Palmerston Game Fishing Club (Inc) (PGFC) recognises the importance of protecting the privacy of personal information and sensitive information collected in a number of ways including:
- from publicly available sources of information;
- when you visit our website and / or via software, such as cookies and web or tracking pixels;
- from you directly;
- from third parties;
- from our own records at PGFC; and
- when legally required to do so.
Personal Information and Sensitive Information
Personal Information refers to information or an opinion about an identified individual or an individual who is reasonably identifiable.
Sensitive information refers to information or an opinion about an individual’s personal preferences and characteristics (such as race, ethnicity, political opinions, memberships, religious or philosophical beliefs and sexual preference), health information about an individual, genetic information and/or biometric information. Sensitive information is afforded a higher level of protection than other personal information.
Kinds of information held and collected by PGFC
Personal information held by us is collected only when knowingly and voluntarily submitted by you. When you register your interest or otherwise in the course of us providing our services to you, we may need to collect personal information which may include your name, address, telephone/mobile phone number, e-mail address, credit card details, your business name, your user ID or password.
Sensitive information held by us is collected only when knowingly and voluntarily submitted by you. Although we will rarely hold and/or collect this kind of information, the information we may hold includes your racial or ethnic background, your family status and/or financial information about you, such as your tax file number. At all times, we will take reasonable steps to obtain your express consent where we propose to handle your sensitive information.
Collecting information from you
- we will tell you why we are collecting information when we collect it and how we plan to use it or these things will be obvious when we collect the information; and
- we will only use your personal information if and when we need to contact you.
For example, we may need to collect such information to provide you with further services or to answer or forward any requests or enquiries. It is our intention that this policy will protect your personal information from being dealt with in any way that is inconsistent with applicable privacy laws in Australia.
If you choose not to provide personal information to us, we may not be able to provide you with access to the parts of this website or to certain content, products and services available on or from this website or generally from PGFC.
Use of Information
Purpose of collecting and holding information
We use your information to provide our services to you or to fulfil administrative functions associated with these services. Personal information is used only for the purpose for which it is submitted or for such other secondary purposes that are related to that purpose, unless we disclose other uses in this Privacy Statement or at the time of collection.
Primary purpose refers to the particular purpose for which the information in question was collected. For example, if we were to provide you with a newsletter and we asked for your address to send it to you, the primary purpose for the collection for your address would be to send the newsletter to you at your address.
Secondary purpose is any purpose other than the primary purpose for which we have collected your personal information. Personal information will only be disclosed or used for a secondary purpose where:
- you have consented to the use or disclosure;
- you would reasonably expect PGFC to use or disclose the information for that secondary purpose;
- the use of disclosure is required by or under an Australian law or a court/tribunal order;
- a ‘permitted general situation’ exists, such as lessening or preventing a serious threat to life, health or safety, locating a missing person or to undertake a confidential alternative dispute resolution process; and
- PGFC reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conduct by or behalf of an enforcement body.
We usually collect personal information such as your name, address, telephone number, and in some instances, some of your business details. When you are on our website, we may collect information regarding the pages within our network which you visited, what you clicked on and your IP address. As a general rule we do not collect sensitive information. However, if we do, it will usually be for the purposes of providing our services and if the law requires us to, we will seek your consent to collect it.
If you subscribe to receive promotional or other material from us or are registered for any services, then your personal information that you provide will be recorded. Your email address will only be used for the purpose for which you have provided it (which may include being added to our mailing list, but otherwise it will not be added to any other mailing lists.
Parties who will have access to personal information
Generally, your personal information will only be accessed by PGFC staff and officers when and where it is appropriate or necessary. However, your personal information may also be accessed, from time to time, by:
- PGFC contractors;
- financial consultants, accountants, lawyers and advisers, and representatives including executors, administrators, guardians, trustees, and attorneys;
- any person where we are required to do so by law; and
- any industry body, government authority, tribunal, court or otherwise in connection with any complaint brought against PGFC.
Where a party, other than an employee or officer of PGFC, has access to the personal information of individuals, they will be required to comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles and, where appropriate, to enter into privacy agreements with PGFC.
Use of Aggregate Data
We may use personal information in aggregate form to improve our services and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
Period for which records are held and Information Retention and Destruction Practices
We have a policy in place for determining whether we will retain or destroy records of personal information. We periodically review the records of the personal information we hold.
Where we have held such records for a number of years or have records for a project or plan which was completed a number of years ago in our possession, we will take reasonable steps to determine whether it is appropriate for PGFC to retain or destroy that information.
Anonymity or pseudonyms
Where we make use of personal information for statistical or marketing purposes, we will endeavour to make use of pseudonyms and/or to make the applicable personal details anonymous.
Holding personal and sensitive information and security
Holding information securely
We strive to ensure the security, integrity and privacy of personal and sensitive information of our clients. We use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss or unauthorised use or disclosure. In relation to personal information provided through our website, unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
Receipt of unsolicited personal information
Unsolicited personal information is information received by an APP entity where the entity has taken no active steps to collect the information.
