The Juniors Group of Clubs Policies

Identity Verification

Where you provide identification documents to us – for example, as part of membership, patron sign-in, or anti-money laundering and counter-terrorism financing customer due diligence – we may verify your identity by checking the details on those documents against official records held by document issuers or government record holders. This verification is performed through the Australian Government’s Document Verification Service (DVS), which is administered by the Attorney-General’s Department.

How We Use the Document Verification Service

We submit the details from your identification document (for example, the name, date of birth, document number and expiry date shown on your driver’s licence or passport) to the DVS through an approved Gateway Service Provider. The DVS returns a “match” or “no match” result, which we use to confirm whether the details you have provided correspond to records held by the relevant document issuer or official record holder.

Third-Party Service Providers

The verification process involves the following categories of third-party service providers:

• Approved Gateway Service Providers, which transmit verification requests and results between us and the DVS (we currently use BNDRY for this purpose);
• the Australian Government’s Document Verification Service, operated by the Attorney-General’s Department as Framework Administrator; and
• the relevant document issuers and official record holders against whose records the document details are checked (for example, State and Territory road authorities for driver’s licences, the Department of Foreign Affairs and Trade for passports, and the Department of Home Affairs for ImmiCards and visas).

Our Legal Obligations

Our collection of your identification information is connected to our legal obligations under:

• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the AML/CTF Rules, including obligations to apply customer identification procedures and ongoing customer due diligence;
• the Gaming Machines Act 2001 (NSW), the Liquor Act 2007 (NSW) and related regulations, including responsible gambling and patron exclusion obligations; and
• the Identity Verification Services Act 2023 (Cth) and the DVS Access Policy, which set out the conditions on which we may use the DVS.

Your Rights

You have the following rights in relation to the collection of your identification information:

• to be informed about how your identification information will be collected, used and disclosed;
• to give or decline consent to the verification of your identity through the DVS;
• to request access to and correction of personal information we hold about you, as set out in the “Access to and Correction of Your Personal Information” section below; and
• to make a complaint about our handling of your identification information, as set out in the “Privacy Contact and Complaints” section below.

Consequences of Declining Consent

If you decline to consent to the verification of your identity through the DVS, we may not be able to verify your identity through that channel. Where verification of your identity is required by law (for example, to comply with our anti-money laundering and counter-terrorism financing obligations), we may not be able to provide you with the relevant product or service, or may need to verify your identity by an alternative method. We will let you know if an alternative verification method is available.

Consent Statement

Before we submit a verification request to the DVS, we will ask you to provide your express consent by accepting the following statement. This consent is collected separately from any other agreement, including any membership agreement or terms and conditions:
“I confirm that I am authorised to provide the personal details presented and I consent to my information being checked with the document issuer or official record holder via third-party systems for the purpose of confirming my identity.”

Complaints and Further Information

You can make a complaint about our handling of your identification information by contacting us using the details in the “Privacy Contact and Complaints” section below. You can find information about the operation and management of the Document Verification Service by the Attorney-General’s Department at idmatch.gov.au.

Access to and Correction of Your Personal Information

You have the right to request access to the personal information we hold about you (APP 12), and to request correction of any personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading (APP 13).

To make a request, please contact our Privacy Officer using the details in the “Privacy Contact and Complaints” section below. We will:

• acknowledge your request promptly;
• respond to your request within 30 days; and
• provide a written explanation if we are unable to give you access or make a correction, including your options for making a complaint.

We do not charge a fee for making a request, although a reasonable fee may apply for giving access in some circumstances. Player activity statements are available on request from club management.

Surveillance of Venues

The Juniors Group of Clubs is subject to video, facial recognition technology and at times audio surveillance for security, safety and legal compliance reasons. Surveillance footage and related data are retained in accordance with our surveillance system’s standard retention period and applicable legislation.

Details of suspected or actual illegal and undesirable activities on our premises may be shared with law enforcement and regulatory bodies without your consent, as permitted by law.

Security of Personal Information

We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, as required by APP 11. These steps include:

• encryption of personal information in transit and, where appropriate, at rest;
• role-based access controls and authentication requirements for staff and contractors who access personal information;
• physical security controls for our premises, servers and storage facilities;
• regular privacy and information security training for staff;
• vendor due diligence and contractual privacy and security obligations on our service providers; and
• incident response and breach notification procedures.

If we suspect or become aware of a data breach that is likely to result in serious harm to any individual whose personal information we hold, we will comply with our obligations under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth), including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.

Data Retention

We retain personal information only for as long as necessary for the purposes for which it was collected, or as required by law. Retention periods vary depending on the type of information and the legal requirement that applies. In particular:

• AML/CTF records: we are required to retain customer identification records, transaction records and other AML/CTF records for at least 7 years, in accordance with Part 10 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the AML/CTF Rules;
• responsible gambling and patron exclusion records: retained for the period required under the Gaming Machines Act 2001 (NSW) and related regulations;
• surveillance footage: retained for the period required by applicable legislation and our surveillance system’s standard retention period;
• member and patron account information: retained while your account is active, and for a reasonable period after your last interaction with us, unless a longer retention period is required by law; and
• marketing preferences: retained for as long as you continue to receive marketing communications from us, plus a reasonable period to evidence your preferences.

Account Deletion

You can request deletion of your account or personal information at any time by:

• using the “Delete Account” option in the app; or
• contacting our Privacy Officer at privacy@thejuniors.com.au.

When you request deletion, we will remove or de-identify your personal data within a reasonable timeframe (typically within 30 days), except where we are required or authorised to retain certain information for legal, regulatory, security or fraud prevention purposes (including the AML/CTF retention obligations described above).

Your Privacy on the Internet

We take care to ensure that any personal information you provide on the internet through our websites is protected and secure. We use cookies to support the security of information you provide to us. You should keep any passwords or access codes confidential, as they help us maintain the security of your personal information and the integrity of our services.

We provide links to other websites that are not under our control. We are not responsible for the conduct of those organisations. We suggest you review the privacy policies of any linked sites before disclosing personal information on them.

Sensitive Information

We do not generally collect sensitive information, including information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, or health information.

Where we do collect sensitive information, we will only do so where:

• we are required or authorised to do so under an Australian law (for example, to maintain the security and integrity of our venues); or
• you have consented to its collection.

Situations in which we may collect sensitive information from you include where you apply for a job with South Sydney Junior Rugby League Club Limited.

Privacy Contact and Complaints

If you have any questions about this Privacy Policy, would like to request access to or correction of your personal information, or wish to make a privacy complaint, please contact:

Privacy Officer South Sydney Junior Rugby League Club Limited
Email: privacy@thejuniors.com.au
Address: 558A Anzac Pde Kingsford NSW 2032

We will acknowledge your complaint within 7 days and aim to resolve it within 30 days. We may ask you for additional information to help us investigate.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):
Website: www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The most recent version will be available on our website at www.thejuniors.com.au. We encourage you to review this Privacy Policy periodically.

Additional Information on Privacy

For more information about privacy and your rights, visit the Office of the Australian Information Commissioner at www.oaic.gov.au.

Company Email Addresses

Email addresses published on our website are for professional communications only. Publication of an email address is not an invitation to send unsolicited commercial emails that are not related to our business.