on The Office of the Australian Information Commissioner website at www.oaic.gov.au

3.0 YOUR RIGHTS TO PRIVACY

ATC must comply with the Privacy Act 1988 which regulates, among other things, the collection, storage, quality, use and disclosure of personal information.

4.0 COLLECTION OF PERSONAL INFORMATION

The ATC collects and maintains different types of personal information of those individuals who seek to be, are, or were employed by ATC, including the personal information contained in, but not limited to:

  • Resumes and work applications;
  • References and interview notes;
  • Identified photographs and video;
  • Working With Children Checks (WWCC), Pre-Placement Medicals (PPM), Visa and Criminal Record checks;
  • Payroll information,including but not limited to Tax File Numbers, bank account and Superannuation details;
  • Salary and entitlement information;
  • Beneficiary and emergency contact information.

In addition, the ATC collects personal information about its stakeholders primarily from membership applications, renewal forms, raceday enquiries and race day or functions/events hospitality sales. ATC also collects personal information from owners, competitions and promotions, internet ticket sales, and from bookmakers and trainers wishing to conduct business at our racecourses. On some occasions, a recognised form of identification i.e. passport or drivers license will also be required to confirm personal details provided.

The personal information collected may include stakeholder’s name, contact details (including postal address, email address, telephone and facsimile numbers), date of birth, occupation, details of prior convictions, details of industry licenses held, credit card, defaulter and solvency details.

As part of its business operations, ATC often engages with third parties such as Australian Genetics Testing (AGT), Australian Pricing Network (APN) and Australian Stud Book (ASB). The Australian Stud Book (ASB) is owned and operated by ATC and the Victoria Racing Club. The ASB collects breeder, stallion and veterinary details, which information can be passed on as required to local and international industry participants as part of the business of operating the ASB. Stakeholders may elect not to have their personal information passed on to third parties such as these.

When or before ATC collects personal information,the Club will take reasonable steps to inform the stakeholder of:

  • the purpose for which the information is collected;
  • any law (where applicable) that requires the particular information to be collected, and
  • the main consequences for the user if all or part of the information is not provided.

5.0 USE AND DISCLOSURE OF INFORMATION

The personal information collected by the ATC covers all stakeholders. With regard to information about employees or potential employees, this is used and disclosed for the ATC’s business purposes, including establishing, managing or terminating employment relationships. Such uses include but are not limited to:

  • determining eligibility for initial employment, including the verification of references and qualifications;
  • administering pay and entitlements;
  • establishing a contact point in the event of an emergency (such as next of kin);
  • processing workers compensation/insurance claims;
  • establishing training and/or development requirements;
  • conducting performance reviews and determining performance requirements;
  • assessing qualifications for a particular job;
  • gathering evidence for disciplinary action, or termination;
  • compiling directories;
  • providing information to relevant external entities as required (ie. Superannuation funds, Australian Tax Office, etc.);
  • Club as permitted or required by applicable law or regulatory requirements. (In these circumstances, ATC will endeavour to not disclose more personal information than is required by law).

Personal information for all stakeholders is primarily collected for use in connection with conducting the businesses of ATC, ASB, AGT and APN. Such use include matters related to the processing of membership applications and renewal forms, membership referral forms, genera l administration and marketing activities of ATC. ATC also uses stakeholder personal information for the secondary purpose of business planning, membership development and providing individuals with information about promotions.

ATC will not use or disclose personal information to third parties other than for a purpose made known unless:

  • The disclosure is authorised or required by or under law (including but not limited to the Australian Privacy Principles under the Privacy Act 1988 {Cth);
  • a stakeholder has consented to the disclosure;
  • the use/disclosure is related to the primary purpose for which the information was collected and would reasonably expect the information to be so used/disclosed, but, if the personal information is sensitive, the disclosure must be directly related to the original collection purpose;
  • there are reasonable grounds to believe that disclosure is necessary to prevent a serious threat to a person’s health or safety; or
  • the disclosure is to relevant ATC third party service providers (such as insurance agents, government authorities, mail houses or ticketing agents) who provide ATC with services inconnection with the operation of ATC’s businesses.

