TFA Privacy Policy

Touch Football Australia

PRIVACY POLICY /

  1. Introduction

This Privacy Policy covers Touch Football Australia Limited (TFA), New South Wales Touch Association Inc (Touch Football NSW), Queensland Touch Association Inc (QLD Touch Football) and each of their affiliates, members, associates, related entities and subsidiaries (together, "we", "us" and "our").  For the avoidance of doubt, a reference in this Privacy Policy to TFA, "we", "us" and "our" (including TFA doing or not doing an act) is a reference to, and is intended to also cover, Touch Football NSW and QLD Touch Football. Please read this Privacy Policy carefully as it describes how we collect, use, disclose and otherwise handle your Personal Information. By providing your Personal Information to us, you consent to its use, storage and disclosure in accordance with this Privacy Policy.

TFA recognises the importance of your privacy and your right to control your Personal Information and is committed to complying with applicable privacy laws (including the Privacy Act).
TFA is always seeking to better understand how players, Touch Football administrators, Affiliates and members interact, communicate and otherwise share Personal Information in order to continue to develop the game of Touch Football. TFA, in conjunction with the National Rugby League (NRL), established and administer data storage architecture (TFA's online database) for processing your Personal Information (Rugby League Exchange).

  1. Anonymity and pseudonymity

We offer you the opportunity, wherever it is lawful and practicable, of not identifying yourself, or of using a pseudonym, when entering transactions or otherwise dealing with TFA in relation to a particular matter by contacting the TFA Privacy Officer (see clause 11).

  1. What kinds of Personal Information do we collect?

3.1 The types of Personal Information TFA may collect depends on the purposes for which it is collected but may include (without limitation):

(a) your name, gender, date of birth, occupation, residential address, email address, telephone number and other contact details;

(b) your favourite NRL Club and other information dealings with TFA, and Affiliates; and

(c) purchasing preferences and financial details.

3.2 TFA will not collect Sensitive Information about you unless:

(a) you have consented to the collection of such specific Sensitive Information;

(b) TFA is specifically permitted to do so under TFA Rules, including for health, medical and anti-doping testing purposes and investigation of disputes (whatever the nature of the dispute);

(c) the collection is required or authorised by law; or

(d) the collection is otherwise permitted under applicable privacy laws (including the Privacy Act).

TFA will assume consent to the collection of all Sensitive Information that is provided to it for use in accordance with this Privacy Policy, unless told otherwise.

3.3 Website

In addition to Personal Information, we use cookies, web beacons and other technologies on our website and applications to collect information about your usage of our services (for instance, third party websites you visit to better understand your preferences and what types of products and services you may be interested in). Cookies are small text files that help a website to remember the preferences of users to improve the experience of using that website. In some cases, the cookies that we use may collect some Personal Information. TFA will treat this information in the same way as other Personal Information we collect. You are free to disable cookies on your internet browser to prevent this information being collected; however, you will lose the benefit of the enhanced website experience that the use of cookies may offer.

When users visit the TFA website, our systems may record certain information about their use of the site, including the web pages visited and the time and date of their visit. TFA uses this information to help analyse and improve the performance of the TFA website.

Websites linked to the TFA website are not subject to TFA's privacy standards, policies or procedures. TFA cannot take any responsibility for the collection, use, disclosure or security of any Personal Information that you provide to a third party website.

4.4 Providing information

Depending on the circumstances, some types of information will be required and others might be optional. If you do not provide some or all of the information requested, this may affect TFA's ability to communicate with you or provide the requested products or services.

By not providing requested information, you may jeopardise your ability to participate in programs or Competitions or apply for employment or volunteer positions with TFA. If it is impracticable for TFA to deal with you as a result of you not providing the requested information or consent, TFA may refuse to do so.

  1. How do we collect your Personal Information?

4.1 Where it is reasonable and practicable to do so, TFA will collect your Personal Information from you. If you are a Minor, TFA may collect Personal Information about you from your parent or legal guardian.

4.2 In addition to collecting Personal Information directly from you, TFA may also collect Personal Information from:

(a) Affiliates, Touch Football NSW, Qld Touch Football and selected third parties (for instance, Ticketek and Ticketmaster) as part of the Rugby League Exchange; and

(b) a third party (such as a corporate partner of TFA or Affiliates, or information that is on public record or which is otherwise unsolicited).

