Workplace Surveillance Policy

Workplace Surveillance Policy – Victoria, Australia

Purpose

This policy outlines Man With A Van’s approach to surveillance in the workplace in compliance with the Surveillance Devices (Workplace Privacy) Act 2006 (VIC) and the Privacy Act 1988 (Cth). Surveillance is used to maintain safety, security, protect company property, and monitor compliance with workplace policies.

Scope

This policy applies to all employees, contractors, and visitors at Man With A Van sites located in Abbotsford and Cranbourne Victoria, including those working remotely using company-owned devices or systems.

Types of Surveillance Used

In accordance with Victorian law, Man With A Van may implement the following surveillance methods in the workplace:

a. Visual Surveillance (CCTV)

Surveillance in private spaces (e.g., bathrooms) is strictly prohibited under the Surveillance Devices (Workplace Privacy) Act 2006 (VIC).

Man With A Van may conduct surveillance under the following circumstances

Installed in clearly marked areas inside and outside company premises. Signage will be used to inform individuals of video or video with audio monitoring.
In vehicles used for work purposes, e.g. “dash cams”, reversing cameras, and load monitoring cameras.
Where load monitoring cameras are used, this shall be for the purpose of monitoring load size only and shall not be used to identify individual employees or record audio.
MWAV may install dedicated on and visible at all times screens to monitor particular locations for safety reasons. (e.g. entrances and exits).

b. Computer and Network Surveillance

Includes monitoring of email use, internet access, data transfers, login/logout activities, and file usage on company-owned devices, and on personal devices used for work purposes e.g. MWAV apps or websites.
This may include screen or call monitoring. Where this occurs, employees have the right to be informed of any surveillance being conducted.
This surveillance helps prevent data breaches, misuse of company resources, and ensures policy compliance.

c. Audio Surveillance

Man With A Van does not conduct covert or unauthorised audio surveillance.

Recording of meetings will only occur with the express consent of all participants.
Recording of phone calls will occur for training and quality purposes.
CCTV audio recording may occur only in depots or yards where vehicles may be present for security and safety reasons and must be clearly signed “CCTV and audio recording used in this area”.

d. GPS and Location Tracking

Applied to company-owned vehicles and devices at all times.
On personal devices when company operational apps are in use. Where available, this will be on an opt-in basis. Where a user opts-out, some functions will not be available.
Used for fleet efficiency, safety, and asset tracking, job efficiency and customer transparency.
Records driving behaviour as well as location.

Legal Notice and Employee Consent

In compliance with the Surveillance Devices (Workplace Privacy) Act 2006 (VIC):

Employees are notified in writing of any workplace surveillance prior to commencement and will be contained in all employment contracts and MWAV Pty Ltd Melbourne VIC-TWU Enterprise Agreement 2025-2028.
This policy serves as formal written notice, and additional consent will be obtained where legally required (e.g., for audio recordings of meetings).
Man With A Van does not use covert surveillance unless specifically authorised by law.

Use and Access to Surveillance Data

Surveillance data is collected and used only for the following reasons:

Security and safety.
Investigating misconduct or breaches of policy.
Fleet and company equipment management (trucks, phones, keys, EFTPOS terminals, tools etc)
Compliance with legal obligations.

Information may be shared with external agencies (e.g., law enforcement) if required by law. Access and disclosure of captured data from a CCTV camera system shall be in accordance with the Privacy and Data Protection Act 2014.

Constraints

Any future implementation of cab facing surveillance cameras (dash cams etc) or in-vehicle audio collection must be via a policy that has the majority support of all staff or unless required by law .
Access to surveillance data is restricted to authorised personnel only.
Managers shall not review CCTV for disciplinary purposes without specific grounds for suspecting misconduct.
No manager shall review CCTV for disciplinary purposes without the authorisation of a second manager.
If the company wishes to change this policy it must do so with the majority support of all staff

Storage and Retention

Surveillance records are stored securely in accordance with privacy and data protection requirements.
Data is retained based on operational needs and legal obligations, after which it is deleted or destroyed.

Remote and Hybrid Work

For employees working remotely, surveillance may apply to use of company-issued devices, including:

System access logs
Application and network use
Email and collaboration tool usage (e.g., Gmail, Slack)
VOIP phone systems
Where this occurs, the employer will clearly state so

Surveillance does not extend to personal devices unless explicitly authorised by both employee and employer and in compliance with Victorian law.

Employee Rights

Employees have the right to:

Be informed of any surveillance being conducted
Request access to personal information collected, in line with the Privacy Act 1988 (Cth)
Raise complaints or concerns through the company’s internal complaint procedures

Breach and Disciplinary Action

Unauthorised surveillance or breach of this policy may result in disciplinary action, including termination of employment and/or referral to authorities.

Review

This policy will be reviewed annually by the company OHS Committee and updated to reflect changes in law or operational requirements.

Approved By: Matthew Windsor
Title: General Manager
Date: 19/08/2025
Next Review: 19/08/2026

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