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Privacy policy

Last updated: 11 Oct 2025

Introduction
1. From time to time Surrey Park Swimming (the “Club”) is required to collect, hold, use and/or disclose personal information relating to individuals (including, but not limited to, its customers, contractors, suppliers and employees) in the performance of its business activities.
2. This document sets out the Club’s policy in relation to the protection of personal information, as under the Privacy Act 1988 (Cth) the (“Act”) and the Australian Privacy Principles (“APP”).
3. The Australian Privacy Principles regulate the handling of personal information.
What is personal information?
1. Personal information means information or an opinion (including information or an opinion forming part of a database), where 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.
Employee records
1. This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record.
2. An employee record is a record of personal information relating to the employment of an employee. Examples of personal information relating to the employment of the employee include, but are not limited to:
  1. Health information and information about the engagement
  2. Training, disciplining, resignation, and termination records
  3. Terms and conditions of employment of the employee.
  4. Please see the Act for further examples of employee records.
Information that the club collects and holds
1. The Club collects personal information that is reasonably necessary for one or more of its functions or activities.
2. The type of information that the Club collects and holds may depend on your relationship with the Club. For examples:
  1. Candidate: if you are a candidate seeking employment with the Club, the Club may collect and hold information including your name, address, email address, contact telephone number, gender, age, employment history, references, resume, medical history, emergency contact, taxation details, qualifications and payment details.
  2. Customer: if you are a customer of the Club, the Club may collect and hold information including your name, address, email address, contact telephone number, gender and age.
  3. Supplier: if you are a supplier of the Club, the Club may collect and hold information including your name, address, email address, contact telephone number, business records, billing information, information about goods and services supplied by you.
  4. Referee: if you are a referee of a candidate being considered for employment by the Club, the Club may collect and hold information including your name, contact details, current employment information and professional opinion of the candidate.
  5. Sensitive information: the Club will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Club’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious and philosophical beliefs, membership of trade unions, sexual preferences, criminal record, health information or genetic information.
How the club collects and holds personal information
1. The Club must collect personal information only by lawful and fair means. The Club will collect personal information directly from you if it is reasonably or practicable to do so.
2. The Club may collect personal information in a number of ways, including without limitation:
  1. Through application forms;
  2. By email or other written mechanisms;
  3. Over a telephone call;
  4. In person;
  5. Through transactions;
  6. Through our website;
  7. Through a surveillance camera;
  8. By technology that is used to support communications between us;
  9. Through publicly available information sources (which may include telephone directories, the internet and social media sites);
  10. Direct marketing database providers;
3. When the Club collects personal information about you through publicly available information sources, it will manage such information in accordance with the Australian Privacy Principles.
4. At or before the time or, if it is not reasonably practicable, as soon as practicable after, the Club collects personal information, the Club must take such steps as are reasonable in the circumstances to either notify you or otherwise ensure that you are made aware of the following:
  1. The identity and contact details of the Club;
  2. That the Club has collected personal information from someone other than you if you are unaware that such information has been collected;
  3. That collection of personal information is required by Australian law, if it is;
  4. The purpose for which the Club collects the personal information;
  5. The consequences if the Club does not collect some or all of the personal information;
  6. Any other third party to which the Club may disclose the personal information;
  7. The Club’s privacy policy contains information about how you may access and seek correction of personal information held by the Club and how you may complain about a breach of the Australian Privacy Principles; and
  8. Whether the Club is likely to disclose personal information to overseas recipients and the countries in which those recipients are likely to be located.
5. Unsolicited personal information is personal information that the Club receives which it did not solicit. Unless the Club determines that it could have collected the personal information in line with the Australian Privacy Principles or the information is contained within a Commonwealth record, it must destroy the information to ensure it is de-identified.
Purposes for which the club collects, holds, uses, and/or discloses personal information
1. The Club will collect personal information if it is reasonably necessary for one or more of its functions or activities.
2. The main purposes for which the Club may collect, hold, use and/or disclose personal information may include but are not limited to:
  1. Recruitment functions;
  2. Customer service management;
  3. Training and events;
  4. Surveys and general research; and
  5. Business relationship management.
3. The Club may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under law.
4. Direct marketing:
  1. The Club may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new goods and/or services being offered by the Club).
