INTRODUCTION

The Company wishes to notify all employees of surveillance in the workplace which may be carried out by the Company and/or our clients whilst employees are at the workplace and/or performing work.

PURPOSE

This policy, and its subsequent distribution to all current and new employees, is intended to meet the Company's obligations for notification of workplace surveillance of employees under the relevant legislation. All surveillance implemented by the Company (if any) will only occur in accordance with the provisions of the relevant legislation and this policy. Surveillance is used for the general security of Company property and assets, operational needs, and for the protection and safety of employees and the general public.

APPLICATION

This policy applies to all workplaces under the control and responsibility of the Company where the following surveillance may directly or indirectly monitor employees, contractors, persons performing voluntary work or any persons authorised to undertake a Company function or activity in the workplace.

DEFINITIONS

The following definitions apply to this policy:

Surveillance of an employee means surveillance of the following means:

a. "camera surveillance", which is surveillance by means of a camera that monitors or records visual images of activities on premises or in any other place.

b. "computer surveillance", which is surveillance by means of software or other equipment that monitors or records the information input or output, or other use, of a computer (including the sending and receipt of emails and the accessing of internet websites); or

c. "tracking surveillance", which is surveillance by means of an electronic device the primary purpose of which is to monitor or record geographical location or movement (such as a Global Positioning System tracking device).

d. "Employee" for the purposes of this Policy includes independent contractors, sub-contractors, persons performing voluntary work without remuneration, reward or obligation and any person authorised to undertake a Company function or activity while in the workplace.

Workplace means premises, or any other place, where employees work, or any part of such premises or place.

REASONS AND REQUIREMENTS FOR SURVEILLANCE

Reasons for camera surveillance: The Company may require designated areas to be under camera surveillance for operational, security or protection/safety reasons.

Requirements for camera surveillance: Cameras will be placed such that they are visible to people in the workplace. Surveillance will not be carried out in change rooms, toilets, or showers. Where the Company intends to introduce surveillance cameras, employees working in the designated area or areas shall be advised in writing by email a minimum 7 days prior to its commencement.

Where camera surveillance is proposed for safety reasons, such as remote work sites or hazardous work activities, the Company shall consult with the relevant employees, before commencing camera surveillance.

The Company will erect visible signs informing people who enter or leave a workplace area that camera surveillance is being carried out.

The signs will state similar to the following:-

"Closed Circuit Television Cameras are in 24-Hour operation in this building".

REASONS FOR COMPUTER SURVEILLANCE

Computer resources are provided for business purposes related to an employee's position. However, reasonable personal use is permitted in accordance with the Company's Acceptable IT Use Policy.

Computer surveillance is used for the general security of the Company's property or assets, for the protection of Company related information and to ensure that Company's computer resources are not misused.

Conditions apply to employees when using the Company's computer resources and these are detailed in the Company's Acceptable IT Use Policy which includes internet and email usage.

REASONS FOR TRACKING SURVEILLANCE

Tracking devices come in many forms and can be fixed (i.e. to a vehicle) or handheld. The devices can be used to provide operational and/or safety information related to the exercise of a function of the Company.

Requirements for tracking surveillance: The Company will install visible signs in all vehicles fitted with tracking devices to 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."

NOTICE OF SURVEILLANCE

The kind of surveillance to be carried out by the Company is:

1. Camera,

2. Computer, and

3. Tracking surveillance

HOW THE SURVEILLANCE WILL BE CARRIED OUT:

a. The Company will use overt cameras, email filters, internet monitoring software and devices, and tracking devices, and any other similar surveillance methods permitted by the relevant legislation, deemed appropriate, from time to time.

a. Audits of surveillance information may be conducted by the Chief Executive Officer, or his designated nominee and the results will be provided to managers and/or directors.

b. If surveillance information is required at any other time by any person, they must gain authority from the Chief Executive Officer to access that information for a specific purpose and an approved period.

WHEN SURVEILLANCE UNDER THIS POLICY MAY COMMENCE:

Surveillance is effective from 8 November 2021 which is 7 days after the day this policy was distributed to all employees.

IF THE SURVEILLANCE IS CONTINUOUS OR INTERMITTENT?

The surveillance may be a combination of both continuous and intermittent as determined by the Company and which may be varied from time to time

IF THE SURVEILLANCE IS TO BE FOR A SPECIFIED LIMITED PERIOD OR ONGOING?

The various means of surveillance covered by this policy will be ongoing permanently.

Notification to employees of this policy will be in writing with a copy in the employee handbook and also available for download from the Company website, which constitutes notice in writing for the purpose of complying with the relevant legislation.

WHERE ADDITIONAL WORKPLACE SURVEILLANCE IS INTRODUCED IN THE FUTURE:

Any new, additional or upgraded software or computers will not require staff notification unless the new or upgraded software or computers is for a purpose other than that specified in this policy.

The introduction of new or additional tracking devices shall be implemented in accordance with this policy.

USE AND DISCLOSURE OF SURVEILLANCE INFORMATION

Surveillance information means, information obtained, recorded, monitored or observed as a consequence of surveillance of a workplace. Surveillance information may be used by the Company as part of investigations for disciplinary purposes and as evidence during any disciplinary interviews in compliance with the disciplinary procedures detailed in the Employees Handbook.

The surveillance information will only be used/disclosed for legitimate employment/business purpose or in connection with suspected corruption, illegal activity, maladministration, misuse of Company resources and imminent threat of serious violence to persons or substantial damage to property.

RESPONSIBILITIES

The Company is committed to ensuring that the surveillance activities which it undertakes are in accordance with the relevant legislation.

RESPONSIBILITIES OF DIRECTORS AND MANAGERS

Directors and managers are responsible for:

a. making staff aware of this policy and their compliance.

a. complying with the requirements of this policy; and

a. notifying the Chief Executive Officer of suspected breaches of this policy.

RESPONSIBILITIES OF EMPLOYEES

Employees are responsible for

a. complying with the requirements of this policy; and

a. notifying the Chief Executive Officer of suspected breaches of this policy.

RECORD KEEPING, CONFIDENTIALITY AND PRIVACY

All managers responsible for records resulting from cameras, computers and tracking surveillance equipment covered by this policy must store the confidential information safely in accordance with direction from the Chief Executive Officer.

ACCESS BY THE PUBLIC

All requests for access to surveillance records will only be considered following a written request addressed to the Chief Executive Officer.

BREACHES AND SANCTIONS

Technical breaches (e.g. lack of signage or training of staff), should be reported to the Chief Executive Officer through your supervisor.

Inappropriate use of surveillance records by any employee shall be a breach of this policy and should be reported directly to the Chief Executive Officer.

REVIEW DATE & FURTHER INFORMATION

The Company reserves the right to review, vary or revoke this policy in accordance with relevant legislation at any time.

For further information, please speak with your supervisor.

AUTHORISATION

This policy was on the date shown.