If a stakeholder has provided their consent to the disclosure of personal information, they may withdraw that consent by contacting ATC in one of the ways set out in Section 10 of this Privacy Policy.

The third parties to whom we disclose persona l information may be located in Australia or other countries.The ATC takes steps to ensure that all our service providers agree to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.

6.0 STORAGE SECURITY OF PERSONAL INFORMATION

Except as otherwise permitted or required by applicable law or regulatory requirements, the ATC endeavours to retain personal information about any stakeholder the ATC has a relationship with only for as long as necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

The Australian Privacy Principles assert that an organisation must take reasonable steps to destroy or permanently de-identify personal information as if it is no longer needed for any purpose for which the information may be used or disclosed under Australian Privacy Principle 11. As such, the ATC will take all reasonable steps to ensure compliance with this principle as soon as practical.

ATC maintains strict standards and security procedures to prevent unauthorised access to personal information and to ensure correct use of personal information. ATC operates secure data networks protected by industry standard firewall and password protection. ATC takes all reasonable steps to ensure that personal information is secure on its systems. Only certain employees have access to the personal information provided to us and we impose strict rules on those employees who have access to personal information.

Employee data pertaining to Worker’s Compensation claims will be permanently archived.

The ATC will use its best endeavours to ensure that personal information is accurate, complete and up to date. ATC updates its details when it processes each membership renewal form. To assist us in keeping personal information up-to-date, stakeholders should contact ATC if any of the information provided to us changes or becomes incorrect. If a stakeholder believes the information the ATC has collected about them is inaccurate, incomplete or not up-to-date, they should contact ATC and all reasonable efforts will be made to correct that information.

Where appropriate, the ATC website provides a secure environment by using Secure Sockets Layer (SSL). This establishes a session, and encrypts all traffic, between ATC web server and a stakeholder’s browser. Stakeholders who chose to access their personal or mobile devices by utilising ATC supplied cables and/or wireless internet access should note the following information will be recorded:

  • IP and MAC addresses;
  • Connection logs that include timestamps of dates, data usage, source and destination, device name, wireless SSID and membership number;
  • Type of TCP/IP protocol used.

ATC will store any credit card details in a secure database but will retain this information for only so long as is necessary to fulfill the immediate purpose for which the information was collected or as required by law.

7.0 ACCESS TO PERSONAL INFORMATION

Stakeholders will always have access to personal Information they provided to the ATC. They may request the ATC to provide them with access to the personal information held about them at any time during standard business hours.

It is important for employees to note that information contained in ATC records remains accurate and current. If an employee’s personal information happens to change during the course of their employment, they are required to update their details via the Employee Self Service (ESS) platform or by contacting a representative from Payroll.

8.0 Changes to the Privacy Policy

ATC may make changes to this Privacy Policy from time to time for any reason. ATC will publish those changes on the ATC website by posting an updated version of the Privacy Policy on the ATC website. A stakeholder’s continued use of the ATC website indicates acceptance of the Privacy Policy on the ATC website at that time. In the event of a merger, acquisition, bankruptcy or other corporate restructure or reorganisation of ATC, the ATC may transfer a stakeholder’s personal information to the entity ATC merges with or is replaced by or it acquires or is acquired by. If such an event occurs, ATC will use all reasonable endeavours to ensure that personal Information will in every other respect remain under substantially the same terms as this Privacy Policy.

9.0 LINKS TO OTHER WEBSITES

The ATC website may contain links to other websites and this Privacy Policy has no application to those websites. Linked websites are not under the control of ATC and ATC is not responsible and has no liability in respect of the privacy practices or contents of other websites. Stakeholders should examine the privacy policies of t hose websites before they disc lose any of their persona l Information on them.

