Policies

Community Protection Policy Privacy Policy Complaint-handling Policy

Community Protection Policy

The Hobart Real Tennis Club (HRTC or the Club) is committed to providing a safe and secure environment for the entire club community, including employees, members, visitors, volunteers, and particularly for children and other vulnerable people.

Aims

Our core expectations as a responsible organisation are to treat all people with fairness and dignity and to care for those who are less powerful and in need of nurture and protection. This Community Protection Policy aims to reduce the risk of abuse occurring, and to ensure that a caring and appropriate response is taken should abuse occur.

Application

The HRTC Committee is committed to implementing this Community Protection Policy and to ensuring our employees, members, contractors and volunteers understand and implement its content and application. All new employees and members will be issued with a copy of this policy. This policy applies to all employees, members, volunteers, contractors and visitors within HRTC or engaged by HRTC. This policy will be reviewed annually by the HRTC Committee.

Definitions

Abuse can be one or more of, but is not restricted to, physical (including harassment or intimidation), financial, or emotional abuse (including bullying). A child is any person under the age of 18. A volunteer is any unpaid person over the age of 16 who is invited to assist in club activities.

Obligations

The Club is committed to adhering to all relevant legislation, including specifically the Children, Young Persons and their Families Act 1997 and the Registration to Work with Vulnerable People Act 2013. The HRTC Committee will actively encourage the maintenance of high standards of conduct at all times. Professional employees will be carefully selected and screened with at least two prior referee checks. Professional employment will be dependent on a satisfactory police check and Working with Children registration, in accordance with Tasmanian legislation. Two employees or volunteers will be present whenever a child is being coached or supervised.

Reporting abuse

The Club actively encourages the reporting of abuse and is committed to being an environment where a member feels able to report abuse. Details of those reporting abuse will be kept private and confidential. Abuse should be reported to either the President or Vice-President of the Club, who will appoint an independent person to investigate and deal with any allegations. Reasonable suspicions of abuse will be reported to the authorities and HRTC insurers.

Approved by the HRTC Committee April 2018

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Privacy Policy

This privacy policy explains how Hobart Real Tennis Club (HRTC) manages the personal data that we collect, use and disclose and how to contact us if you have any further queries about our management of your personal data. This privacy policy does not cover personal data collected or held by HRTC about its employees. HRTC adheres to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cwth) and protections afforded to residents of the EU under the General Data Protection Regulation (GDPR).

What is personal data?

Personal data includes personal information that identifies you as a person, or from which your identity could be reasonably ascertained. Personal data may also include financial information about your bank accounts and credit cards and sensitive information about your racial or ethnic origin and health information.

What types of data do we collect?

HRTC provides a number of different member services, including tennis club membership, a bar and kitchen, function facilities, the sale of goods and services through the pro shop, coaching, tournaments and more. In the course of providing member services, HRTC may collect a range of personal data about you. We collect information that is necessary for membership and the provision of our services. If you choose not to provide your personal or sensitive information, then we may not be able to provide you with our full range of services. The types of information collected will depend on the services you have asked us to provide, and may include your name, address, telephone and fax numbers and email address, age, date of birth, occupation and bank account or credit card payment details.

While we endeavour to collect personal data from you directly, in some instances we may also receive information about you from third parties, such as referees. We will record your email address if you send us an e-mail. For some services, we may collect and maintain sensitive information, including health and medical details, dietary requirements and allergies, emergency contacts and next-of-kin details. We will only use sensitive information in order to provide or facilitate medical assistance where first aid or emergency treatment is required, or as otherwise allowed under the APPs. When you browse our website, contact us electronically, or engage with us on social media, we may also record geographical tagging, cookies, your IP address and statistical data from your activity. We may use your personal data to customise and improve your user experience on our website and other social media platforms.

Who controls and processes your data?

HRTC is the data controller for your personal data. For some membership services, we use http://www.RealTennisOnline.com (RTO) as a data processor. For email services, we use MailChimp as a data processor.

How do we use your data?

HRTC will primarily collect, hold, use and disclose your personal data where it is reasonably necessary for us to carry out our organisation’s functions and activities. We may also use your personal data (usually your name) for inclusion on the online court booking system, newsletters and competition results. We may also use your personal data for related purposes which you would reasonably expect, such as providing you with details about other services offered by us, as well as any promotions or offers that may be of interest to you, including tournaments, tennis games or fundraising.

