1. W. Short Hospitality and privacy
W. Short Hospitality is one of Australia’s leading hospitality groups. In operating our restaurants, bars, events and related hospitality businesses, W. Short Hospitality collects and handles personal information.
W. Short Hospitality understands the importance of protecting the privacy of an individual’s personal information and being open and transparent in how we handle and deal with personal information.
(a) Privacy Act means the Privacy Act 1988 (Cth);
(b) W. Short Hospitality means
(i) Shortcorp Management Pty Ltd
(ii) Together with W. Short Hospitality; and
(c) W. Short Hospitality Events means any public, corporate, private or other events conducted or organised by W. Short Hospitality or any events sponsored by W. Short Hospitality;
(d) W. Short Hospitality Venue means the hotels, bars and other venues operated by W. Short Hospitality;
(e) Together with W. Short Hospitality means the Trustee for Shortcorp Management Ltd, ABN 70117481222, trading as W. Short Hospitality; and
(g) We, us, our means W. Short Hospitality;
3. Compliance with Privacy Act
In collecting, holding, using, disclosing and otherwise managing personal information, W. Short Hospitality will comply with the Privacy Act and the Australian Privacy Principles in the Privacy Act.
4. Collection of personal information
Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, W. Short Hospitality may collect your personal information.
W. Short Hospitality provides a diverse range of hospitality services and experiences. As a result, the kinds of personal information that W. Short Hospitality collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information W. Short Hospitality collects may include:
(a) contact and identification information such as your name, address, telephone number and email address (for example where you make a reservation at a W. Short Hospitality Venue or join one of our mailing lists);
(b) information regarding your ordering history, food or beverage or other dining preferences, to assist us to provide a more customised dining experience;
(c) payment information, such as credit card or other payment details;
(d) where you organise or conduct an event using W. Short Hospitality, information regarding the event, your guests and any relevant requirements;
(e) information regarding your experience at a W. Short Hospitality Venue (for example as part of our guest feedback activities or where you contact us with feedback); and
(f) where you apply for employment with W. Short Hospitality (in addition to contact and identification information detailed above) information relevant to us considering your application for employment including information in relation to your CV, employment history, qualifications and references.
Depending on the W. Short Hospitality Venue you visit, we may also collect identification information, such as driver’s licence or passport information. We generally collect this information because we are required to do so by law and/or for venue, patron and employee security purposes. Specific information regarding the collection and handling of this type of personal information will be available at the relevant venue.
W. Short Hospitality also collects CCTV footage at many of W. Short Hospitality Venues, including for venue, patron and employee safety purposes. Details of suspected or actual illegal or improper conduct (including CCTV footage relating to that conduct) may be shared with relevant law enforcement or regulatory bodies.
At some W. Short Hospitality Venues or W. Short Hospitality Events, we may also take photographs or other images or content (such a video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images or other content are being taken and the purposes for which they are being used. By attending such a W. Short Hospitality Venue or W. Short Hospitality Event, you consent to us taking such photographs, images or other content and using those photographs, images or other content, including at the venue and on W. Short Hospitality websites and social media sites.
W. Short Hospitality may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where W. Short Hospitality does collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency. If we do collect sensitive information about you, we will only do so with your consent or where we are required or authorised to do so by law.
5. Collection of personal information by W. Short Hospitality
Generally, W. Short Hospitality collects your personal information directly from you. For example, W. Short Hospitality may collect your personal information where:
- you make a reservation for a W. Short Hospitality Venue or a W. Short Hospitality Event;
- you join one of our mailing lists, fill out a survey, enter a promotion, request services or otherwise provide us with your details;
- you dine at or attend a W. Short Hospitality Venue;
- you stay at any W. Short Hospitality Venue that provides accommodation services;
- you organise an event with W. Short Hospitality or participate in or attend an event organised by W. Short Hospitality;
- you sign up to or participate in any W. Short Hospitality loyalty program;
- you provide feedback to us regarding your experience at a W. Short Hospitality Venue or your other interaction with W. Short Hospitality;
- you post information to any of our social media sites;
- you attend a W. Short Hospitality Event; or
- you apply for or express an interest in employment with us.
We generally collect personal information directly from you. However, there may be occasions when W. Short Hospitality collects your personal information from someone other than you, for example from:
- other entities within W. Short Hospitality;
- our service providers or contractors (for example where we appoint a service provider/contractor to assist with conducting an event);
- an information services provider;
- a publicly maintained record or other publicly available sources of information including social media and similar websites; or
- a referee or previous employer where you apply for employment with W. Short Hospitality.
6 Purposes for which personal information is used
Generally speaking, W. Short Hospitality collects and uses personal information so that we can provide our hospitality services, interact with you in relation to our services and venues and administer and manage our business and our venues.