10.0 Contact the ATC about Privacy

For further information regarding this privacy policy or if a stakeholder believes ATC has breached any aspect of this Privacy Policy or the National Privacy Principles,please contact ATC Privacy Officer by:

  • Telephoning the ATC on 8622 6764 between standard business hours of 9.00 am and 5.00 pm Monday to Friday;or
  • Via email on privacyofficer@australianturfclub.com.au; or
  • Writing to the address: – Privacy Officer, Human Resource Business Partner, Australian Turf Club, Locked Bag 3, Randwick NSW 2031.

The ATC Privacy Officer will then:

  • acknowledge receipt in writing of the complaint;
  • conduct an assessment of the complaint;
  • if necessary, the ATC Privacy Officer or by engaging an appropriate investigator, will investigate the complaint further;
  • based on the results of the assessment and further investigations (if necessary), the ATC Privacy Officer will make a determination as to whether the ATC breached an Australian Privacy Principle;
  • if it is determined the ATC breached an Australian Privacy Principle, the ATC Privacy Officer will determine what action or remedy is to be taken and advise that decision to the person making the complaint within 30 days of receipt of the complaint if reasonably possible. The matter will then be closed
  • If the complaint is not satisfied with the outcome of the investigation or the process undertaken they can escalate to the Executive General Manager, Human Resources.

11.0 SUPPLEMENTARY ITEMS

When a stakeholder views the ATC website, the ATC’s Analytics Tags, our Internet Service Provider (ISP) & Google Analytics makes a record of your visit and logs the following information for statistical purposes:

  • your IP address;
  • your top level domain name (for example .com, .gov, .au, .uk etc);
  • the date and time of your visit to the site ;
  • the pages you accessed and documents downloaded;
  • the previous site you have visited ; and
  • the type of browser you are using.

11.1 Access to Information Collected

Employees and contractors should note that if they use ATC equipment, compliance with ATC Internet, Email and Computer Usage policy is mandatory. All internet sites and content accessed via ATC equipment can be traced and will be monitored.

The ATC will not make any attempt to identify external users or their browsing activities, however in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect our Internet Service Provider’s logs.

11.2 Use of Information Collected

If an ATC Member contacts the Membership Office via the Membership email address, the Membership System is updated with any new details the person may have provided. The original email is then deleted after 6 months

This site does not provide facilities for the secure transmission of information across the Internet. Users should be aware that there are inherent risks transmitting information across the Internet.

11.3 Cookies

11.3.1 General Overview

When you visit, access, or use the website, mobile site, application, electronic newsletter or widget that links to this Cookie Policy (collectively “Site”) the ATC and it’s entities (“ATC”, “us,” or “we”) use cookies and other tracking technologies to deliver and improve the Site, and to display relevant content, products, services and advertising.

This Cookie Policy explains these technologies, including cookies, local storage, pixels, web beacons, and flash cookies, and how you can control them. In this policy, we will refer to all these technologies as “Cookies”.

We hope that this Cookie Policy helps you understand, and feel more confident about, our use of Cookies. If you have any further queries or requests, please contact us at privacy@australianturfclub.com.au

By using the Site, you agree that we can use these Cookies as described in this Cookie Policy. We may change this Cookie Policy at any time. Please take a look at the Last Revised date at the end of this policy to see when this Cookie Policy was last revised. Any changes in this Cookie Policy will become effective when we make the revised Cookie Policy available on or through the Site.

11.3.2 What is a cookie?

Cookies and other tracking technologies (such as browser cookies and local storage, pixel beacons, and Adobe Flash technology including cookies) are comprised of small bits of data or code that often include a de-identified or anonymous unique identifier. Websites, apps and other services send this data to your browser (on your computer or mobile device) when you first request a web page and then store the data on your computer so that such websites, apps and other services can access information when you make subsequent requests for pages from that service. They are widely used in order to make websites work, or work in a better, more efficient way. For example, they can recognise you and remember important information that will make your use of a website more convenient (e.g., by remembering your user preferences).