You can opt out of receiving offers or information at any time by notifying us. Opt out procedures are also included on all of our marketing and promotional communications.

In some cases, we may disclose your personal data to third parties, such as persons to whom we contract to provide services as required in order to provide you with services. For example, tennis club member information is shared with Australian Real Tennis Association (ARTA) for affiliation and insurance purposes and also keep your details updated on the online handicap etc. We will seek to ensure that third parties to whom we disclose are bound by confidentiality and non-disclosure agreements, if they are not otherwise required to adhere to the Privacy Act.

HRTC also discloses your personal data by utilising RealTools.biz which sources personal details from RTO. These personal details include name, handicaps, and RTO administration settings for organisations. RealTools.biz does not store RTO username or passwords. When a person logs onto RealTools.biz, these details are sent to the RTO system for authentication. We may also disclose your personal data where we have sought your consent or in accordance with the Privacy Act or any other legislation. Other than the personal data stored in RTO, we do not share your personal or sensitive information outside Australia, say to other real tennis clubs, unless you consent to such release.

We may also disclose your personal data to third parties (including government departments and enforcement bodies) where required or permitted by law. We also gather broad summary information on our membership, for example how many members are residents of which countries or how many members of what age category we have. We might, for example, share this summary information—but not any individual person’s data—with third parties when asking for support for our interests.

When organising playing activities, for example tournaments, we may share your name, contact details, and handicap information with the real tennis club hosting the event.

It is occasionally necessary for us to study technical web-browsing data, for example to investigate problems with our website or to see which pages are popular, so we can ensure our website content is of interest to its readers. We do not share this data with any other person or organisation. We retain this data for the period of time set by our web hosting service and website content management software.

How long is your data retained for?

We retain personal data for as long as it is required for any of our functions or for any other lawful purpose.

How is your data stored?

Your personal and sensitive information is stored electronically, on paper, or both. HRTC has physical, electronic and procedural safeguards in place and takes reasonable steps to ensure that your information is protected from misuse, interference and loss, and from unauthorised access, modification and disclosure. Credit card details are held electronically in encrypted and locked forms in our accounts.

Please be aware that personal data provided by email may not be secure. If you have any concerns regarding the security of your personal data, please provide it in an agreed alternate form. HRTC uses secure methods to destroy or permanently de-identify your personal data.

Your data rights and how to exercise them

You have various rights in connection with your data. The following paragraphs explain how these rights are upheld by HRTC.

The right to be informed

You have a right to be informed about the collection and use of your personal data. For example, you have a right to know the purposes for which it is kept and with whom it will be shared. This Privacy Policy provides you with this information.

The right of access

You have a right to access your personal data that is being held. In order to receive information about your data as held by HRTC, please contact us.

The right to rectification

If any of your data as held by HRTC is incorrect, please notify us and we will promptly correct it.

The right to be forgotten

You can unsubscribe from HRTC’s email list at any time using the link at the bottom of every email. When you unsubscribe, your data is retained and your account is marked as “unsubscribed”. Instead, or as well as doing this, you can make a request to have any data held about you permanently deleted. Please be aware, though, that this will stop us being able to work with you, as we will have no record of your membership.

The right to restrict processing

You may ask HRTC to not process your data. For the email list, this is also known as “unsubscribing”. After unsubscribing, you will no longer receive any emails from HRTC at the subscription address. A link to unsubscribe is included in every email. Alternatively, please contact us if you want us to unsubscribe your email address or you would like us to stop processing your data. Please be aware, however, that this will stop us being able to work with you, as in “the right to be forgotten” above.

The right to data portability

You have a right to obtain a copy of the data you have explicitly provided to HRTC to reuse for your own purposes or across different services. If you would like a copy of the data HRTC holds on you in a form suitable for these purposes, please contact us.

The right to object

You have the right to object to processing at any point in time. The same conditions apply as described in “the right to restrict processing” above.

Rights in relation to automated decision-making and profiling

HRTC does not carry out any automated decision-making or profiling activities.

