1.0 Policy Statement
ATC 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 ATC;
- Promote its products, services and sponsors.
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 who visits ATC’s various premises and/or it and its associated entities websites and social media accounts (Websites and Social Media Accounts).
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 (APPs) 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, ATC collects personal information about its stakeholders primarily from the stakeholder though membership applications, renewal forms, race day enquiries and race day or functions/events hospitality sales.
ATC also collects personal information from:
- owners, bookmakers and trainers wishing to conduct business at its racecourses;
- participants in competitions and promotions
- stakeholder’s social media account(s) when you use a tag that relates to ATC or the Races in your social media posts and/or uploads or otherwise share content with ATC;
- internet ticket sales;
- from social media and/or marketing agencies that we may use from time to time;
- from ATC’s Website and Social Media Accounts; and
- from publicly available resources.
On some occasions, a recognised form of identification i.e. passport or driver’s licence 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, social media account(s) and any posts, uploads and/or photographs uploaded to the stakeholder’s various social media accounts including the stakeholder’s location when using various social media accounts, 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 ATC 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.
ATC’s ability to meet its obligations to its stakeholders, including to process any membership applications, renewal forms and/or race day enquiries may be adversely affected if the stakeholder does not provide ATC with the requested personal information, of if the information provided is incomplete or inaccurate.
5.0 USE AND DISCLOSURE OF INFORMATION
The personal information collected by ATC covers all stakeholders. With regard to information about employees or potential employees, this is used and disclosed for 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.);
- 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 and APN. Such use include matters related to the processing of membership applications and renewal forms, membership referral forms, general administration and marketing activities of ATC. ATC also uses stakeholder personal information for the secondary purposes of business planning, membership development, administering and managing the content of ATC’s Websites and Social Media Accounts and providing individuals with information about promotions.
If ATC intends to use a stakeholders’ personal information for direct marketing, such as by adding the stakeholder’s personal information to a marketing database, and the stakeholder has not already consented to this use, ATC will notify the stakeholder and will provide him or her an opportunity to opt-out.
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 in connection with the operation of ATC’s businesses.
ATC takes all reasonable steps, in the circumstances, to ensure that all our service providers do not breach privacy laws in relation to that information and agree to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.
ATC is not likely to disclose personal information to overseas recipients, and will only do so in accordance with the Privacy Act.
6.0 STORAGE SECURITY OF PERSONAL INFORMATION
Except as otherwise permitted or required by applicable law or regulatory requirements, ATC endeavours to retain personal information about any stakeholder ATC has a relationship with only for as long as necessary to fulfil 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 APPs 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 APP 11. As such, 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 ATC 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.
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. See section 7.0 below for more information about the correction of your personal information.
Where appropriate, ATC’s website provides a secure environment by using Secure Sockets Layer (SSL). This establishes a session, and encrypts all traffic, between ATC’s 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 fulfil 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 ATC. They may request ATC to provide them with access to the personal information held about them at any time during standard business hours.
ATC will comply with any request by a stakeholder to access their personal information except where the Privacy Act 1988 or the APPs allows it to refuse to do so. There is no fee for making a request to access personal information but the ATC may charge a fee for giving the stakeholder access to their personal information in a mutually agreed format, usually by sighting the accessible information on file. A stakeholder also has the right to ask ATC to correct information about the stakeholder that is inaccurate, incomplete, out-of-date, irrelevant or misleading. If ATC refuses to correct the stakeholder’s personal information as requested, ATC must:
- notify the stakeholder in writing of the reasons for the refusal (unless it would be unreasonable to do so) and how to complain of the refusal; and
- upon request from the stakeholder that ATC associates a statement that the information is inaccurate, incomplete, out-of-date, irrelevant or misleading, take such steps are as reasonable in the circumstances to associate such a statement so that it will be apparent to users of the information.
It is important for employees to note that personal information about them contained in ATC records will usually be the subject of an exemption under the Privacy Act that applies to employee records. Employees do not have the right to access or seek correction of these records. 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.
9.0 LINKS TO OTHER WEBSITES
The links contained in ATC’s websites should in no way be construed as an endorsement, approval or recommendation by ATC of the owners or operators of the linked websites or of the content, products or services contained on or referred to by the linked websites.
10.0 Contact the ATC about Privacy
- Telephoning ATC on 8622 6764 between standard business hours of 9.00 am and 5.00 pm Monday to Friday; or
- Via email on email@example.com; or
- Writing to the address: – Privacy Officer, Human Resource Business Partner, Australian Turf Club, Locked Bag 3, Randwick NSW 2031.
ATC’s Privacy Officer will then:
- acknowledge receipt in writing of the complaint;
- conduct an assessment of the complaint;
- if necessary, ATC’s 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), ATC’s Privacy Officer will make a determination as to whether ATC breached an APP;
- if it is determined ATC breached an APP, ATC’s Privacy Officer will determine what action or remedy is to be taken and advise the 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 Australian Privacy Commissioner
If any stakeholders are not satisfied with the way in which ATC handled their enquiry or complaint, they can contact the Office of the Australian Privacy Commissioner on Tel: 1300 363 992 or email: firstname.lastname@example.org.
12.0 SUPPLEMENTARY ITEMS
When a stakeholder views ATC’s Website and Social Media Accounts, 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.
12.1 Access to Information Collected
Employees and contractors should note that if they use ATC equipment, compliance with ATC’s Internet, Email and Computer Usage Policy is mandatory. All internet sites and content accessed via ATC equipment can be traced and will be monitored.
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.
12.2 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.
12.3.1 General Overview
12.3.2 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).
12.3.3 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.
(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.
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 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.
12.3.5 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)
12.4 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.
12.5 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. 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 ATC and its events and other business activities including by way of its Websites and Social Media Accounts.
The terms and conditions of entry to ATC racecourses stipulate that, in summary, ATC may use images of race day patrons for promotional purposes