Privacy at Lifestyle Club Events: A Checklist for Owners

This checklist is for owners of private lifestyle clubs in the US and Canada. It follows one night in order: before it, at the door and after it. Each step covers what your club holds on the people who come, and what your staff do with it.

It rests on one line from the FTC's guide for businesses: "Keep only what you need for your business" (FTC). What you never collect can't leak. A plan for a leak or a lost phone, the law and how Enclave fits come at the end. This is general information, not legal advice.

Before the night

What your invitation shows

An invitation travels further than your guest list. Its subject line shows on lock screens. Its calendar entry can land in a shared family or work calendar. A forwarded email carries everything in it.

• Name the night neutrally. The name appears in emails, calendar entries and notifications. Choose one you'd be at ease seeing on a screen at work.
• Write subject lines and preview text the same way. People see them before they open the email.
• Use your own artwork, or a photo of the empty venue. Never use photos of members, even cropped or from behind.
• Decide when guests get the address. Your own venue's address may be public already. For a party in a member's home, the address is their privacy too. Send it only to confirmed guests, close to the night.
• Keep public posts to the night itself. A post on social media or a directory gives the date and the kind of night, never who is coming.
• Know what card statements say. A member's statement shows your billing descriptor, which the payments guide covers.

Who on your team sees the guest list

Give each person on your team their own account, with only the access their job needs. The FTC calls this the "principle of least privilege" (FTC). A shared login hides who looked at what, and removing one person means changing it for everyone.

A starting point you can adapt:

• You and your managers: everything, including real names, payments and incident reports.
• Whoever reviews applications: applications, answers and verification photos.
• Door staff: tonight's guest list and each guest's photo, for their shift.
• Bar staff, DJs and photographers: a headcount at most.
• The venue or a security company: the name each guest goes by and the size of each party. Take the list back at the end of the night.

Keep guest names out of staff group chats and personal camera rolls. When someone leaves your team, remove their access that day, and ask them to delete any lists or photos they hold. Name one person, usually you, to own this checklist. In Canada, the law requires a business to name someone accountable for the personal information it holds (PIPEDA, Schedule 1, 4.1).

At the door

Look at ID, keep nothing

Look at the ID, match the face and the date of birth, and hand it back. Don't photocopy it, photograph it or scan it into a file. Canada's privacy commissioners say copying or scanning a driver's license "generally goes too far" (Privacy Commissioner of Canada). Several US states also limit what a business may keep from a scanned license. The application questions guide has two examples.

Your door staff will see real names on IDs. Ask them never to write those names down or say them aloud.

Ask guests not to send photos of their ID before the night. If one arrives by text or email, check it, then delete it from the thread and from the deleted items.

The door list

• Show the name each guest goes by: their alias or first name, the size of their party and their ticket.
• Keep the list on a club device, not a staff member's own phone. Lock it when no one is at the door.
• Turn the screen away from the line. Guests waiting to come in shouldn't see who else is coming.
• Greet guests by the name they go by. Never read a real name aloud.
• If you print the list, number the copies. Collect them at close and shred them that night.
• For walk-ins, write down only what you need to let them in and reach them later.

Phones and photos

Set the rule before the night, post it at the door and repeat it at check-in. A sign you can copy:

• Phones stay in your pocket or bag inside the club.
• No photos or video of anyone without the consent of everyone in the frame.
• Photos only at [the photo wall].
• Anyone who breaks this rule will be asked to delete the photo and to leave.

If a guest takes a photo, ask them to delete it while a staff member watches. That includes the recently deleted album. If they refuse, ask them to leave. Don't take or search their phone; call the police if it comes to that.

The rule binds your staff too: no photos of guests, IDs or the list. If you have security cameras, point them at the entrance and the parking lot, and post a notice. Never place one in a private room or changing area.

After the night

Photos people took

If a member finds a photo from your night online, act the same day:

1. Talk with the member privately, and ask what they want done.
2. If it's an intimate image, the member, or someone acting for them, can ask the site to remove it.
3. The TAKE IT DOWN Act covers public sites and apps built on users' posts (Public Law 119-12). They must remove the image within 48 hours of a valid request.
4. A valid request is written and signed, and says where the image is. It states in good faith that the image was shared without consent, and gives contact details.
5. Treat whoever took or posted it under your house rules, and put any ban in writing.
6. If the member wants to go to the police, help them. Knowingly publishing such an image without consent can be a federal crime, even if the person agreed to the photo.

Post your own photos of the night only with the written consent of everyone who can be recognized. A photo of the room before the doors open needs none.

How long to keep what

Write down what you keep, how long you keep it and how you delete it. If you must keep information, the FTC's advice is to "develop a written records retention policy" (FTC). Here is one to adapt. The periods given "for example" are a starting point: set your own with your lawyer.

• IDs: never kept. Look, then hand them back.
• ID photos or selfies sent by message: deleted once checked, from every thread and folder.
• Printed door lists: shredded the same night.
• Staff group chats about a night: disappearing messages, set to a week, for example.
• Camera recordings: 30 days, for example, unless an incident needs them.
• Guest lists and check-ins: a year, for example, so you can answer a late report about a night. After that, keep only the numbers.
• Messages with members and applicants: until the matter is closed.
• Former members' profiles and photos: 90 days after they leave, for example, apart from the records below.
• Incident reports and bans: as long as a claim could be brought, which can be many years. Ask your lawyer, and keep them where only you can see them.
• Orders and payments: as long as tax law requires. Your accountant will know the period.

