RUPA is sensitive to the privacy concerns that RUPA’s Members, RUPA’s Accredited Player Agents, service providers, sponsors, partners and online users may have with respect to the confidentiality, security and use of their own Personal Information (as defined below).
What is Personal Information?
“Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is in a material form or not.
The types of Personal Information that RUPA collects from an individual will depend on the circumstances in which the information is collected. Generally, the types of Personal Information that RUPA collects include name, date of birth, gender, address, financial details (such as credit card / banking details) and contact details. If an individual applies for employment at RUPA or is an RUPA contractor, RUPA may also collect information relevant to the application or engagement including qualifications, resume, bank details, tax information, family details and reference information.
What is not Personal Information?
Information where RUPA has removed any reference to an individual will not be Personal Information, provided that the identity of the individual can no longer be ascertained.
It is RUPA's policy not to disclose this data to external organisations other than for the operation and management of the activities and services of RUPA, and the provision of programs and services to the Members, such as the management and delivery of the RA/RUPA Professional and Career Development Program, or with the consent of the relevant individual. RUPA may provide information to external providers for the purpose of delivering communications on behalf of RUPA and / or for promotional activities (subject to consent being obtained from the individual for such promotional purposes) and/or for campaigns or petitions RUPA may conduct from time to time.
Personal Information RUPA collects and holds
RUPA collects Personal Information through various avenues in the course of conducting its businesses, including:
• directly from individuals when they provide Personal Information to RUPA or its agents or contractors, for example when the individual is involved in acquiring goods or services from RUPA or supplying goods or services to RUPA;
• directly from individuals via RUPA websites (including social media pages);
• directly from individuals when they enter a trade promotion, or competition or when they sign up to a campaign or petition;
• from publically available sources;
• from related companies;
• from third parties; and
• via security video surveillance at RUPA sites.
Where reasonable and practical, RUPA will collect Personal Information directly from the individual and inform the individual that this is being done.
RUPA does not generally require individuals to disclose “Sensitive Information”, for example information about an individual’s race, religion, sexual orientation or beliefs. If an individual discloses sensitive information to RUPA for any reason, that individual consents to RUPA collecting the information and using and disclosing it for the purpose for which it was disclosed and as permitted by the Privacy Act and other relevant laws.
Information collected by RUPA is stored on RUPA’s database and RUPA takes reasonable steps to prevent unauthorised access, unauthorised disclosure, use or modification to the information. Some of this information is held by, and may be transferred to, RUPA's web provider for the purpose of enabling members to access and update their Personal Information.
All RUPA staff members with access to the information are obliged to keep that information confidential.
RUPA Member/Player Data
RUPA, collects data on its present and past members (and other past and present players who may be eligible for membership of RUPA) to maintain contact with them and enable the facilitation of RUPA’s programs which will assist its members and RUPA’s Accredited Player Agents.
Accredited Player Agents
RUPA collects information from individuals who are, or apply to be, Accredited Agents, under RUPA’s Player Agent Accreditation Scheme (“Scheme”). This information is collected for the purposes of administering the Scheme and RUPA’s Player Agent Accreditation Scheme Regulations (“Regulations”), maintaining and improving the quality of representation of Australian professional rugby players by player agents and enabling RUPA and third parties to make and maintain contact with player agents in a business context for the purposes of engaging them in dealings on behalf of professional rugby players.
This information may be provided by RUPA to the members of RUPA’s Player Agent Accreditation Board and the Independent Appeals Tribunal under the Regulations for the purposes of undertaking their functions under the Regulations. The information may also be disclosed where required by law.
Unsolicited Personal Information
If RUPA receives Personal Information where it has taken no steps to collect the information, then within a reasonable time it will decide whether it could, under the APPs, have solicited that Personal Information itself.
If RUPA determines that it would not, under the APPs, have been permitted to solicit the Personal Information, RUPA will as soon as practical (where lawful and reasonable to do so) destroy or de-identify that unsolicited Personal Information. If RUPA could, under the APPs, have solicited the Personal Information then RUPA may use and disclose the Personal Information for the purpose for which it was disclosed and as permitted by the Privacy Act and other relevant laws.
Use and Disclosure of Personal Information
The purpose for which RUPA uses and discloses Personal Information will depend on the circumstances in which it is collected. Generally, RUPA may use or disclose Personal Information:
· for the purposes for which it was collected;
· for a related secondary purpose, if the use or disclosure could be reasonably expected (e.g. disclosure to a delivery contractor for the purpose of delivering goods ordered from RUPA);
· for other purposes to which an individual has consented; and
· as otherwise authorised or required by law.
