A man had been a member of a club ('Club A') and his continuing membership was conditional on his paying annual subscription fees. Club A terminated his membership on the grounds that he had not paid his subscription for the current period. The man claimed that he had paid the subscription. He also alleged that Club A disclosed to another club ('Club B') that his membership of Club A had been terminated.

The man complained to me that Club A had used inaccurate information to terminate his membership, that it compounded the error by disclosing the termination to Club B and that these actions amounted to an interference with his privacy.

I formed the view that the complaint did not have substance.

The complaint raised issues under principles 8 and 11.

Principle 8

Principle 8 requires agencies to take steps which are reasonable in the circumstances to ensure that personal information is accurate, complete, relevant and not misleading before acting upon the information.

Club A made the decision to terminate the man's membership by reference to its own subscription records.

The man said he had paid his fees and had the sticker on his membership card to prove this. Club A could not find a receipt issued in his name. It allowed the man to examine the subscription records for the relevant year and he, too, was unable to find any evidence of a receipt being issued in his name. Club A said that the sticker had been given to the man in error and was intended for another person with a similar name.

Principle 8 is not concerned with the quality of any decision, but with the quality of information used to make that decision. I formed the opinion that by checking the records Club A had taken reasonable steps to ensure the information was accurate before using it as a basis for making decisions about the man's continuing membership.

Principle 11

Principle 11 restricts the instances in which personal information may be disclosed. In this case I had to consider whether any of the exceptions contained in principle 11 allowed the disclosure to Club B.

Club A said it responded to an enquiry made by Club B about the man's membership. It explained that Club B granted reciprocal visiting rights to members of Club A. The man visited Club B after his membership of Club A had been terminated, which meant the rights were no longer available. The manager of Club B was alerted to this and asked Club A to clarify his membership status to ensure Club B complied with its licence for the sale and supply of liquor, which was limited to serving:
- members of the club;
- anyone who was a guest of and was accompanied by a member of the club; and
- members of other clubs with which the holder of the licence had an arrangement for reciprocal visiting rights.
Club A considered that, as one of the parties to the reciprocal arrangements, it had a responsibility to verify that the man was no longer entitled to avail himself of the reciprocal visiting rights.

I formed the opinion that confirming eligibility to enjoy reciprocal visiting rights was directly related to the purpose for which Club A held information about membership. I formed the opinion, therefore, that the disclosure to Club B was permitted by principle 11(a).

Indexing terms: Accuracy of personal information - Club - Membership terminated - Checking records before terminating membership was a reasonable step to ensure accuracy - Information privacy principle 8

Disclosure of personal information - Club - Information about terminated membership disclosed to another club - Disclosure to prevent breach of liquor licence - Disclosure a directly related purpose - Information privacy principle 11(d)

May 1999