Protecting your privacy

The Hawthorn Football Club is committed to providing you with the highest levels of customer service. This includes protecting your privacy.

Set out below is information that we are required to communicate to our members and customers. We recommend that you keep this information for future reference.

Help us to ensure we hold accurate information

We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. 



However, the accuracy of that information depends to a large extent on the information you provide. That's why we recommend that you:
•    let us know if there are any errors in your personal information; and
•    keep us up-to-date with changes to your personal information such as your name or address. If you are a subscriber to one of our online products or services, you may change your personal details by using the relevant facility on our website.

1.    INTRODUCTION 
The principal activities of the Hawthorn Football Club Limited (“HFC”) are to compete within the Australian Football League by maintaining, supporting and controlling a team of footballers bearing the name of the Hawthorn Football Club. The Hawthorn Football Club from time to time gathers information from Customers and other parties with whom we deal for a variety of reasons including, in particular, to enable us to both deliver our services and to improve the nature of the services we provide. 

HFC understands individuals’ concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers. 

To safeguard that information, HFC has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the National Privacy Principles (“NPPs”). This Privacy Policy forms part of that compliance program and outlines how HFC deals with Personal Information.

2.    WHY HAWTHORN FOOTBALL CLUB COLLECTS PERSONAL INFORMATION
2.1    Nature of Information 
The information HFC collects in most cases relates to members and customers of HawksNest but can relate to suppliers and other parties we deal with (for the purposes of this Privacy Policy all such people are described as “Customers”). Information is gathered for a range of purposes, including the provision of ongoing Customer support and the compiling of Customer databases to enable us to provide you with the services you request and helps us plan to improve the level of our services. The type of information we collect includes such things as contact details, opinions and transactional details and may include your name, date of birth, current and previous address, telephone and facsimile number, e-mail address, bank account or credit card details and occupation. We also hold details of HFC services you hold or join including their status.  HFC treats all such information which is collected and identifiable as relating to an individual as Personal Information. It is this information which is described as “Personal Information” for the purposes of this Privacy Policy.

2.2    Collection of Personal Information 
In accordance with the NPPs, where practical, Customers of HFC may deal with HFC on an anonymous basis. However, as a provider of a wide range of services, HFC frequently finds that it is necessary to collect Personal Information during the course of providing our services. 

Personal Information may be collected about Customers via the following means:
(a)    competition entry forms;
(b)    application forms;
(c)    email;
(d)    websites (including in some instances cookies);
(e)    online transactions;
(f)    networking functions (eg: business cards);
(g)    over the phone;
(h)    credit card details via credit card purchases; and
(i)    information collected from third parties.
Where any law requires HFC to collect Personal Information from the Customer, HFC will endeavour to advise you about the requirements of that law.


2.3    Information given to Customers.
Where HFC collects Personal Information about a Customer from a third party, and the Customer has not previously consented to that third party providing the information to HFC, HFC will, where reasonable and practical, provide the Customer with the following information about that third party:
(a)    the third party’s contact details;
(b)    the purpose of collection;
(c)    the fact that the Customer can gain access to the Personal Information;
(d)    the types of organisations to which their Personal Information may be disclosed by that third party;
(e)    any law that requires the Personal Information to be collected; and
(f)    the key consequences if all or some of the information cannot be collected.

2.4    ‘sensitive information’
HFC in providing its services will need to collect certain information from you.  HFC will only ask you for information where HFC believes it is necessary to know that information in the course of providing these services.
HFC will not ask a Customer for information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation, unless:
(a)    the Customer provides their consent;
(b)    the collection of that information is specifically authorised by law;
(c)    the collection is necessary to lessen a serious or imminent threat to the health or safety of a person; or
(d)    the collection of the information is necessary for the establishment, exercise or defense of a legal claim.

2.5    Customer consent
Wherever practical, HFC will obtain the express consent of Customers to the collection of Personal Information.

In some situations, HFC will interpret a Customer’s actions as indicating that a Customer consents to the collection of Personal Information. This may occur where the Customer has provided Personal Information for a particular purpose and that purpose cannot be achieved without HFC making use of the Customer’s Personal Information.

2.6    What happens if Personal Information is not provided?
Where relevant, HFC will endeavor to make Customers aware that HFC may not be able to provide a proper level of service to them if Personal Information is not provided upon request.

3.    MAINTENANCE AND MANAGEMENT OF PERSONAL INFORMATION
3.1    Who may view Personal Information? 

In general, only officers, employees or contractors of HFC may view Personal Information. HFC will only grant access to parties other than HFC’s officers, employees and contractors to view Personal Information where HFC believes that access is necessary to achieve the purpose for which the Personal Information was collected.