11.3.3 What cookies do we use?

We use a variety of different types of Cookies on our Sites. Different Cookies have different specific purposes but in general they are all used so that we can improve your experience in using our Sites and interacting with us. Some of the purposes of different Cookies we use are described below.

(A) Some Cookies are essential to the Site in order to facilitate our log-in process and enable you to move around it and to use its features. Without these Cookies, we may not be able to provide certain services or features, and the Site will not perform as smoothly for you as we would like.

(B) We may use Cookies to allow us to remember the choices you make while browsing the Site, and to provide enhanced and more personalised content and features, such as customising a certain webpage, providing relevant advertising, remembering if we have asked you to participate in a promotion and for other services you request, like watching a video or commenting on a blog.

(C) We may use Cookies to receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. If you access the Site from a mobile or other device, we may collect a unique device identifier assigned to that device (“UDID”), geolocation data, or other transactional information for that device.

(D) We and our service providers and advertisers may use analytics Cookies, which are sometimes called performance cookies, to collect information about your use of the Site and enable us to improve the way it works. Analytics Cookies collect information about how you use the Site, for instance, which pages you go to most. The information allows us to see the overall patterns of usage on the Site, help us record any difficulties you have with the Site and show us whether our advertising is effective or not.

(E) We and our service providers and advertisers may use advertising Cookies to deliver ads that we believe are more relevant to you and your interests. For example, we may use targeting or advertising Cookies to limit the number of times you see the same ad on our Site, to help measure the effectiveness of our advertising campaigns as well as to customise the advertising and content you receive on our Site.

(F) Social plug-in tracking Cookies can be used to track both members and non-members of social networks for additional purposes such as behavioural advertising, analytics, and market research.

All information derived from these Cookies may be combined with other information acquired from third parties, and we may share this information with other organisations, such as advertisers, provided it is anonymised.

11.3.4 How do Third Parties use cookies on the site?

In some circumstances, we may work with third parties to provide certain services on our Site. For example, we use analytics services supported by third party companies who generate analytics Cookies on our behalf. We may not have access to these Cookies, although we may use statistical information arising from the Cookies provided by these third parties to customise content and for the other purposes described above. These companies may also transfer this information to other parties including where they are required to do so by law, or where such other parties process the information on their behalf.

Third-party advertisers and other organisations may also use their own Cookies to collect information about your activities on our Site and/or the advertisements you have clicked on. Advertisers and others who wish to do this should only do so in compliance with our Advertiser Data Policy or otherwise as approved by the ATC. Again, this information, which may be combined with other information acquired from third parties, may be used by them to serve advertisements on our Site and third party sites that they believe are most likely to be of interest to you based on content you have viewed.

Third-party advertisers may also use this information to measure the effectiveness of their advertisements and to track aggregate usage statistics.

We may not control these third-party Cookies and their use may be governed by the privacy policies of the third parties employing these Cookies. To learn about these Cookies and to disable or reject third-party Cookies, please refer to the relevant third party’s website.

11.3.5 How can you Opt-Out?

For more information about targeting and advertising cookies and how you can opt out, visit Your Online Choices:http://www.youronlinechoices.com.au (Last revised: 20 May 2015)

11.4 Unsolicited Personal Information

From time to time ATC employees may receive unsolicited information relating to a person (in particular resumes). This may be via electronic means or postal. The employee must take reasonable steps to destroy or de-identify this information as soon as practicable.

11.5 Photography and Filming on ATC Racecourse

In some circumstances an image of a person may amount to personal information. This is not always the case. The ATC commissions photographers to attend race days to capture images reflective of the activities and general environment at such events, including images of individuals. The intention always is that these images may be used at some stage to promote the ATC and its events and other business activities.

The ATC also liaises with the media for access to race days. This Privacy Policy does not regulate the activities of the media.

The terms and conditions of entry to the ATC racecourses stipulate that, in summary, the ATC may use images of race day patrons for promotional purposes

Last updated 28th August 2015

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