When and where PGFC receives unsolicited information PGFC will need to determine whether it could have collected the information under Australian Privacy Principle 3 (which governs the collection of solicited personal information). Where PGFC could not have collected the information under Australian Privacy Principle 3, PGFC will destroy or de-identify the information as soon as practicable, so long as it is lawful and reasonable to do so in all the circumstances.
Accessing and correcting Personal Information
Accessing personal information
You have a right to access most personal information we hold about you. If you request access to your personal information, generally, we must we must give you access. If we deny access in some circumstances, we will tell you why.
You can make a request for access to your personal information under Australian Privacy Principles 12 or under the Freedom of Information Act 1992 (WA). Should you experience difficulty in determining the correct route by which to request access to your personal information, please contact us and we will provide you with assistance.
To request access, please contact our privacy officer as set out at the end of this document.
We reserve the right to charge a fee for locating and providing you with your personal information.
Correction personal information
You have a right to request the correction and/or amendment of your personal information. If you make a request, we must take reasonable steps to correct the errors in the personal information if we consider it is incorrect.
Applications to have personal information held by PGFC corrected or amended should be made in writing to the privacy officer (see details set out at the end of this document), should provide enough information to determine what changes are required and should provide current contact details.
- your server address;
- your to-level domain name (eg. .com, .gov, .uk, etc);
- the date and time of your visit to PGFC’s site;
- the pages accessed and documents downloaded by you;
- the previous site(s) visited by you; and
- the type of browser used by you.
PGFC will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any cookies, tracking / web pixels or Google advertising products or features, unless it has robust notice of and the relevant party’s consent to that merger.
PGFC’s website also makes use of third party cookies – these are cookies sent by businesses that provide content, such as advertising, on websites that you visit – that is, businesses other than PGFC. Third party cookies are used on PGFC’s website to enable remarketing and reporting for impression assisted visits, website conversions, user demographics and user interests.
The third party cookies used on PGFC’s website include, but are not limited to, Google Analytics Advertising Features (via the use of Google advertising cookies), cookies from YouTube and the Facebook tracking / web pixel.
If you want to opt out of the operation of third party cookies – such as those associated with the Google Analytics Advertising Feature – you will need to refer to the privacy policies of the relevant third party website(s).
Information that may be collected
Information provided to you
Information contained in any materials or products provided to you by any means including though use of our website may be subject to the Privacy Act and the must not be used for direct marketing of goods and services or be released to any person or third party for the purpose of direct marketing of goods and services. PGFC takes no responsibility for any breaches of the Privacy Act and the Australian Privacy Principles by any person in relation to information obtained from the material or products supplied to you by any means including through our website.
Via our website
In relation to use of our website, we may establish relationships with business partners that allow visitors to our website to link directly to sites operated by these partners. Some of these sites may be “co-branded” with our logo; however, these sites may not be operated or maintained by or on our behalf. These sites may collect personal information from you that may be shared with us. This Privacy Statement will apply to any personal information we obtain in this manner.
Generally PGFC has taken steps, and will continue to take steps, to ensure that and/or encourage any domestic third parties it has dealings with to comply with the Privacy Act and the Australian Privacy Principles when collecting, holding or using personal information provided to them by PGFC.
PGFC records all information posted to its social media pages and uses that information for the purposes of administering the pages, for record keeping, for considering and / or addressing any comments made and for running competitions and campaigns. No attempt will be made to further identify social media subscribers except where requested and authorised by law.
The social networking services may also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Twitter, Facebook and YouTube (a Google company) on their websites.
Likely overseas disclosure
It is not standard practice for PGFC to disclose personal information to overseas recipients. However, there is a possibility that, on occasion, your personal information may be disclosed to an overseas recipient. The location of any potential recipients will vary depending on the project or purpose concerned. Should you have any queries about the potential disclosure of your personal information to an overseas recipient, please contact our privacy officer set out at the end of this document.
PGFC will disclose personal information when it permits that information to become known outside PGFC and where it releases it from its effective control. For example, PGFC would be said to have ‘disclosed’ your personal information where:
- it shares that your personal information with another entity;
- it publishes your personal information on the internet so that it is accessible by others;
- where one of its staff reveals your personal information in the course of a conversation with a person who does not work for PGFC; or
- where one of its staffs sends a document containing your personal information to someone who is not you.
Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, personal information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose personal information when we believe in good faith that the law requires disclosure.
Notifiable data breaches
We are committed to protecting information we hold about you, and to compliance with the Notifiable Data Breaches scheme.
Where we become aware of a potential data breach which is likely to result in serious harm to any individuals about whom we hold information, we will:
- investigate the suspected breach and determine scope of any breach that has occurred and the risk of harm to affected individuals whose information may have been compromised;
- notify you and the Privacy Commissioner of the potential breach; and
- take steps to minimise any harm caused to affected individuals as a result of the breach.
Notification of Changes
If we decide to change this Privacy Statement, we will post those changes to our website and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
Problems or questions
If you have any queries relating to this Privacy Statement, or you have a problem or complaint, please contact PGFC.