Specific purposes for which RUPA may use or disclose Personal Information include the purposes of:
· supplying good or services to, or acquiring good or services from, an individual or organisation;
· to improve RUPA’s products and services;
· contacting individuals for marketing purposes;
· considering an individual for a position (e.g. as an employee or contractor) at RUPA;
· online petitions;
· responding to an enquiry by an individual;
· financial services and insurance;
· mailing systems and direct marketing;
· market research; and
· to maintain security over RUPA premises and systems.
RUPA may disclose Personal Information locally to other Australian based parties including its related companies and to any agent, contractor or third party who provides administrative or other services to RUPA or its related companies.
RUPA will, where commercially practical, require that any third party to whom Personal Information is disclosed will treat the Personal Information in a manner that is consistent with the APPs.
RUPA may disclose Personal Information to third parties, such as law enforcement agencies or government authorities, without authorisation in some circumstances, in accordance with the APPs. RUPA will not sell Personal Information to a third party without the consent of the individuals to whom the Personal Information applies. RUPA may sell de-identified, aggregated data to third parties that cannot be used to specifically identify an individual.
Those entities are not authorised by us to use Personal Information for anything other than the purpose for which we supplied that information to them. We may also disclose Personal Information where you consent to us doing so. That consent may be written, verbal or implied from your conduct.
Disclosure outside Australia
Unless direct consent is provided by the relevant individual, RUPA will not disclose Personal Information to third parties outside of Australia.
RUPA may send marketing communications in line with an individual’s previously expressed marketing preferences or as otherwise permitted under the Privacy Act and other relevant laws.
RUPA (and other parties to which it may have disclosed Personal Information) will not direct market to you unless you have been given an opportunity to opt out of receiving future direct marketing communications or unless you have otherwise consented to direct marketing. If you do not want to receive such offers from us or do not want us to disclose your Personal Information to our related entities or dealerships for marketing purposes, you can opt out at any time by contacting us using our contact details provided below.
From time to time, RUPA conducts various campaigns and may collect and use your personal information as part of any such campaign. RUPA may also use your details for specific petitions in relation to such campaigns. If you have signed a petition, your Personal Information may be used to verify the authenticity of the petition by presenting this information to organisations to which such petitions is relevant, such as the Rugby Australia Ltd (RA). If you do not wish for RUPA to contact you via phone or email during or campaign or as part of a petition you have signed, please let RUPA know.
Security of Personal Information
Individuals should notify RUPA immediately if they become aware of any breach of security.
Where Personal Information is no longer needed for any purpose for which RUPA is authorised to use it and there is no legal requirement for RUPA to keep it, RUPA will take reasonable steps to destroy or de-identify Personal Information.
How you can access and seek correction of your Personal Information which RUPA holds
An individual may request access to, or correction of, their Personal Information held by RUPA by sending a written request to the RUPA Privacy Officer – see the “Contact RUPA” section below.
If an individual makes a written request for access to Personal Information held by RUPA, RUPA will respond to such request within 30 days and, where reasonable and practical, give access to the Personal Information in the manner requested by the individual. However, RUPA may refuse a request for access to Personal Information where it is legally entitled to do so and, where reasonable, it will provide the reasons for this.
RUPA may require the person requesting access to provide suitable identification and, where permitted by law, may charge a fee for giving access to Personal Information in response to an individual’s request. The fee (if any) will be disclosed prior to providing the requested information and the costs being incurred. Any such fee will not be excessive and will relate to the reasonable costs incurred in responding to the request, not to making the request itself.
RUPA will take reasonable steps to ensure that the Personal Information it collects is accurate, up-to-date and complete. Correction of Personal Information may be requested by contacting the RUPA Privacy Officer at the address set out in the “Contact RUPA” section below. If RUPA refuses to correct Personal Information in response to a request it will, where reasonable, provide a written notice setting out the reasons for refusal. In this situation an individual may request RUPA to append a statement to their Personal Information that there is a dispute as to its accuracy.
Complaining about a breach of the APPs
Please contact the RUPA Privacy Officer in relation to privacy matters:
Mail: ATTN: RUPA Privacy Officer, The Rugby Union Players' Association, Level 1, 10 Mallett Street, Camperdown, NSW, Australia 2037