HFC will only disclose Personal Information to parties other than HFC’s officers, employees and contractors if:
(a)    That disclosure is required to give effect to the purposes for which HFC collected the Personal Information;
(b)    The Customer has consented to that disclosure;
(c)    HFC believes that the disclosure may lessen a risk of harm to the health or safety of any person;
(d)    HFC believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of HFC’s investigation into this activity;
(e)    HFC is required by law to disclose the Personal Information; or
(f)    The disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue.

3.2    Identification
HFC does not use any prohibited identifiers (such as a tax file number) to identify its Customers.

3.3    Storage and Security
Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password protected.

Where possible and practical, HFC will endeavor to comply with recognised Australian and international standards relating to information security.

HFC regularly deletes and de-identifies Personal Information if the information is no longer needed by HFC.

3.4    Updating Personal Information
HFC regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis.

Customers can update their Personal Information at any time by contacting HFC’s Privacy Officer.

4.    MINORS
HFC has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed.

Where HFC is aware that it is gathering information from a minor, HFC will obtain consent from a legal guardian for the collection of the information. Where this is not possible, HFC staff will make a determination as to the minor’s understanding of why the Personal Information is being collected, before deciding to collect that information.

5.    COMPETITIONS
Personal information gathered during competitions run by HFC will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.

6.    DIRECT MARKETING
Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Customer as provided for in this Privacy Policy. 

In circumstances where HFC cannot practically obtain the consent of a Customer, then HFC may still engage in direct marketing to that Customer, but will:
(a)    advise the Customer that he or she can be taken off the mailing list at any time; and
(b)    display its contact details clearly in each direct marketing publication.
Customers may be taken off any mailing list by contacting HFC‘s Privacy Officer.

7.    ACCESS TO PERSONAL INFORMATION
Customers may access their Personal Information by contacting HFC‘s Privacy Officer. Access is generally granted within 30 days of that request.

HFC may impose a reasonable charge for access.

8.    WHEN HFC MAY WITHHOLD ACCESS TO PERSONAL INFORMATION
8.1    When access can be withheld 
Access to Personal Information may be withheld in a number of circumstances. These include where:
(a)    providing access would pose a serious and imminent threat to the life or health of a person;
(b)    providing access would have an unreasonable impact on the privacy of others;
(c)    the information is subject to confidentiality where the person who provided the information to HFC did so expressly on the condition that it remains confidential;
(d)    the request is vexatious or frivolous;
(e)    the information relates to current or anticipated legal proceedings between HFC and the person and the information would not be required to be discovered to a court;
(f)    HFC is in commercial negotiations with the person and the information would reveal HFC‘s intentions;
(g)    providing access would be unlawful or HFC is required by a law to withhold access; or
(h)    providing access could prejudice the investigation or detection by HFC or by a government body of an unlawful activity or some serious or improper misconduct.

Where HFC does withhold Personal Information, HFC may instead choose to give the Customer a summary of that information.

8.2    Written reasons 
If HFC does withhold Personal Information, HFC will provide written reasons.

8.3    Third party intermediary 
If HFC withholds access to Personal Information, HFC will consider whether the provision of access to an independent third party will meet HFC’s and the relevant Customer’s needs.

9.    CONTRACTORS 
HFC may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy Policy applies equally to those subcontractors.

10.    WHO TO CONTACT 
If you have any queries with respect to this Privacy Policy please contact our Privacy Officer at HFC, Stadium Circuit, Mulgrave, Victoria.

11.    MODIFICATIONS TO THIS DOCUMENT 
HFC may modify this Privacy Policy and the way it handles Personal Information at any time in its sole discretion.

12.    FURTHER INFORMATION 
Further information on privacy can be obtained from the Privacy Commissioner at www.privacy.gov.au.

13.    COMPLAINTS ABOUT YOUR PRIVACY
If you have a complaint about a breach of your privacy of how your personal information is collected or used please direct your complaint to our Privacy Compliance Manager at the address detailed below. We will respond to your query or complaint as soon as possible but not more than 14 days after the complaint has been made.

lf you are not satisfied with the response you receive you can forward concerns in writing to the CEO at the postal address detailed below. You will receive a further response within 14 business days.

14.    CONTACT US
If you have any questions or feedback about privacy or you feel that this company is not abiding by its posted privacy policy, you should contact:

Privacy Officer
Hawthorn Football Club
membership@hawthornfc.com.au
1300 042 957

POLICY REVIEW
Last reviewed: 05/11/2009