Policy Consultation and review

This policy is under review and is seeking your consultation.  Please read and review the document and provide comments at the bottom.  Your comments will be acknowledged by the Policy committee and will be taken into review for any further changes.


Policy Number:

Effective From:  DRAFT

1. AIM


The aim of this policy is to outline the circumstances in which FLINTWOOD conducts surveillance of its premises, employees and Participants by means of camera and vehicle tracking devices.  The Workplace Surveillance Act 2005 (NSW) requires employees and other persons be notified as to the nature of the surveillance and this policy constitutes the provision of notice to employees of FLINTWOOD’s surveillance under the Act.




This policy applies to all current employees, Participants, contractors and visitors who have access at any time to FLINTWOOD premises, computer systems and equipment including GPS tracking and house surveillance.




Act:  means the Workplace Surveillance Act 2005 (NSW)

Monitor:   a form of surveillance meaning the collection or storage of information or creation of records.  It also includes routine review of the information or records to ensure integrity, security and service delivery.  Monitoring DOES NOT involve actively investigating or keeping track of an individual and their activities.

Surveillance:   means surveillance by way of:

  1. Camera – monitoring and/or recording visual images of persons and/or activities on FLINTWOOD premises.
  2. Tracking surveillance – by means of an electronic device to monitor/record geographical location or movement eg GPS


Surveillance Record:   a record or report of surveillance information, including visual data.



This policy should be read in conjunction with the following FLINTWOOD policies:

  1. IT Policy
  2. Vehicle Policy
  3. Code of Conduct
  4. Mobile Phones Policy
  5. Privacy Policy
  6. Recruitment and Induction Policies
  7. Archives Policy


FLINTWOOD carries out surveillance in the form of monitoring to:

  1. Ensure the health, safety and welfare of FLINTWOOD employees and its Participants
  2. Compliance with legal obligations including reporting obligations.
  3. Assist employees to monitor Participant’s movements at site
  4. Provide a reference of incidents and injuries
  5. To pin point exact locations when in need of emergency assistance
  6. To substantiate or unsubstantiated claims or complaints
  7. To provide factual data on people’s whereabouts and actions


Surveillance and Surveillance Information and Records


FLINTWOOD may access records as necessary from the ongoing monitoring and tracking.


FLINTWOOD will access information to specifically include:


  1. legitimate purposes related to the employment of employees
  2. legitimate business activities or functions of FLINTWOOD, including internal inquiries and investigations of alleged unlawful activities or activities that are alleged to be in breach of any FLINTWOOD rule, policy or code of conduct or in breach of a person’s duties to FLINTWOOD as its employee
  3. use or disclosure in any legal proceedings (including an inquiry by the NSW Ombudsman) to which FLINTWOOD is a party or is directly involved
  4. disclosure to a member or officer of a law enforcement agency for use in connection with the detection, investigation or prosecution of an offence
  5. where otherwise required or authorised by law to do so (for example, if FLINTWOOD is required to comply with a search warrant or subpoena)
  6. where FLINTWOOD considers this is reasonably necessary to avert a serious and imminent threat of:

a) violence to a person

b) damage to property

c) disruption to FLINTWOOD’s business, reputation, systems or operations.


Prohibited Surveillance


FLINTWOOD will not carry out and does not condone any surveillance which is prohibited under the Act.  No surveillance of employees / participant’s in area’s which would be considered private such as bathrooms, bedrooms, change rooms.


Notice Requirements


This Policy is formal notice to employees that FLINTWOOD does the following in accordance with this Policy:

  1. it conducts surveillance in the form of monitoring in the workplace
  2. where authorised under the Act or this Policy, it conducts workplace surveillance other than monitoring
  3. it creates, accesses, uses and discloses information or records in relation to surveillance, including as part of monitoring.






Employees are prohibited from conducting any form of workplace surveillance or from accessing records or surveillance information.


The following employees are only authorised by Flintwood for the purposes of performing their designated duties:


  1. The Chief Executive Officer
  2. General Managers and Acting General Managers
  3. Service Managers
  4. IT resources and backup


Notice Requirements


FLINTWOOD also provides notice to employees about surveillance (including monitoring) in other formats as follows:

  1. in the case of monitoring by cameras, by means of visible physical signage at the entrances to or within FLINTWOOD premises
  2. in the case of vehicle tracking devices, by means of physical signage inside the vehicle
  3. by obtaining a signed acknowledgement when an employee commences employment
  4. by means of regular (every 12 months) reminder notifications to all employees by the HR Department.
  5. for new methods of monitoring, specific written notice to all employees (which may be given by email) at least 14 days before that routine monitoring commences.


Type of Surveillance


In the course of carrying out monitoring, FLINTWOOD collects, creates and stores records and information (including logs, images, backups, and archives) using any one or more of the following methods:


  1. Camera Monitoring – FLINTWOOD has installed fixed security cameras at some sites. These cameras (including any casings) are clearly visible and not covered or hidden. and monitor activities on an ongoing and continuous basis.
  2. Tracking Monitoring – FLINTWOOD owned or leased vehicles have tracking devices installed, that are monitored through an on-line system.


Camera and vehicle monitoring will take place at all times continuously on an ongoing basis. Records will be surveyed by persons authorised by this Policy at their discretion, or in the event of incidents that require review.


Footage will be stored for a 6 month period and follow the FLINTWOOD archiving policy. Evidence or sensitive footage used for the purpose of investigations will be kept on file indefinitely.


Service Managers will place an item on team meeting agendas to discuss general issues arising from camera and vehicle surveillance.




  1. The location of the monitors will be disclosed to employees at time of induction and a notice on the buildings affected.
  2. All vehicles will display the tracking notice.
  3. There will not be any hidden cameras
  4. The monitoring will be seen as a 2 fold system:
    • Employees to use as a monitoring and safety of Participants.
    • Record keeping to be utilised as a resource in case of an incident etc.
  5. There is no expectation that it will be used by management as a live monitoring of staff movements whilst on shift.
  6. If an employee objects to being monitored through our devices then we will discuss their employment location.
  7. Participants who do not wish to be monitored or have behaviours where the recording could be inappropriate to record i.e. sexualised then a meeting will be held with the General Manager to discuss the issues. Only the General Manager and CEO have the discressionary power to decide if the monitoring will be turned off.
  8. It is the role of the Service Manager to randomly check the vehicle tracking and monitoring to ensure program goals are being met.
  9. Any incidents and complaints trigger the ability to review the monitoring devices and history to assist with a full investigation.
  10. Employee will be told of any tracking or monitoring which directly affect them.
  11. At no point are the monitors, cameras or tracking devices to be tampered with, turned off, or covered in any way by any employee or Participant.




All employees are responsible to read, understand and adhere to this Policy.


Service Managers are responsible to ensure cameras and vehicle tracking devices are operational, by checking footage and tracking every 2 weeks.  They are also responsible to ensure there are no obstructions to cameras getting appropriate footage.



Changes Required:

  • Date Format: MM slash DD slash YYYY

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