Policy 104 Access to Information


Rainbow Club Australia is committed to transparency in its operations and to ensuring it is open to public scrutiny. It will balance upholding the rights of individuals to privacy while respecting the confidentiality required to run the organisation.

Rainbow Club Australia will prevent unauthorised persons gaining access to an individual’s confidential records and permit individuals access to their own records when this is reasonable and appropriate.

Accordingly, access to some Rainbow Club Australia documents and records will be limited to specified individuals and not be available to others for viewing.

This policy applies to the internal records, member records and unpublished materials
of Rainbow Club Australia.


Member records

• Member records will be confidential to club management, teachers and
administrative staff
• Information about members may only be made available to other parties with the
consent of the member and/or their parent/guardian
• All member records will be kept securely within the Salesforce system operated by
Rainbow Club and updated, archived and destroyed according to the organisation’s
member records policy

Board records

• Board minutes will be open to members of the organisation once approved as a true
record by the Board, except where the Board passes a motion to make any specific
content confidential
• All papers and materials considered by the Board will be open to members of the
organisation following the meeting at which they are considered, except where the
Board passes a motion to make any specific paper or material confidential
• The minutes, papers and materials from any sub-committee meeting will be open to
Board members and relevant staff, but not to the members of the organisation

Staff records

A personnel record is held for each administrative staff member and teacher and contains
• Contact details of staff member and contact details in case of emergency
• Swimming teacher qualifications
• Working with Children Check No and verification information
• Bank Account and Superannuation Account Information

Payroll is outsourced to ADP Payroll Solutions and all information regarding payroll
and superannuation is held on the ADP system.

Access to personnel information is restricted to:
• The individual staff member accessing their own file
• Relevant club management and administrative staff

Corporate records

Corporate records are those that contain confidential or commercially sensitive information about the organisation’s business. They include:
• Financial accounts and records
• Taxation records
• Corporate correspondence with Fair Trading NSW and other Government agencies
• The corporate key and other access or user name information
• Records of staff or other internal meetings
• Project management files
• Contracts between the organisation and other parties
Access to these records is limited to administrative staff and Board members.

Requests for Access – General Records

All records and materials not falling into the categories above may be released to the
public at the discretion of the General Manager. Any request for access to information
should be directed to the General Manager, who will:
• Make available to staff or Board/Club management information that they are
entitled to access
• Refer any request from Rainbow Club members or members of the public to the
appropriate person
In considering a request, the General Manger will take into consideration:
• A general presumption in favour of transparency
• The relevant provision of the Rainbow Club Australia constitution regarding information to be made available
• The business, legal and administrative interests of Rainbow Club Australia, including
commercial confidentiality and privacy obligations
• Where an external party requests access to information that requires staff to devote
time to collating, copying or otherwise making material accessible, the General
Manager may determine a subscription to be charged

Requests for Access – Member Records

All members have the right to access their records and advise the organisation about
• Any request for access to information should be directed to the General Manager
• The General Manger will maintain a record of member requests to access files
• Make fair and appropriate decisions about permitting or refusing access to
personal information
• Provide access for members or former members to access their own
confidential information
• Advise members refused access to personal information how to appeal
(if appropriate)
• Enable members to change records they believe to be inaccurate or misrepresenting
when appropriate
Requests for information about members from outside agencies or individuals will be
referred to the General Manager. Before any information is released, the General Manger will contact the member concerned to obtain consent.


Individuals who are refused access to their own records or information files may appeal
by following the Compliments, Complaints and Grievance Policy as outlined in the
Club Manual.



Documents related to this policy
Related policies
P101 Member Rights and Safety
P108 Compliments and Complaints

Forms, record keeping  or other organisational documents
Welcome Letter to Teachers and New Staff
Rainbow Club Employment Conditions
Employment Form
Welcome Letter to New Parents
Club Charter
Club Manual