Privacy Policy


The Company is committed to protecting the privacy of the personal information we manage and are required to comply with the Australian Privacy Principles (the Principles).



This policy covers all Workers and other Persons in the workplace in line with the requirements of the Privacy Act 1988 (the Act).  This policy, in conjunction with other policies dealing with the collection, use, retention, disclosure and protection of personal information such as our Alcohol and Other Drug Policy and Substance Testing Procedures; our Social Media and Guidelines Policy; and our Appropriate Workplace Behaviour Policy and Procedures, is intended to notify or make all Workers and other Persons aware of the collection of their and others personal information.

This policy does not form part of the employment contract between us and any employee.  Nothing in this policy limits any of our other obligations or rights at law.

This policy operates in conjunction with other relevant Company documents and associated forms as well as the applicable Certified Agreement / Awards and relevant legislation.

Further details on Privacy Legislation can be obtained from the P&C Department or

Further details on the Privacy Principles can be obtained from the P&C Department or



The Kinds of Personal Information Collected

The kinds of personal information that we collect and hold in accordance with the Principles may include, but is not limited to:

·        Employee records, health information, identification information, sensitive information, your name, date of birth, current and previous addresses, phone numbers, email addresses, bank details, superannuation fund details, tax file number, licences and permits, personal medical information, next of kin (and their details), biometric details, not limited to fingerprints, palm prints, eye/retinal scans, facial recognition scans, unique personal identifiers and other information required for legal, compliance, WHS and business requirements.

·        Skin swabs which may be collected as part of our Quality Assurance Programs.

·        Bodily fluids, breath, tissue and/or hair for substance testing which may be collected as part of our Alcohol and Other Drugs Policy and Substance Testing Procedures.

·        Your photograph, likeness or images of you and/or your property.  Our premises and vehicles may have surveillance cameras installed and therefore your photograph, likeness, image, personal property or vehicle may be captured in camera footage or in photos.  This could include registration details of private vehicles if they are in view of our cameras.

·        Your activities, journeys or whereabouts.  We utilise various mobile devices for day-to-day purposes which may have GPS tracking capabilities.  You should note that if you carry a company mobile device or use a company vehicle (including third party vehicles) your journeys and whereabouts may be recorded.

·        Any personal details entered by you into any company phone or computer equipment may be collected and saved, either purposefully or accidently, and entered into company records.

Collecting and Holding Personal Information

We may collect and hold personal information:

·        from information supplied by you;

·        in conversation and communication with you;

·        from third parties, including other Workers, government agencies or your representatives;

·        from publicly available sources of information; and

·        when we are required to do so by law.

If we collect a Person’s personal information from someone other than the Person, we will take reasonable steps where appropriate to notify the Person or ensure that they are aware that we have collected the information and the circumstances in which the information was collected.


Collection Methods

Personal information is collected in various ways which include, but are not limited to, HR Forms, Payroll Forms, Time and Attendance Records, Surveys, Training documents, Licences, QA Procedures and WHS Procedures.


How Personal Information is Stored

All personal information collected is treated as confidential and is only able to be accessed by authorised staff and service providers having a business reason to do so.  Information may be stored in paper and electronic formats in identifiable or de-identified format.


The Purposes of Collection

We collect personal information for various purposes, including but not limited to:

·        performing our services for you;

·        providing technology services and solutions;

·        responding to requests;

·        administrative purposes;

·        recruitment purposes;

·        purposes related to employment;

·        engagement of service providers, contractors or suppliers relating to the operation of our business;

·        meeting, or conscientiously striving to meet, our contractual obligations and our obligations under law, including WHS; and

·        drug, alcohol or other substance testing.


Sensitive Information

Sensitive information is defined in the Act to include information or opinion about such things as an individual’s racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; or criminal record that is also personal information; or health information about an individual; genetic information about an individual that is not otherwise health information; biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or biometric templates.

Sensitive information will be used by us only:

·        for the primary purpose for which it was obtained;

·        for a secondary purpose that is directly related to the primary purpose; or

·        with your consent; or where required or authorised by law.


Security of Personal Information

Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in individual files which will be kept securely by us for up to 7 years.


Processing Personal Information

Your personal information may be stored in our management systems or transmitted electronically, by post or by courier and processed or recorded via an offshore facility and we will take all reasonable steps to guard the privacy of your personal information as set out in the Principles.


Dealing with Personal Information

Your personal information will only be used or disclosed in accordance with Principle 6.  Your personal information will not be used or disclosed for the purpose of direct marketing.


Gaining Access to Personal Information

Requests for details of, or corrections to, personal information held can be made by writing to the HR Department and are subject to some limited exceptions permitted or required by law.

The factors that affect your right to access your personal information include whether:

·        it is a frivolous or vexatious request;

·        it relates to a commercially sensitive decision-making process; or

·        access would be unlawful.



If you have a complaint about how we collect, store or use your personal information, you may write to the HR Department outlining your concerns and we will respond to your complaint.  If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner.


Cookies on our Website

Most internet browsers are set to accept cookies which are small text files placed on your computer when you first visit a website.

If you visit our website, we may collect statistical data from your visit.  We will use this information to make our site more useful and attractive to you and others.

Our website is not intentionally designed for or directed at children under the age of 13 and it is our policy to never knowingly collect or maintain information about anyone under the age of 13.

You can adjust your internet browser to reject cookies, or to notify you when they are being used.


Monitoring Electronic Traffic

Company telephones, record keeping, processing and communication systems, along with any associated hardware are supplied to Persons to assist them to undertake their job duties.  These systems, which include but are not limited to email (both inwards and outwards) and internet sites visited, may be monitored, tracked and recorded by us.


Unsolicited Information

If we receive unsolicited personal information which is not reasonably necessary for, or directly related to our business functions, we will destroy or de-identify that information, if it lawful and reasonable to do so, so that it is no longer personal information.