PRIVACY POLICY                                                                         



1 Purpose and Scope



1.1   Purpose:

This document sets out our policy and commitment to protecting the privacy of the information it collects about individuals, including players, prospective players, parents and staff in compliance with its legal and regulatory obligations.



1.2  Scope:

This Policy applies to:

  • All staff
  • All players and parents
  • All contractors and consultants and agents we use when collecting and/or dealing with personal information on behalf of the ACPE Football Academy Pty Limited trading as Liverpool FC International Academy NSW or Liverpool FC International Academy

1.3   References

  • References in this policy to ‘Liverpool FC International Academy NSW’, ‘Liverpool FC International Academy Australia’, ‘LFCIA’, ‘we’, ‘us’, ‘they’, ‘our’ or ‘them’ means ACPE Football Academy Pty Ltd (ABN: 73 647 696 446) trading as Liverpool FC International Academy NSW and Liverpool FC International Academy Australia.
  • References to ‘programs’ mean any program, clinic, camp, training session(s), event, course delivered by Liverpool FC International Academy NSW or Liverpool FC International Academy Australia.
  • References to parent(s) means the parent(s) or legal guardian(s) of the child or children registered for our programs, registering interest in our programs or visiting our website.
  • References to the ‘player’, ‘child’ or ‘participant’ mean the child or children who has been registered and is participating in our programs.
  • References to ‘staff’ means any coaches, support staff, contractors or agents involved in the management, administration or delivery of our programs or the along with collecting and/or dealing with personal information acquired in the operation of our programs.

2 Definitions


2.1. Approved third parties


Any institution with which we have entered into a Memorandum of Understanding (MOU). External service providers, partner schools where we deliver programs, our Australian partners The Australian College of Physical Education (ACPE) and its subsidiaries and Liverpool Football Club and its subsidiaries are also included in this definition.


          • Health information has the meaning provided in section 6 of the Health Records and Information Privacy Act 2002 (NSW).

“(a) personal information that is information or an opinion about:

the physical or mental health or a disability (at any time) of an individual; or an individual’s express wishes about the future provision of health services to him or her, or a health service provided or to be provided to an individual; or

          • other personal information collected to provide, or in providing a health service, or
          • other personal information about an individual collected in connection with the donation, or intended donation, of an individual’s body parts, organs or body substances, or
          • other personal information that is genetic information about an individual arising from a health service provided to the individual that is or could be predictive of the health (at any time) of the individual or of any sibling, relative or descendant of the individual, or
          • healthcare ”
          • Health privacy principles (HPPs) means the principles set out in Schedule 1 to the Health Records and Information Privacy Act 2002 (NSW):
          • Information: Information in electronic or hard copy form, including written records, photographs, images, video or audio footage, and health
          • Information protection principles (IPPs) mean the principles set out in Part 2 Division 1 of the Privacy and Personal Information Protection Act 1998 (NSW).
          • Notifiable privacy breach has the meaning given in clause 9 of this personal information has the meaning provided in section 4 of the Privacy and Personal Information Protection Act 1998 (NSW).
          • Privacy Acts means either or both of the Privacy and Personal Information

Protection Act 1998 (NSW) (the ‘PPIP Act’) and the Health Records and Information

Privacy Act 2002 (NSW) (the ‘HRIP Act’).


          • Personal information: Any information that identifies an individual, whether recorded in a material form or not and whether true or Personal information related to the player or parent that is commonly collected by us may include:
          • name
          • address (residential, postal and email)
          • phone number
          • date of birth
          • gender
          • banking and credit card details
          • emergency contact details
          • photographs or video recordings, including CCTV footage
          • metadata from use of online services and facilities
          • social media account details; or
          • information in regard to use of our website, social media platforms/pages, products and services.
          • Privacy breach means when personal or health information held by us is: lost; or subjected to, or likely to be subjected to, unauthorised access, modification or
          • Sensitive information: As defined in the Privacy Act 1988 is:
          • Information or an opinion about an individual’s:
            1. racial or ethnic origin; or
            2. political opinions; or
            3. membership of a political association; or
            4. religious beliefs or affiliations; or
            5. philosophical beliefs; or
            6. membership of a professional or trade association; or
            7. membership of a trade union; or
            8. sexual orientation or practices; or
            9. criminal record
          • health information about an individual; or
          • genetic information about an individual that is not otherwise health information; or
          • biometric information that is to be used for the purpose of automated biometric verification of biometric identification; or
          • biometric
          • Unsolicited Information We may receive personal information without having sought it through its normal means of

3.   Policy


3.1   Statement of Intent

          • In the course of its normal business of providing football player and football coach education programs, we collect, store and use personal information. The marketing, sale and delivery of football programs will often involve the collection of personal While we treat this information with the highest standards of security, confidentiality and privacy, there are occasions when we may disclose this information to third parties where required to by law, or where necessary for the efficient conduct of our its business.
          • Our Privacy Policy seeks to:
            1. Ensure personal information is collected, stored, and used in accordance with the Privacy Act 1988 and the associated 13 Privacy
            2. Acknowledge our responsibility in ensuring that stakeholder information is
            3. Protect the privacy of stakeholders by ensuring that only relevant personal information, which is necessary to provide products and services, is
            4. Ensure that all personal information collected, used or disclosed is accurate, complete and up-to-date.
            5. Ensure that an individual’s consent is obtained prior to the collection of sensitive
            6. Take reasonable steps to make an individual aware of:
              1. Why we are collecting information about them
              2. With whom this information will be shared; and
          • Other specified matters

(g) Destroy or permanently de-identify personal information if we no longer needs it for any purpose for which it may use or disclose information.