Some examples of the purposes for which W. Short Hospitality collects, holds, uses and discloses your personal information include to:
- take bookings for W. Short Hospitality Venues or W. Short Hospitality Events;
- provide dining and other hospitality experiences at W. Short Hospitality Venues;
- provide our event services to you;
- manage and administer the provision of our services and our relationship with you;
- verify your identity;
- maintain venue, patron and employee safety;
- enable us to supply you with information you request from us;
- conduct promotions, competitions, giveaways and events;
- contact you to obtain your feedback regarding our products or services or to conduct other market research;
- provide you with marketing information regarding W. Short Hospitality and our venues (as further detailed in paragraph 7 below);
- analyse information we collect so that we can administer, support and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information;
- comply with the obligations of W. Short Hospitality under any applicable laws; and
- consider any application you make for employment with us.
In addition to the purposes listed above, W. Short Hospitality may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law. Where personal information is used or disclosed, W. Short Hospitality takes reasonable steps in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.
You are under no obligation to provide your personal information to W. Short Hospitality. However, without certain information from you, W. Short Hospitality may not be able to provide services or information to you or may be limited in how we can interact with you.
7. Direct marketing
In addition to the purposes outlined in paragraph 6 above, W. Short Hospitality may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. Where you make a booking at a particular W. Short Hospitality Venue or sign up for the mailing list of a particular W. Short Hospitality Venue, this may include sending you information about that W. Short Hospitality Venue or other W. Short Hospitality Venues, W. Short Hospitality Events or services that may be of interest to you.
In doing so, W. Short Hospitality may disclose your personal information to the companies within W. Short Hospitality or other entities with which W. Short Hospitality has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.
These communications may be sent using email, telephone, SMS, social media or other similar forms of communication.
8. Disclosure of personal information
- the companies or other entities within W. Short Hospitality;
- our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, data analytics service providers, bookings or reservation systems providers, event service providers or other business or administration service providers);
- W. Short Hospitality’s auditors, tax, insurance, legal or other professional advisors;
- persons or entities considering acquiring an interest in W. Short Hospitality’s business or assets; or
- W. Short Hospitality’s insurance providers.
W. Short Hospitality may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorised by law. Examples of disclosure that may be required or authorised by law include disclosure to law enforcement bodies, liquor and gaming regulators or under Anti-Money Laundering and Counter-Terrorism Financing laws.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
9. Overseas disclosures
Some of the parties that W. Short Hospitality discloses your personal information to may be located outside Australia. We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.
10. Links to other websites
11. Cookies and website statistical information
W. Short Hospitality may collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. We use this information to analyse how our websites and other online services are being used and seek to improve our websites and other online services and provide more user friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.
12. Security of personal information
W. Short Hospitality takes the security and protection of the personal information we hold seriously. We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
W. Short Hospitality will destroy or de-identify personal information in circumstances where it is no longer required, unless W. Short Hospitality is otherwise required or authorised by law to retain the information.
13. Access and correction
W. Short Hospitality takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by W. Short Hospitality. If at any time you would like to access or correct the personal information that W. Short Hospitality holds about you, or you would like more information on W. Short Hospitality’s approach to privacy, please contact W. Short Hospitality Privacy Compliance Officer using the details set out in paragraph 14 below. W. Short Hospitality will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- W. Short Hospitality requests that you be reasonably specific about the information you require; and
- W. Short Hospitality may charge you a reasonable administration fee, which reflects and will not exceed the cost to W. Short Hospitality for providing access in accordance with your request.
W. Short Hospitality will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If W. Short Hospitality refuses your request to access or correct your personal information, W. Short Hospitality will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with W. Short Hospitality’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
14. Contacting W. Short Hospitality
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact W. Short Hospitality’s Privacy Compliance Officer using any of the following contact details:
Privacy Compliance Officer
Phone: 02 9241 2711
Post: Level 1, 100 Cumberland Street, The Rocks NSW 2000
15. Privacy complaints
Please direct all privacy complaints to W. Short Hospitality’s Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and W. Short Hospitality.
W. Short Hospitality will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless W. Short Hospitality informs you otherwise and seeks your agreement in writing.
W. Short Hospitality will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which W. Short Hospitality will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.
Annexure A: W. Short Hospitality entities
- Royal Hotel Operations Pty Ltd – ABN 20197591687, trading as The Royal Hotel Leichhardt
- Seabreeze Beach Hotel SWR Pty Ltd – ABN 32481070520, trading as Seabreeze Beach Hotel
- The Trustee for Glenmore Trading Unit Trust – ABN 48394934225, trading as Glenmore Hotel
- The Trustee for Hotel Australian The Rocks Trust – ABN 60086096161, trading as Australian Heritage Hotel
- The Trustee for Redfern Operations Unit Trust – ABN 65627040023, trading as Tudor Hotel
- The Trustee for Toormina Hotel Operations Trust – ABN 72612590566, trading as Toormina Hotel
- The Trustee for Redfern & Co Operations Unit Trust – ABN 42750703203, trading as Misfits Bar & Dining
- The Trustee for Sawtell Operations Unit Trust – ABN 14743143584, trading as Sawtell Hotel
- The Trustee for P & P WW Trust – ABN 96121641349, trading as Palm & Pawn
- The Trustee for Shorty’s Liquor CBD Unit Trust – ABN 44036395077, trading as Shorty’s Liquor
- Connection Creek Pty Ltd – ABN 51107804946, trading as Rancho Relaxo, Crescent Head