4.3 Information may be collected when you:

(a) become a member of TFA or an Affiliate;

(b) subscribe to any publication of TFA, including electronic publications;

(c) provide details to TFA, consent form, survey, feedback form or incident report;

(d) enter Personal Information into, or agree to having your Personal Information entered into, one of TFA's online systems;

(e) access the TFA website;

(f) contact TFA via email, telephone or mail or engage with TFA via social media;

(g) participate in any program, activity, Competition or event run by TFA;

(h) purchase tickets to a TFA event from Ticketek, Ticketmaster or an authorised agent;

(i) purchase merchandise, products or services from TFA or an authorised agent or licensee;

(j) are elected or appointed to the Board or a committee of TFA;

(k) apply for employment or a volunteer position with TFA or an Affiliate Member; and

(l) where TFA is required to do so by law (for education, child protection, work health and safety laws, charitable collections, medical treatment or other legislation in Australia).

  1. Why do we collect, use, hold and disclose your Personal Information?

5.1 TFA and third parties to whom we may disclose Personal Information to generally only collect, use, disclose or holds Personal Information that is reasonably necessary for TFA to perform one or more functions or activities in administering the game of Touch Football (the primary purpose), including:

(a) to research, develop, organise, conduct and promote Competitions, Matches, programs, activities and other events relating to Touch Football (including for the purpose of providing information and making ticket offers to you);

(b) direct communication with you by Touch Football administrators;

(c) disclosure to Touch Football Partners, unless you have indicated that you do not want to receive any communication from Touch Football Partners;

(d) compliance with TFA Rules, including the administration and development of Touch Football (if you are a Participant);

(e) serving content in accordance with your preferences and previous consumption;

(f) research, develop and market products, services, merchandise and special offers made available by us and third parties;

(g) serving advertising that is suited to your age;

(h) verify your identity;

(i) complete background checks;

(j) respond to emergency situations involving or requiring medical treatment;

(k) administer, manage and provide you with access to TFA's website; and

(l) keep you informed of news and information relating to various Touch Football events, activities and opportunities via various mediums.

TFA may use health information to ensure that programs we operate are run safely and in accordance with any special health needs Participants may require. Health information may also be kept for insurance purposes. In addition, we may use de-identified health information and other sensitive information to carry out research, to prepare submissions to government, or to plan events and activities.

5.2 Wherever practicable, TFA will inform you more specifically of the primary purpose of a collection as part of its collection statement, which will be made available to you at the time of the collection.

5.3 When we collect your Personal Information, your Personal Information will only be used or disclosed for the primary purpose for which it was collected, a related secondary purpose, in accordance with any express or implied consent you grant TFA, to lessen or prevent a threat to an individual or public health or safety or as otherwise lawfully required (e.g. where your Personal Information is requested by a law enforcement agency).

Direct Marketing

5.4 TFA will assume consent to use non-sensitive Personal Information to provide better services and for marketing purposes (including disclosure of such information to service providers) and may use or disclose your Personal Information to a Touch Football administrator for the secondary purpose of direct marketing communication, if:

(a) TFA collected the information from you;

 (b) TFA has provided a simple means by which you can request not to receive direct marketing; and

(c) you have not made a request not to receive direct marketing.

 5.5 In each direct marketing communication, TFA will prominently display a simple notice or actionable option that you may express a wish not to receive any further direct marketing communication.

5.6 Each written direct marketing communication by TFA with you sets out TFA's contact details including business address, telephone number and email address.

  1. Who do we disclose your Personal Information to?

6.1 Subject to compliance with applicable privacy laws (including the Privacy Act) and this Privacy Policy, TFA may disclose your Personal Information to:

(a) Touch Football NSW, QLD Touch Football, Affiliates and the NRL to enable them to administer the and the Rugby League Exchange and the game of Touch Football and provide related activities and services; and

(b) unless you inform TFA otherwise, the NRL, Touch Football NSW, QLD Touch Football, Affiliates, Touch Football Partners and selected other partners as part of the Rugby League Exchange to enable such recipients to provide you with information, materials and promotional opportunities. This sharing of Personal Information via the Rugby League Exchange will assist these organisations to more effectively administer promotional and information sharing activities;

(c) its service providers, mail houses or other similar third-party organisations for the purpose of implementing the primary purposes, including fulfilling ticket requests and communicating Touch Football related offers. For example, TFA uses third party credit card payment gateway services on its website and applications. If you pay for a product or service through TFA's online platform, TFA will be required to provide certain financial details to the third-party service provider to effect the transaction. TFA requires these third party organisations to keep your contact details and Personal Information confidential and only use them for the designated purpose;

(d) its advisers, including our accountants, auditors, lawyers and insurers; and

(e) in other circumstances permitted by law.

