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INVEHICLE SURVEILLANCE POPLICY

(C) Copyright 2024 - ACM Cleaning Group 

POLICY OF

VERSION NUMBER

APPROVED DATE

SCHEDULED REVIEW DATE

ACM Cleaning Group

002

1 September 2024

30 August 2025

From the date of this policy, in-vehicle monitoring systems may become operational in Company owned vehicles.

This policy, and its subsequent distribution to all employees who have use of a Company owned vehicle, is intended to meet Teamwork Direct Pty Ltd (the Company) obligations under the Workplace Surveillance Act 2005 (NSW)] (Act).

This policy outlines the purpose of in-vehicle monitoring, and details how data collected by the system will be used by the Company. It also regulates the management, operation and use of the in-vehicle monitoring system by the Company employees.

Employees who access surveillance data must comply with the applicable provisions of this policy and the Act. Surveillance implemented by the Company will only occur in accordance with the provisions of the Act and this policy.

APPLICATION
This policy applies to all employees with assigned Company owned vehicles.

PURPOSE
Tracking devices come in many forms and can be fixed to a vehicle or handheld. The devices are used by the Company to provide operational and safety information related to the exercise of the functions of the Company.

The Company will install visible signs in all vehicles fitted with tracking devices which will inform all vehicle users that surveillance tracking is being carried out. The signs will state similar to the following:
"Tracking surveillance devices have been fitted to this vehicle/equipment."

The purpose of installing in-vehicle monitoring is to streamline the fieldwork process to improve:

1. customer service levels;

2. the ease and speed of information exchange;

3. and resource management (both human and capital);

4. facilitate integrity assurance – to facilitate and reinforce the Company’s commitment to the relentless pursuit of best practice in integrity.

SYSTEM OVERVIEW

Monitoring System

The in-vehicle monitoring system will:

1. facilitate the efficient dispatch of employees into the field;

2. be used as an automated booking system for the purposes of scheduling field work for all employees with allocated Company owned vehicles;

3. allow management to view, track and report on vehicle management and movements.
Emergency

The in-vehicle monitoring system will also incorporate a duress facility by the way of a remote emergency pendant including driver ID, which will facilitate emergency response in times of crisis or accident.

BENEFITS

The new system and technology will deliver a range of benefits across a number of areas, including but not limited to:

1. occupational health and safety.

2. risk management.

3. customer service.

4. work scheduling and allocation.

5. record keeping.

6. fatigue management.

7. manual processing.

8. route planning.

9. location of registered persons.

10. maintenance of integrity.

11. substantiation and audit of fringe benefits tax.

12. fleet management.

13. emergency response; and

14. security and protection from litigation

DATA COLLECTION

The in-vehicle monitoring system will provide both live and historical reporting, collecting a range of data that will be used to generate two types of reports. These will be detail reports and summary reports.

REPORTS

Detail Reports

Detail reports analyse vehicle activity and performance for individual vehicles.
Summary Reports

Summary reports compare vehicle performance and productivity for multiple vehicles.

HOW DATA WILL BE USED

The data will only be used for legitimate work purposes or in connection with suspected corruption, illegal activity, maladministration, misuse of the Company resources and imminent threat of serious violence to persons or substantial damage to property, in accordance with the Act.

Usage of fleet vehicles will be monitored centrally by the Company during work hours. In most cases, the system will not be monitored live. Rather, the system will be accessed as required, to book and allocate jobs, respond to urgent customer issues, and locate employees in cases of emergency.

The detail and summary reports may be used as part of the performance appraisal process. More specifically, to monitor the efficiency of employees during allocated work hours and to ensure that both capital and human resources are being used productively. The Company may also conduct a yearly audit of usage data as part of the fringe benefits tax audit process.

Data collected may also be used by the Company as part of investigations for disciplinary purposes and as evidence during any disciplinary interviews. If an incident or complaint against an employee is made by a member of the public, the Company may access data and historical reports to substantiate claims in the interests of maintaining the integrity of the Company’s activities.

DATA SECURITY

The Company will take all reasonable steps to protect the data it collects and the information it holds from misuse and loss from unauthorised access, modification or disclosure.
The information will be stored in a secure online environment managed by a reputable service provider.

ACCESS

There will be different levels of access to the in-vehicle monitoring system within the Company. Steps will be taken to restrict access to the information to only those employees who require access, and to develop an audit trail to detect unauthorised access.

PRIVACY POLICY

The Company’s Privacy Policy accords with the national privacy principles in the Privacy Act 1988 (Cth), to protect the privacy of the information collected and is based on the Privacy Act 1988 (Cth). The Company understands the importance of your personal information and its privacy.
The Company respects those individuals have the right to know what information it holds about them.
For more information, please refer to the Company’s Privacy Policy.

DISCLOSURE

The Company will not use or disclose your personal information for a purpose other than the primary purpose of collection outlined in this policy.

The only exception to this is:

1. if the personal information is requested by a member or officer of a law enforcement agency for use in connection with the detection, investigation or prosecution of an offence; or

2. if the personal information is required for use or disclosure for a purpose that is directly or indirectly related to the taking of civil or criminal proceedings.

The Company will not disclose information to any external parties (except those outlined in this policy) unless consent is sought from the individual concerned.

REVIEWS

This policy will be reviewed annually.

FURTHER INFORMATION

For further information, please speak with your supervisor.

AUTHORISATION

This policy was approved on the date shown.

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