          • We also collect statistical information which cannot be related to any specific individual for continuous improvement purposes and does not provide personal information to external parties for marketing


3.2   Our Responsibilities in the Collection of Personal information


          • When we collect personal information, it undertakes to inform the individual why it is
          • We will not collect personal information unless it is reasonably necessary to enable it to:
          1. Provide services to parents and players enquiring about joining our programs
          2. Process registrations for our programs
          • Recruit staff and generate staff contracts
          1. Communicate with players, parents, staff and ex players or their parents
          2. Maintain appropriate administrative and financial records
          3. Perform other internal administrative functions
          • Provide required data to the Commonwealth or State government departments to comply with any legal and regulatory
          • We collect sensitive information only if the individual has consented to its collection and the information is reasonably necessary to our business or activities, unless we are required to collect such information by Australian law or a court / tribunal
          • Before or at the time of collecting personal information from an individual or where not practicable as soon as practicable after its collection, we will take reasonable steps to provide a Privacy Statement to the
          • Different personal information may be collected and held in different forms depending on how the individual interacts with the
          • If an individual contacts us for any reason, there may be a record of the individual’s name, address, email address, phone number or other contact details kept.


3.3        Sensitive information


          • We collect minimal data classified as sensitive information. Sensitive information as relating to health must be collected with the consent of the individual unless it is required by law or unless it is necessary to prevent or lessen a serious and imminent threat to the life or health of that
          • All sensitive information is collected and stored in compliance with other personal information as it relates to the Australian Privacy


3.4        Anonymity and pseudonymity


          • There are circumstances where an individual may wish to remain anonymous or use a pseudonym such as searching or enquiring about our programs, gaining background information about us as an organisation and while exploring the public features of the website without making an identity known to us.
          • We may not, however, be able to provide appropriate products or services which an individual may request without the required and correct personal


3.5        Quality of personal information


          • We will take all reasonable steps to ensure that the personal information it collects, uses or discloses is, having regard to the purpose of the use or disclosure, is accurate, up to date and complete.
          • Procedures undertaken to ensure data quality include:
            1. Regular training of all relevant stakeholders in use of the online options to update personal information.
            2. Verification of personal information during contact.
          • Audit of any undeliverable email or mail (including relevant contact and updating).


3.6          Holding and securing personal information


          • We take reasonable steps to protect personal information from unauthorised access, modification or We are mindful of the importance of data security matters and treat personal data with the utmost care and respect.
          • We secure access to all transactional areas of our website using ‘https’ technology.
          • Access to personal data is restricted and secure, and sensitive personal information such as health information is secured via password protection and encryption.
          • Except where required by law to be kept, personal information is destroyed or permanently de-identified when no longer
          • 3.7.5 Where personal data is stored digitally, it is located within Australia only, on site and in a secure back-up data base off campus.


3.7        Disclosure of Personal Data


          • We will take reasonable steps to ensure that personal information is not disclosed to a third party except in certain permitted situations, including:
            1. Where we have obtained the individual’s consent
            2. It is necessary to provide the information to a third-party who provides services to us
            3. Approved as defined in this
            4. 3.8.2 Where disclosure is required or authorised by law or regulatory obligations
          1. 3.8.3 Other third parties we work with which may include:
          1. Education agents
          2. IT companies supporting our website
          3. cloud storage companies
          4. customer relationship management application providers
          1. educational establishments
          2. regulatory authorities
          3. accommodation providers
          4. online webinar providers


3.8             Cross-border disclosure of personal information


We will only transfer personal information about an individual to someone (other than within our business or the individual) who is in a foreign country if:


          • We reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian National Privacy Principles; or
          • The individual consents to the transfer; or
          • The transfer is necessary for the performance of a contract between the individual and the College, or for the implementation of pre-contractual measures taken in response to the individual’s request; or
          • The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between the organisation and a third party; or
          • All of the following apply:
            1. The transfer is for the benefit of the individual;
            2. It is impracticable to obtain the consent of the individual to that transfer;
            3. If it were practicable to obtain such consent, the individual would be likely to give it; and
            4. ACPE has taken reasonable steps to ensure that the information, which is transferred, will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy


3.10        Withdrawal of consent


Whenever an individual has given consent to use their personal data, they have the right to change their mind at any time and withdraw their consent.


3.11        Individual Rights

          • We take reasonable precautions to ensure that the personal information collected is accurate, complete and current. It is important that players, parents, and staff ensure we are kept up-to-date with changes to their personal information, especially in regard to name and contact
          • An individual has the right to request access to their personal information which we hold holds and to have it corrected at no charge if there is substantiated evidence of any
          • We reserve the right to withhold personal information where its disclosure is restricted by law, is the subject of legal action, or may compromise the privacy of another person.


3.12      Access to Personal Information


          • We understand that open communication with individuals in relation to access to personal information is necessary to gain trust and to build a
          • In relation tour Privacy Policy, giving access means that on request, and if none of the Australian Privacy Principles exceptions apply, we must give an individual access to information it holds about the individual that falls within the definition of personal information. This includes information it has collected from third parties and information it has received unsolicited and added to its

4   Related Documents



Policies and procedures:
  • General Terms and Conditions
  • Staff Code of Conduct
  • Player and Parent Codes of Conduct
  • LFCIA Values