Covid19 Protocols

Cromer Golf Club COVID-19 Vaccination Collection Notice

This COVID-19 Vaccination Collection Notice (this Notice) is issued pursuant to Australian Privacy Principle 5 in Schedule 1 to the Privacy Act 1988 (Cth) (Privacy Act).

1. Who is collecting and storing this information?

Your vaccination information is being sought by Cromer Golf Club (the Club), located at Cromer Road, Cromer NSW. For any queries, please contact 02 9982 3088.

2. What information is the Club is collecting?

The Club is seeking to collect your “covid19 vaccination information” which includes one of the following two types of documentation defined by Public Health (COVID-19 Additional Restrictions for Delta Outbreak) Order (No 2) 2021 (NSW):
a) A medical contraindication certificate issued by a medical practitioner in the form approved by the Chief Health Officer of NSW that certifies a person is unable to have the COVID-19 vaccine because of a specified medical contraindication; or
b) Evidence from the Australian Immunisation Register (operated by the Commonwealth) that a person has had 1 or 2 doses of a COVID-19 vaccine.

This information is “sensitive information” under the Privacy Act which is subject to a high level of privacy protection.

3. Consent

The Privacy Act requires the Club to obtain your consent to collect your vaccination information. We recognise this is sensitive private information and will be treated in confidence.

If you consent to this COVID-19 Vaccination Collection Notice, you are confirming that as a member or employee of the Club, you agree that the Club has notified you of the purposes of collecting your vaccination information and that:

a) You understand how the Club will collect and handle your vaccination information in accordance with this Notice and the Club’s privacy policy and
b) You acknowledge that you are providing this consent voluntarily.

At the end of this Notice, you have an opportunity to consent to providing the Club this information.

4. Who does this Notice apply to?

This Notice applies to all members and employees of the Club, as well as volunteers, in conjunction with its privacy policy and procedures.

5. Who do we collect the information from?

The Club is seeking to collect your vaccination information directly from you.

6. Why is the Club collecting COVID-19 vaccination information?

The Club is seeking to collect your vaccination information because:

• The Delta variant of the coronavirus, which is currently circulating throughout NSW and Australia, is highly transmissible and infectious and capable of causing hospitalisation and death to people who are exposed, and
• The COVID-19 vaccines approved by the Therapeutic Goods Administration (TGA) of the Commonwealth are currently our most effective “first line of defence” at limiting the transmission of COVID-19, as stated by the Australian Technical Advisory Group on Immunisation (ATAGI), and
• Having records of your vaccination information will enable the Club to comply with its duty under health and safety laws to eliminate or, if that is not reasonably practicable, minimise the risk of exposure to COVID-19 in the workplace.

The Club is also seeking to collect your vaccination information because:

• A media release issued by the NSW Premier on 9 September 2021 provides that only people with 2 doses of an approved COVID-19 vaccine, or those who are medically exempt, may attend a hospitality venue on the Monday after NSW reaches the 70% double-dose milestone, projected to be 18 October 2021, and
• To prepare for opening and trading with fully vaccinated staff or those who are medically exempt, the Club requires this information from you to ensure it complies with legislation that gives effect to the media release.

7. Consequences of the Club not collecting your vaccination certificate.

If the Club is unable to collect your vaccination information, it will:

• undermine the Club’s ability to comply with an applicable public health order.

8. Who are the types of bodies and persons to whom we may disclose your vaccination information?

The Club will only disclose your vaccination information in accordance with any obligation or duty imposed on the Club by an order under the Public Health Act or any other law.

9. Will my vaccination information be disclosed to overseas recipients?

No, the Club will not disclose your vaccination record to any overseas recipient.

10. How will records of my vaccination information be stored?

The Club may record your vaccination information in hard copy and electronic formats.

The Club will take all reasonable steps to protect your vaccination information from misuse, loss or alteration. These steps include but are not limited to:

• keeping any hard copies in in locked cabinets,
• storing the information in a database on a cloud which is routinely checked and audited; 
• implementing technological controls – for example, restriction of access, firewalls, use of encryption and passwords;
• destroying the information once the Club no longer needs to hold it (if hard copy – by shredding, and if soft copy – by deleting or permanently de-identifying); and
• if hard copies of the information are removed from the Club – requiring that they be placed in a plain manila folder which does not identify the person.

The Club will destroy the information when the purposes for which it was collected are no longer relevant. The information may be retained to comply with any legal or regulatory requirements introduced after this Notice is issued.

11. How can I access my COVID-19 vaccination record?

The Club will take reasonable steps to ensure that the Personal Information and/or Sensitive Information it collects, uses, holds or discloses is accurate, complete and up-to-date.

Members will be allowed access to their COVID-19 vaccination record held about them upon request, unless that access would pose a threat to health and safety of any individual or would unreasonably impact on the privacy of another person. Reasonable steps will be taken to correct any information if it is shown to be inaccurate, incomplete or out-of-date.

12. Can I make a complaint about how my data is handled?

If you are concerned your vaccination information has been collected, used, disclosed or otherwise handled in a manner which is inconsistent with this Notice or the Club’s privacy policy, you are able to make a complaint to the Club by contacting Daniel Constable (General Manager) gm@cromergolfclub.com.au.



Consent

I, confirm that I have read and understood this Notice. I understand and accept how the Club will collect and handle my vaccination information in accordance with this Notice and the Club’s privacy policy and I acknowledge and agree that I am providing this consent voluntarily.