Contacting HRTC

If you have any questions about how HRTC collects, uses or discloses your personal data, please contact us.

Approved by the HRTC Committee July 2019

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Complaint-handling Policy and Procedure

Purpose

This policy and procedure provides members and employees of the Hobart Real Tennis Club (HRTC) (“Club”) with a well-defined structure and process for handling all forms of complaints, from minor infractions of the rules to serious breaches that demand prompt disciplinary action by the Club. This will ensure that all complaints are handled consistently, promptly and fairly.

Complaints Panel

Authority

The Complaints Panel (“Panel”) is authorised by the HRTC Committee (“Committee”) in accordance with rule 22(2) of the HRTC Club Rules and By-laws (“Rules”). The Panel is appointed as a subcommittee under rule 29(1). The powers of the Panel are limited by the Committee and the Rules. In particular, rule 33 requires that only the Committee has the power to expel a member.

Scope

The Panel handles all complaints concerning the behaviour of members, on and off court, including but not limited to:

  • Unsportsman-like conduct
  • Dangerous play
  • Dress code violations
  • Public safety
  • Inappropriate behaviour
  • Theft
  • Sexual harassment
  • Bullying and intimidation
  • Violent and abusive behaviour

The scope explicitly excludes complaints regarding the actions of employees of the Club or the policies of or decisions taken by the Committee or subcommittees. Complaints regarding an employee or committees must be handled directly by the Committee.

Any complaint received by the Panel concerning a potential criminal act must be referred to the police without delay.

Where this policy conflicts with the HRTC Community Protection Policy, the Community Protection Policy takes precedence.

Appointment

The Panel comprises two members, each with an alternate. The Chair is the President, with the Vice-President as their alternate. The second member and their alternate are senior members, elected by the Committee.

Procedure

Submission

Complaints can be submitted by any member, employee, or guest of the Club.

Complaints should be submitted by email or by mail to the President care of the Club.

Submit a complaint

Where the complaint is against a member of the Panel, an alternative method of submission will be provided.

Process

The Panel meets on an as-needs basis, according to the seriousness and volume of complaints. Any member of the Panel or their alternate can schedule a meeting. If a member of the Panel is not available, the meeting is not delayed, and the alternate attends in their place.

On receiving a complaint:

  1. The Chair confirms receipt of the complaint by return email or mail to the complainant.
  2. If the complaint is of a serious nature, the Chair schedules a meeting of the Panel within 14 days of receipt. Otherwise it will be dealt with at the next scheduled meeting.
  3. The Panel reviews the complaint and determines what action should be taken.
  4. The Chair reports any actions taken at the next Committee meeting.
  5. On concluding a complaint, the Chair advises the parties involved of the outcome.
  6. The Panel maintains confidential, permanent records of all complaints, including rejected complaints and any actions taken, copies of all correspondence, and records of interviews.

Reviewing complaints

  • All complaints are confidential. The name of the complainant must not be disclosed to the respondent or the Committee without their permission.
  • Where the complaint is against a Committee member, it will be dealt with in the same manner as a general member.
  • Where the complaint is against a member of the Panel, they will be replaced by their alternate.
  • The complaint must contain the following information:
    • The name of the complainant (anonymous complaints will be rejected)
    • The name of the respondent
    • A description of the alleged breach of the Rules or incident
    • The date and time of the incident
    • If available, the names of any witnesses e.g. pennant team members or dedans spectators.
  • If a complaint is missing key information, the Chair must request more information from the complainant and delay review until all information has been provided.
  • The Panel determines whether an investigation is required based on the seriousness of the alleged breach. The Panel exercises their discretion to determine the manner in which an investigation is conducted and by whom. Most investigations will be conducted by the Panel, but in more serious cases, it may be appropriate to engage an external party. The cost of conducting an investigation, such as engaging an external party, must be approved by a minimum of two members of the Executive.
  • Complaints must be dealt with expeditiously, especially where the matter is of a serious nature.
  • The Panel determines an appropriate action based on:
    • The seriousness of the alleged breach
    • The known history of the respondent
    • The complaints history of the complainant

Guidelines

Application

  • This complaints procedure is the means by which the Rules are enforced. If the Panel considers that this procedure or the Rules are inadequate or ambiguous or inappropriate, they should refer their concerns to the Committee for discussion and decision. For example, if the Club’s dress code is considered to be unduly onerous or arbitrary, it is not within the prerogative of the Panel to decide if the dress code is sensible: they simply decide if a rule was breached and decide what action should be taken.