  2. The Club may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.
  3. You can opt out of receiving direct marketing communications from the Club by contacting the Privacy Officer in writing or if permissible accessing the Club’s website and unsubscribing appropriately.
Disclosure of personal information
1. The Club may disclose your personal information for any of the purposes for which it was collected, as indicated under clause 6 of this policy, or where it is under a legal duty to do so.
2. Disclosure will usually be internally and to related entities or to third parties such as contracted services suppliers.
3. Before the Club discloses personal information about you to a third party, the Club will take steps as are reasonable in the circumstances to ensure that the third party does not breach the Australian Privacy Principles in relation to the information.
Cross-border disclosure of personal information
1. The Club is likely to disclose personal information to overseas recipients.
2. Before the Club discloses personal information about you to an overseas recipient, the Club will take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information.
3. The countries in which overseas recipients are likely to be located include:
  1. New Zealand;
  2. United States of America;
  3. European Union;
  4. United Kingdom.
Access to personal information
1. If the Club holds personal information about you, you may request access to that information by putting a request in writing and sending it to the manager. The Club will respond to any request within a reasonable period, and a charge may apply for giving access to the personal information.
2. There are certain circumstances in which the Club may refuse to grant you access to the personal information. In such situations the Club will give you written notice that sets out:
  1. The reasons for the refusal; and
  2. The mechanisms available to you to make a complaint.
Correction of personal information
1. If the Club holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, it must take steps as are reasonable to correct the information.
2. If the Club holds personal information and you make a request in writing addressed to the Privacy Officer to correct the information, the Club must take steps as are reasonable to correct the information and the Club will respond to any request within a reasonable period.
3. There are certain circumstances in which the Club may refuse to correct the personal information. In such situations the Club will give you written notice that sets out:
  1. The reasons for the refusal; and
  2. The mechanisms available to you to make a complaint.
4. If the Club collects personal information that it has previously supplied to a third party and you request us to notify the third party of the correction, the Club will take such steps as are reasonable to give that notification unless impracticable or unlawful to do so.
Integrity and security of personal information
1. The Club will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that it:
  1. Collects is accurate, up-to-date and complete; and
  2. Uses or discloses is, having regard to the purpose of the use or disclose, accurate, up-to-date and complete.
2. The Club will take steps as are reasonable in the circumstances to protect the personal information from misuse, interference, loss and from unauthorised access, modification or disclosure.
3. If the Club holds personal information it no longer needs for any purpose which the information may be used or disclosed, and the information is not contained in any Commonwealth record and the Club is not required by law to retain it, the Club will take such steps as are reasonable in the circumstances to destroy the information or to ensure it is de-identified.
Anonymity and pseudonymity
1. You have the option of not identifying yourself, or using a pseudonym, when dealing with the Club in relation to a particular matter. This does not apply:
  1. Where the Club is required or authorised by or under Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
  2. Where it is impracticable for the Club to deal with individuals who have not identified themselves or who have used a pseudonym.
2. However, in some cases if you do not provide the Club with your personal information when requested, the Club may not be able to respond to your request or provide you with the goods or services that you are requesting.
Complaints
1. You have a right to complain about the Club’s handling of your personal information if you believe the Club has breached the Australian Privacy Principles.
2. If you wish to make such a complaint to the Club, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with the Club’s complaints procedure and the Club will provide a response within a reasonable period.
3. If you are unhappy with the Club’s response to your complaint you may refer your complaint to the Office of the Australian Information Commissioner.
Privacy officer contact details
1. The Club’s Privacy Officer can be contacted in the following ways:
  1. CEO
  2. Telephone number: 03 9898 8876
  3. Email address: manager@surreypark.org.au
  4. PO BOX 286, Box Hill, Victoria, 3128
Breach of this policy
1. Any employee who is found to have breached this policy may be subject to disciplinary action up to and including termination of employment.
Variations
1. This policy does not form part of any Employee’s contract of employment. The Club may vary, replace or terminate this policy from time to time.