  1. Data quality and security

7.1 TFA will take reasonable steps to:

(a) make sure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date; and

(b) protect the Personal Information it holds about you or that is within its direct control from misuse, interference and loss and from unauthorised access, modification or disclosure. Some of the security measures TFA uses include strict confidentiality requirements of our employees, volunteers, Affiliates and service providers, security measures for system access and security measures for our website.

We seek to protect your Personal Information from any unauthorised loss, disclosure or access. However, if a serious data breach occurs, we must notify you as required under the Privacy Act regarding the circumstances of the breach, and must also advise the Office of the Australian Information Commissioner.

7.2 TFA will take reasonable steps to destroy or permanently de-identify Personal Information if it is no longer needed for any purpose for which the information may be used or disclosed (at your request or otherwise) or if you withdraw your consent, unless TFA is required by or under law, or a Court order, to retain such information. Where TFA is required to destroy or permanently de-identify your Personal Information, it will take reasonable steps to inform other parties using, holding or disclosing the same Personal Information (including any links to, copies of or replication of that Personal Information).

7.3 Information storage

(a) TFA stores information in different ways, including in paper and electronic form.

(b) Much of the information we collect from and about our members is added to TFA's online database. When your information is entered into TFA's database, the information may be combined or linked with other information held about you.

  1. Openness, access and correction

8.1 TFA strives to provide you with the greatest available control of the Personal Information which TFA collects from you or about you from Affiliates, Touch Football NSW, QLD Touch Football and other parties. Accordingly, TFA is continually developing and enhancing the ways which you can access your Personal Information (for example, via your NRL Account).

8.2 TFA will provide you with a variety of ways to access, review and manage your Personal Information. For example, if you have an NRL Account you can use your login credentials to access, review and manage your Personal Information at any time. If you don't have an NRL Account, you can still opt out of and otherwise manage your communications preferences via links in emails and other communications we send to you from time to time. You will be responsible for ensuring your Personal Information remains accurate, complete and up to date.

8.3 Upon your request, TFA will take reasonable steps to let you know, in general terms, what sort of Personal Information it holds, for what purposes, and how it collects, holds, uses and discloses that information. Where TFA has collected your Personal Information from you directly or with your consent, you have a right to receive (upon request) that Personal Information from TFA in a structured, commonly used, machine readable format and/or a right to instruct TFA to transmit that Personal Information to a third party (if technically feasible). In such circumstances, we will respond to your request for access within 14 days and endeavour to provide the requested information within 30 days. If you find that the Personal Information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will see that it is corrected.

8.4 Before supplying any Personal Information to you or updating your Personal Information at your request, TFA must be reasonably satisfied as to your identity (for example, by asking to see your passport or driver's licence). TFA is not under any obligation to provide Personal Information to you where TFA is not required to do so under applicable privacy laws (including the Privacy Act).

8.5 If TFA refuses to provide you with access to Personal information it holds on you in the manner requested by you, TFA will either:

(a) take such steps (if any) as are reasonable in the circumstances to give access to the information in a way that meets the needs of TFA and you; or

(b) provide you with a written notice that sets out:

(i) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and

(ii) the mechanisms available to complain about the refusal.

8.6 If:

(a) TFA is satisfied that, having regard to a purpose for which the Personal Information is held, the information is inaccurate, out-of-date, incomplete or irrelevant or misleading; or

(b) you request TFA to correct your Personal Information,
TFA will take reasonable steps to correct the Personal Information to ensure that, having regard to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading. TFA will not charge you for making such a request or for correcting the information.

8.7 If TFA refuses to correct the Personal Information at your request, TFA will provide you with a written notice that sets out the same matters listed in clause 8.5(b).

  1. Transborder data flows

9.1 Subject to clauses 9.2 and 9.3, TFA will not transfer your Personal Information to an overseas recipient unless it has first taken steps reasonable in the circumstances to ensure that the Personal Information that it transfers will not be held, used or disclosed by the recipient of the information inconsistently with, or otherwise in breach of, applicable privacy laws (including the Privacy Act). For example, TFA may adopt appropriate contractual clauses with overseas recipients that ensure their compliance with applicable privacy laws (including the Privacy Act). This clause does not apply to the transfer of Personal Information in accordance with TFA Rules, including to facilitate the registration of a Player by an international Touch Football association.