Confidentiality

  • The details of a complaint are confidential and must not be disclosed to any person, including members of the Committee, except as described in this procedure.
  • When, and only when, a matter is referred to the Committee for suspension or expulsion, the details of the incident, with one exception, will be fully disclosed to the Committee. The name the complainant, however, must not be disclosed without their permission.

Mandatory reporting

  • As a condition of their employment, employees of the Club are expected to monitor members’ compliance with Club Rules and Rules of Play. When they become aware of a matter of a serious nature, they are required to lodge a complaint using the process described in this procedure.
  • As a matter of the Club’s duty of care, when a member makes a verbal complaint to an employee or a Committee member of a serious nature about the behaviour of another member, the employee or Committee member must lodge the complaint on the member’s behalf.

Conflict of interest

  • If the Panel member considers they have a conflict of interest, e.g. the complainant or the respondent are relatives or part of their close friendship group, they should recuse themselves from the review or investigation.

Serious matters

  • If the matter involves a potential criminal breach against a person, it must be referred to the Tasmania Police immediately.
  • Where a matter is considered to be of a serious nature, the Panel must undertake an investigation. The investigation should include interviews with the complainant, witnesses and the respondent. The respondent must be provided with an opportunity to respond to the complaint.
  • Where a matter is considered to be of a serious nature, the Panel may at their sole discretion temporarily suspend the respondent while the complaint is investigated.
  • The Panel should determine whether the incident occurred on the basis of “the balance of the facts”. If, in the opinion of the Panel, there is reasonable doubt about the details, the complaint should be rejected.
  • All decisions must be unanimous. A split decision indicates there is reasonable doubt.

Less serious matters

  • Matters of a less serious nature, such as dress code violations, are expected to be dealt with by issuing written warnings.

Reporting

  • Subject to considerations of confidentiality (see above), the Panel will submit a report to next Committee meeting summarising all complaints received and actions taken.
  • As a general guide, the Panel’s report will contain the following information for each complaint:
    • Date of complaint
    • Respondent’s name
    • Nature of the breach
    • Action taken (rejected, warning, investigated, referred)
    • Date of action

Actions

The Panel is authorised by the Committee to take the following actions with regard to a complaint:

  • Reject the complaint.
  • Issue a warning by email (from the Chair).
    • Warnings should only be issued where it is a first breach and/or not of a serious nature.
    • For repeated or more serious breaches, the Panel can only reject the complaint or recommend suspension or expulsion.
  • Temporary suspension.
    • When the alleged breach is serious, the respondent may be suspended temporarily while the complaint is investigated.
    • While suspended, the respondent must not attend the Club premises and must avoid all contact with the complainant. If the respondent ignores these instructions, they will be immediately referred to the Committee for suspension or expulsion.
  • Refer to the Committee recommending suspension.
    • The Panel can recommend a period of suspension between 1 to 12 months.
    • Made in any case where the member repeatedly flouts and disregards the Rules or the member’s behaviour is considered to be unacceptable and has the potential to cause harm to the Club or bring the sport into disrepute.
    • While suspended, the respondent can only attend the Club premises at the invitation of the Committee. If the respondent ignores these instructions, they will be referred to the Committee for expulsion.
    • A suspended member is charged their normal monthly membership fee and is expected to maintain their account in good order. A member suspended by the Panel can resign but cannot change their membership class while they are suspended.
  • Refer to the Committee recommending expulsion.
    • Made in cases where the member has either been previously suspended (for any reason) or, in the first instance, the breach is of such a serious nature that, in the opinion of the Committee, the member fails the test of being of “good character”.
  • Refer to Tasmania Police.
    • Where a potential criminal act has occurred.

Record-keeping

The Committee must provide the Panel with the means to permanently and securely store the details of all complaints, including rejected complaints. Only the Panel are permitted to have access to this information. Provision should be made to create regular backups of the stored information.

Approved by the HRTC Committee December 2019

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