- 1 The UCD University Club (the ‘Club’) is committed to the protection of personal information. This Policy outlines the Club’s commitment to maintain privacy when collecting, using and disclosing personal information of Club members and guests.
This privacy notice aims to give you information on how the Club collects and processes your personal data, including any data you may provide through our website, when you make an enquiry on your own or a third party’s behalf, visit our Club, sign up to our newsletter, purchase or avail of a product or service at the Club or take part in a competition.
We do not sell directly to children, normally if you are under the age of 18 you will need to be accompanied by an adult such as parents, guardians or other adult family members in which case they are required to take responsibility for your privacy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We reserve the right in its sole discretion to amend this privacy statement at any time. You should regularly check this privacy statement for any amendments.
- WHAT IS PERSONAL INFORMATION?
- 1 ‘Personal Information’ is information that allows an individual to be identified. but does not include:
- COLLECTION OF PERSONAL INFORMATION
- 1 Examples of the types of personal information that the Club may collect about its members and guests, include:
- Contact information (name, home address, work address, home and/or work email address, home and/or work phone, and mobile phone numbers, country of residence);
- Date of Birth;
- Occupation and professional associations if voluntarily provided by the member or guest;
- Emergency contact information if voluntarily provided by the member or guest;
- Information regarding guests that you bring to the Club;
- Personal preferences, including dietary preferences, allergies and other medical conditions if voluntarily provided by the member or guest;
- Information on member and guest reservations and Club events that members and guests attend;
- Credit card information and/or banking information for billing purposes;
- Images of members or guests on the Club’s video surveillance system (discussed in section 7);
- Details on when you access the Club, including with which device (or person) you authenticated or identified yourself and,
- 2 What does the Club use your Personal Data for?
We use different methods to collect data from and about you including through:
(a) Direct interactions: You may give us your Identity Data, Health Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when book or purchase our services, including booking and purchasing
- meeting rooms and/or event space
- meals in our restaurant, café or other spaces
- membership events
- subscribe to our service, newsletter or publications;
- participate in any rewards programme;
- request marketing to be sent to you;
- participate in market research;
- enter a competition, promotion or survey; or provide some feedback on your experience via third party travel websites or directly with the Club.
The Club uses the Personal Data provided to contact you directly and respond to your enquiry and to accommodate your request which will be subject to a contract. The Club holds your Personal Data on a database in order to book an event or room or to process your application for membership and to maintain that membership. As we progress with your enquiry, we may request your consent to communicate marketing material to you by email or by post. You are not obliged to give such consent and if you do, you can withdraw that consent at any time.
- USE AND DISCLOSURE OF PERSONAL INFORMATION
- 1 The Club uses personal information for the following purposes:
- To establish your membership or access to the Club as a member or guest;
- To maintain a record of all members and guests in the Club at any given time;
- To establish and maintain a relationship with you and provide ongoing services;
- To enquire about and to reserve a restaurant table
- To enquire about and to book an event/meeting space
- To enquire about and to book participation in a member’s event.
- To process membership and other payments to the Club;
- To enquire about or to join as a member
- To meet legal and regulatory requirements;
- To determine member and guests’ interests and preferences in order to market future services to the member or guest. Please note that the Club does not market to individuals under 18 years of age; and
- Such other reasons as a reasonable person would consider appropriate in the circumstances.
- 2 The Club may disclose personal information with third parties engaged to assist the Club in providing services or products to members and guests or to carry out one or more of the purposes described above. These service providers are prohibited from using personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed to them by the Club and to comply with the general privacy principles described in this Policy and all applicable privacy laws. (Please see below for list of internal and external third parties)
- LIMITING COLLECTION, USE AND DISCLOSURE
- 1 The Club will limit the collection of personal information to that which is reasonably necessary for the purposes identified.
- 2 The Club will not use or disclose personal information for any purpose other than those for which it was collected (as identified in section 4 of this Policy). Where an additional use or disclosure is necessary, the Club will notify the member or guest prior to or at the time of the additional use or disclosure, unless such notice is not required or permitted by law.
- 3. Personal information will only be disclosed within the Club on a need-to-know basis.
- 1 Except where required or permitted to do so without consent, the Club only collects personal information with the member or guests’ consent. In most cases, the Club relies on express consent. However, where the purpose of the collection of personal information is obvious on its face (such as use of a credit card to pay an account), the Club may rely on implied consent.
- 2 In some cases, such as using personal information for marketing the Club’s services to the member or guest, the Club will rely on opt-out consent. (i.e. information will be provided unless the member or guest advises the Club that they do not wish to receive it.)
- 3 The Club only collects personal information where it is necessary to provide the service that the member or guest is seeking and that the Club has agreed to provide. The Club does not use deceptive or misleading practices to obtain consent.