9.2 We may disclose your Personal Information to overseas recipients for things such as processing membership and hosting services.

9.3 TFA may transfer Personal Information about you to someone who is in a foreign country if:

(a) TFA reasonably believes that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that is, overall, substantially similar to applicable privacy laws (including the Privacy Act) and there are mechanisms available to you to enforce that protection or scheme; and

(b) you expressly consent to the transfer after TFA has informed you that the applicable privacy laws (including the Privacy Act) will no longer apply if you provide your express consent.

  1. Notifiable data breaches scheme

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, TFA will investigate and notify you and where applicable the relevant supervisory authority (e.g. the Australian Information Commissioner) within 72 hours of becoming aware of the loss, or unauthorised access or disclosure, in accordance with applicable privacy laws (including the Privacy Act).

  1. Inquiries procedure

11.1 All complaints and inquiries concerning your Personal Information, including in respect of alleged breaches of this Privacy Policy or applicable privacy laws (including the Privacy Act), should be directed to the TFA Privacy Officer:

The Privacy Officer
Suite 1
18 Napier Close
Deakin, ACT, Australia 2600
+61 6212 2800
TFAprivacyofficer@touchfootball.com.au

11.2 At all times, privacy complaints will be treated seriously, dealt with promptly and confidentially, and will not affect your existing obligations or commercial arrangements with TFA.

  1. Privacy Policy updates

This Privacy Policy was updated in April 2020. We may update this Privacy Policy from time to time, in which case we will post the updated version of the Privacy Policy on our website (www.touchfootball.com.au). As such, please check back periodically to see if our Privacy Policy has been updated.

  1. Definitions

In this Policy:

Affiliate means any Affiliate Member as defined by the TFA Constitution.

Competition means any competition, event, tournament or league registered or carried out by TFA, or Affiliates including pre-season, season proper, finals series and any post season tournament, event, or knockout cup competition and any other Touch Football competition, event or tournament.

Match means a game of Touch Football and includes any match staged, participated in, sanctioned by, or played under the auspices of TFA or Affiliates (including any match held as part of a Competition).

Match Official means any person in charge of safety or any other person appointed by TFA, the States or an administrator to assume responsibility in connection with a Match.

Minor means any person younger than 18 years of age.

NRL Account means a person's login credentials and personal account for accessing the NRL digital network, including TFA’s MySideline registration platform, the NRL website and application and fantasy/tipping websites and applications, etc.

NRL means National Rugby League Limited.

TFA Privacy Officer means the person appointed by TFA from time to time to deal with complaints and inquiries under this Privacy Policy.

TFA Rules means its constitution, rules, regulations, policies and procedures and any other ancillary document that governs TFA in administering the game of Touch Football, as promulgated and amended from time to time.

Official means:

(a) a Match Official or Team Official;

(b) an employee, consultant, officer or director of TFA or a Competition administrator; or

(c) a member of a council, committee, panel or body constituted by TFA or a Competition administrator.

Personal Information means any information or an opinion about an identified natural person, or a natural person who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

Participant means participants in the game of Touch Football including the Players and Officials.

Player means any person who is, from time to time, registered to an Affiliate or is selected as a member of a Representative Team.

Privacy Act means the Privacy Act 1988 (Cth).

Privacy Policy means this document as updated from time to time and made available on TFA's website (www.touchfootball.com.au).

Rugby League Exchange has the meaning given to that term in clause 1 of this Privacy Policy.

Touch Football Partners means any entity that has a commercial agreement or arrangement with TFA, Competition administrator or Affiliate (as the case may be) and which you may also have a direct relationship with (including by participation in a Competition).

Sensitive Information means information or an opinion about a natural person's racial or ethnic origin, political opinions, membership of 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 that is also Personal Information as well as health information, genetic information, biometric information for the purposes of verification/identification and biometric templates about a natural person.

Team Official means any personnel involved with the management, preparation or participation of an Affiliate’s team (whether paid or unpaid), including the coaches, managers, medical staff (including team or match day doctor), physiotherapists, gear persons and other support staff.

Updated May 2020