Updating you Privacy Policy and Application form in anticipation of the new Privacy Act 2020
17 September 2020
In anticipation of the new Privacy Act coming into force in December this year, Clubs New Zealand has reviewed the template privacy policy and template membership application form for clubs.
Both these updated templates can be found in the resources section of the website under Members Area > Resources > Membership.
Back in January we advised clubs to start thinking about introducing a Privacy Policy as opposed to a simple Privacy Statement. This is because clubs are now collecting information above and beyond the basic details required to assess suitability for membership, and thanks to technology we are now able to collect information from far more sources, websites, emails, phones calls, point of sale, you name it.
The Privacy Act can seem daunting but it doesn't need to be. It is something that the club can manage easily with appropriate policies, systems and commonsense.
Note Worthy Considerations
Disclosure of Criminal Convictions - On membership applications clubs tend to ask “Have you ever been convicted of any crime under the Crimes Act?” It suggested that clubs simply ask “Have you been convicted of a crime” as the some crimes are not contained in the Crimes Act. Your clubs will want a disclosure of all crimes.
Do you need to give a reason for a membership application being declined? – In some cases yes, as the reason an applicant is denied membership will constitute personal information. The applicant will therefore be entitled to have access to that information unless an exception in the Privacy Act applies. The most likely exception that could apply is that the information is ‘evaluative material’. The evaluative material must have been compiled for the sole purpose of determining whether to grant the applicant membership, and disclosing it to the applicant would breach a promise to the person who supplied the information that the information and/or their identity would be held in confidence. This could include circumstances where an existing member has an objection to an applicant’s membership but wishes to raise it anonymously – something to be aware of and it suggested clubs use the wording "the Club may not be required to supply a reason for that refusal.”
Sign in Books - You will have seen some privacy concerns around manual sign in sheets for COVID and arguably the same concerns can be applied to club sign in books. Sign in books should not be left unattended and Clubs New Zealand recommends that they are kept at the bar where they are continually monitored by staff.
If you have any questions regarding privacy policies and how to go about introducing one please contact the team at National Office on 0800 4CLUBS