Deleting means every copy: exports, screenshots, printouts, downloads and the backups you control.

When a member asks to see or delete their data

Some members will ask what you hold about them, or ask you to delete it. In some places it's a legal right, with a deadline:

• Connecticut: since July 1, 2026, residents can ask any business that handles their sensitive data to show, correct or delete it. The answer is due within 45 days (Connecticut Data Privacy Act).
• Canada: under PIPEDA, people can ask to see what you hold about them, and you must answer within 30 days (PIPEDA, s. 8).

Answer every member the same way, wherever they live:

1. Confirm it's them: reply only to the email address you have on file.
2. Search everywhere: your staff app, the club's inboxes, spreadsheets and exports, staff phones and chats, and paper files.
3. To show them their data, send what you hold in a form they can read, leaving out other people's details.
4. To delete it, remove every copy you found.
5. Tell them what you keep, and why.
6. Write down the request, the date you answered and what you did.

A reply you can adapt:

Hi [name], we've deleted your profile, photos, messages and the record of the nights you came to. We keep your payment records for as long as tax law requires. We also keep your email address on our do-not-email list, so you don't hear from us again. [Your name]

The first 48 hours after a leak or a lost phone

It might be a phone left in a taxi, a guest list sent to the wrong person or a screenshot posted online. Write this plan down before you need it. It follows the FTC's breach guide for businesses: secure, fix, then notify (FTC).

In the first hour

1. For a lost or stolen phone, use its find-and-erase service to lock it, and erase it if it doesn't come back.
2. Sign the phone out of your staff app, the club's email, its social accounts and shared drives.
3. Change the passwords saved on it, starting with email, since email can reset everything else.
4. If a list or photo is posted online, ask whoever posted it to take it down. Report it to the site, and note the link and the time.
5. Ask your staff to keep every message and record about what happened.

Within a day

1. Write down what happened: when, who noticed, what was exposed and whose details.
2. Work out what each person could lose: a real name tied to an alias, a photo, the fact that they came.
3. Close the gap: remove the access that was used, change shared passwords, and fix the habit that caused it.
4. Call the police if a phone was stolen, or if anyone asks for money to keep things quiet.

Within two days

1. Check who you must tell. Each US state has a breach notification law, with its own triggers and deadlines (FTC).
2. In Canada, report to the Privacy Commissioner any breach that creates a real risk of significant harm. That includes humiliation and damage to reputation or relationships (Privacy Commissioner of Canada). Tell the people affected as soon as feasible.
3. Tell the members affected, even where no law requires it. Say what happened, what was exposed, what you've done, what they can do and whom to contact.
4. Say how you'll contact them about it, so they can spot fake messages.
5. Keep the record. In Canada, you must keep a record of every breach for two years, reported or not.

A message you can adapt:

Subject: About your information at [club name]

On [date], [a staff phone with our door list on it was stolen]. It held [your alias, your first name and the nights you came]. It did not hold [your payment details or photos]. We have [signed the phone out of our systems and changed our passwords]. If anyone contacts you about the club, don't reply to them, and tell us. We will only write to you about this from this address. Questions: [name, phone number].

The law, briefly

US state privacy laws

Most state privacy laws apply only above a size that many small clubs don't reach, as the start guide explains. Connecticut's is the one to plan for. Since July 1, 2026, it covers any business that handles Connecticut residents' sensitive data, whatever its size (Connecticut Data Privacy Act). Sensitive data includes data revealing a person's sex life or sexual orientation. Such a business must collect only what is reasonably necessary, and needs consent to handle sensitive data.

Members in the EU

If you offer memberships or events to people in the EU, the GDPR can apply to your club (European Data Protection Board). It treats data about a person's sex life or sexual orientation as sensitive. Processing it is generally prohibited unless an exception applies, such as explicit consent. A breach must be reported to the data protection authority within 72 hours, unless it's unlikely to put anyone at risk. When the risk is high, the people affected must be told without undue delay (European Data Protection Board).

Event privacy on Enclave

On Enclave, members see each other under aliases, and real names stay in your staff app. On an event page, who's going shows aliases, never real names, or just a count if you hide the list. At the door, your staff find guests by name, alias or email. If your club asks for a verification photo, only your staff and the member see it. Your door staff see it when they scan the member's pass.

Roles decide what each person on your team can see and do. Your door staff can check guests in without seeing your revenue. Staff actions are recorded in the audit log. Your staff and members can each see the devices signed in to their account and sign one out remotely.

Frequently asked questions

Should a lifestyle club keep copies of members' IDs?

No. Check ID at the door and hand it back. A copy adds nothing to the check, and it is one more thing that can leak.

How long should a club keep its guest lists?

Long enough to answer a late report about a night, such as a year. Then keep only the numbers, and delete every copy.

What should a club do if its guest list leaks?

Stop the spread, find out what was exposed and whose, and check the breach laws that apply. Then tell the members affected, even where no law requires it.