- 4 The Club does not require consent to the collection, use or disclosure of personal information as a condition of the supply of a service by the Club unless such collection, use or disclosure is required to fulfil the aforementioned purposes of collection.
- 5 The Club reserves the right to collect, use or disclose personal information in certain limited circumstances, without the member or guests’ knowledge and consent, where required or permitted by law. Examples of this include:
- where it is clearly in the member or guest’s interests and consent cannot be obtained in a timely way;
- in order to create aggregate information in order to identify a member or guest’s needs and preferences, and to aid in the development of new services and products;
- where it is required, by law, to be disclosed to law enforcement and other government agencies;
- where it is reasonable to expect that disclosure with consent would compromise an investigation or proceeding;
- where disclosure is for the purpose of complying with a court order, warrant or order issued or made by a Court; and
- where disclosure is required or authorised by law.
- 6 A member or guest may withdraw their consent to the collection, use and disclosure of personal information in connection with the services that the member or guest has requested from the Club at any time, subject to legal or contractual restrictions and reasonable notice. The Club will inform the member or guest of the implications of withdrawing their consent. If a member or guest wishes to withdraw their consent at any time, please contact the Club’s Privacy Officer (see section 12 for contact information).
- VIDEO SURVEILLANCE
- 1 The Club may collect personal information of members and guests via the Club’s video surveillance system. The video surveillance is used for the purposes of security and protection of Club property from theft and other crimes.
- 2 The Club’s video surveillance will not be used in any areas where people have a reasonable expectation of privacy such as locker rooms and restrooms. Currently, the Club has video cameras in the following locations: service areas, entrance and exits.
- 3 All video surveillance is overt and only captures images, not audio. The video surveillance is only reviewed in response to a triggering event. For example, if there is a safety incident at the Club, the video surveillance will be reviewed.
- 4 Where a triggering event requires the Club to review video surveillance, the Club may use information collected through video surveillance to make decisions regarding a member or guest’s continued access to the Club, up to and including termination of Club membership.
- 5 Video images may only be reviewed by:
- 6 Video images will not be disclosed to third parties unless such disclosure is required for the purposes of conducting an investigation, for law enforcement purposes or as authorised by privacy or other legislation.
(i) individuals responsible for the technical operation of the video surveillance system (for technical purposes only); and
(ii) individuals who reasonably need to view the video images for purposes of investigating a specific incident, including human resources and/or legal counsel.
- 7 Video images will be erased within 90 days from the date of the recording unless the video image is associated with a specific incident being investigated. If the video image is associated with an incident being investigated or necessary for a prosecution, it will be retained for as long as reasonably necessary in the circumstances of the specific incident in issue.
- 1 Personal information will be retained only if necessary or required by law. If you are applying for membership, the Club will retain your Personal Data provided in an application form and recorded on a database for the duration of your membership plus two years and limited Personal Data (e.g. name, address, occupation and year of birth) for archiving and historical purposes. If you are booking a conference, an event or a room, the Club will retain your Personal Data provided in an application form, until your event has taken place and then one year thereafter for accounting purposes.
- 1 The Club will make all reasonable efforts to ensure that personal information is accurate, complete and current as required for the purposes for which it was collected. If necessary, the Club will correct or amend any personal information if its accuracy is challenged and found to be deficient.
- PROTECTION OF PERSONAL INFORMATION
- 1 Personal Information will be safeguarded through appropriate measures, including the following as appropriate:
- Physical measures such as locked drawers or filing cabinets;
- Organisational measures such as restricting access to personal information to designated individuals on a ‘need-to-know’ basis; and
- Computer security measures such as encryption and/or password protection.
- 2 Member and customers files will be kept in a secure area with policies to ensure that information on member files is protected from unauthorised access, collection, use, disclosure, copying, modification and disposal. Only duly authorised individuals, who need to have access to such information in order to perform their duties, will have access to such information.
- 1 Individuals have the right to request access to their personal information that is under the control of the Club. Upon request, in writing to the Privacy Officer, the Club will inform a member or guest of the existence, use and disclosure of their own personal information and will be given access to that information, to the extent permissible by law. A member or guest may challenge the accuracy and completeness of the information and request that it be amended as appropriate.
- 1 The Club is responsible for protecting any personal information under its control. Questions or concerns regarding privacy procedures or the Club’s compliance with applicable privacy legislation may be directed to the UCD Club General Manager or by emailing firstname.lastname@example.org. The mailing address for all Privacy queries is as follows: The UCD University Club, University College Dublin, Belfield, Dublin 4, Ireland.
- 2 If an individual is not satisfied with the Club’s response, he or she may contact the Data Protection Commissioner.