LIFT Privacy Policy
Overview
This Privacy Policy sets out how the Launceston Institute of Fitness and Training (LIFT) manages personal information provided to or collected by it. LIFT is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988. In relation to health records, LIFT is also bound by the Personal Information Protection Act 2004 (Tas). LIFT may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the business operations and practices and to make sure it remains appropriate to the changing environment.
Associated documents
The following documents are associated with this policy: •LIFT Terms and Conditions
LIFT App
The LIFT App (Clubworx version 2.6.0) collects location data, for use of proximity checkin. Members can refer to Clubworks Privacy Policy on the following link: https://www.clubworx.com/legal/privacy-policy
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What Kinds of Personal Information Does LIFT Collect and How Does LIFT Collect It?
The type of information LIFT collects and holds includes (but is not limited to) personal information, including health and other sensitive information, about: •Name, contact details (including emergency contacts), date of birth, address, •Medical information (e.g. details of illness, medical reports and names of doctors); •Any court orders; •Complaint records and investigation reports; •Facility surveillance information; Personal Information you provide: LIFT will generally collect personal information held about an individual by way of forms filled out, face-to-face meetings and interviews, emails and telephone calls. Exception in relation to employee records: Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to LIFT’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between LIFT and employee.
How Will Lift Use the Personal Information You Provide?
LIFT will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected by you, or to which you have consented. LIFT will take reasonable steps to ensure the information it uses is accurate, up-to-date, complete and relevant, having regard to the reasons why it is being used. Members: In relation to personal information of members, LIFT’s primary purpose of collection is to enable LIFT to provide an exercise facility, exercise its duty of care, and perform necessary associated administrative activities, which will enable members to take part in all the activities, facilities and equipment at LIFT. The purposes for which LIFT uses personal information of members: •to keep members informed about matters related to the gym, through correspondence, emails, and social media; •day-to-day administration of LIFT; •looking after members’ medical wellbeing; •marketing for the gym; and •to satisfy LIFT’s legal obligations and allow LIFT to discharge its duty of care. In some cases where LIFT requests personal information about a member, if the information requested is not provided, LIFT may not be able to enrol or continue the enrolment of the member or permit the member to take part in a particular activity. Job applicants and contractors: In relation to personal information of job applicants and contractors, LIFT's primary purpose of collection is to assess and (if successful) to engage the applicant or contractor, as the case may be. The purposes for which LIFT uses personal information of job applicants and contractors include: administering the individual's employment or contract, as the case may be; •for insurance purposes; •for marketing of LIFT; and •satisfying LIFT's legal obligations, for example, in relation to certain legislation. Volunteers: LIFT also obtains personal information about volunteers who assist LIFT in its functions or conduct associated activities. Marketing: LIFT treats marketing for the future growth and development of LIFT as an important part of ensuring that LIFT continues to provide a quality facility in which both members and staff thrive. Personal information held by LIFT may be disclosed to organisations that assist in LIFT's marketing, for example, on LIFT's social media or website. If you do not wish to be included in LIFT marketing materials, you can opt-out by contacting LIFT, the contact details are on the website.
Who Might LIFT Disclose Personal Information To and Store Your Information With?
LIFT may disclose personal information, including sensitive information, held about an individual for administrative and support purposes. This may include to: •government departments •medical practitioners; •people providing, support and health services at LIFT, including personal trainers, exercise physiologists, and group fitness instructors•people providing administrative and financial services to LIFT; •a junior members parent or guardian; •anyone you authorise LIFT to disclose information to; and •anyone to whom we are required or authorised to disclose the information to by law. LIFT may use online or 'cloud' service providers to store personal information and to provide services to LIFT that involve the use of personal information, such as services relating to direct debit, software platforms, email and instant messaging. Some limited personal information may also be provided to these service providers to enable them to authenticate users that access their services. This personal information may be stored in the 'cloud' which means that it may reside on a cloud service provider’s server which may be situated outside Australia.
How Does LIFT Treat Sensitive Information?
In referring to 'sensitive information', LIFT means: information relating to a person's personal information; health information, genetic information and biometric information about an individual. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless a member agrees otherwise, or the use or disclosure of the sensitive information is required or allowed by law.
Management and Security of Personal Information
Personal information is stored electronically, on paper, or both. LIFT's staff are required to respect the confidentiality of members’ personal information and the privacy of individuals. LIFT has in place steps to protect the personal information LIFT holds from misuse, interference and loss, unauthorised access, modification or disclosure by use of various methods including locked storage of paper records and password access rights to computerised records. Please be aware that sending personal information by email or through LIFT’s website may not always be secure. If you are concerned about the security of email or sending information through LIFT’s website, you should arrange alternative delivery of information, for example by registered post or encrypted email.
Access and Correction of Personal Information
Under the Privacy Act an individual has the right to seek and obtain access to any personal information which LIFT holds about them and to advise LIFT of any perceived inaccuracy. Members will generally be able to access and update their personal information, but members aged 16 years and under must have parent consent to access and correct themselves. There are some exceptions to these rights set out in the Privacy Act. To make a request to access or to update any personal information LIFT holds about you or a member, please contact the Manager of LIFT by telephone or in writing. LIFT may require you to verify your identity and specify what information you require.
Consent and Rights of Access to the Personal Information of Members
Generally, LIFT will refer any requests for consent and notices in relation to the personal information to the member. LIFT will treat consent given by Parents as consent given on behalf of the junior member Under 16, and notice to Parents will act as notice given to the member. Members may seek access to personal information held by LIFT about them by contacting the Manager by telephone or in writing. However, there may be occasions when access is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others, or where the release may result in a breach of LIFT's duty of care to the members.
Destruction and De-identification of Personal
LIFT securely destroys or de-identifies personal information when it is no longer required. LIFT generally retains client records indefinitely. Publications, selected photographs and marketing material is archived and kept indefinitely.
Responding to Data Breaches
LIFT will take appropriate, prompt action if there are reasonable grounds that a data breach may have or is suspected to have occurred. This includes notifying affected individuals as required by the Privacy Act 1988. Depending on the type of data breach, this may include a review of LIFT’s internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).
Enquiries and Complaints
If you would like further information about the way LIFT manages the personal information it holds, or wish to complain that you believe that LIFT has breached the Australian Privacy Principles, please report the breach to LIFT Management
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