INFORMATION PRIVACY POLICY FOR WORKERS

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1 INFORMATION PRIVACY POLICY FOR WORKERS February 2015 INFORMATION PRICACY FEBRUARY 2014

2 Information Privacy Policy for Workers SITA Australia Pty Ltd (ACN ) This Information Privacy Policy for Workers (Policy) applies to SITA Australia Pty Ltd, its related companies and joint ventures (and their subsidiaries) in which those companies are involved in Australia ("SITA", "we", "us", "our"). SITA collects, processes, uses and discloses information relating to people who carry out work for us or on our behalf. Those people may be SITA employees, contractors or subcontractors, or they may be employees of contractors engaged by SITA to perform work, such as, for example, employees of an owner driver company engaged by SITA, or employees of a labour hire company assigned to work for SITA ( workers ). This Policy explains the nature of the personal information SITA collects about workers, why this is done and how such information is handled. INFORMATION PRICACY FEBRUARY

3 1. Other related policies Workers have obligations under policies other than this Policy. Some of those policies include: Suez Environnement s Ethics Charter and Ethics in Practice, our Social Media Policy and SITA s Acceptable Use of Technology Policy. 2. Collection of worker information 2.1 SITA collects, holds and processes personal information as part of a worker s engagement to perform work for SITA. 2.2 The information SITA may collect includes: (a) name, address, phone numbers, and other contact details; (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) (n) (o) photographs, videos, digital images, location details and biometric information; date of birth, immigration status and marital status; CVs, application forms, details of education, job history and experience (both within SITA and previous employers), areas of expertise, qualifications, licences (including drivers licences), references, contracts of employment and offer letters; details of any directorships with SITA; trade union membership; details of criminal convictions; emergency contact details; health information (such as medical records, sickness absence records and medical certificates); incident and accident reports; bank details; full details of current and previous positions within SITA, details of compensation and benefits (including details of company loans, salary, pension contributions); work attendance times and records relating to annual and other forms of leave; details of training and development needs and achievements, records and documentation relating to any appraisals, performance reviews, salary reviews, disciplinary matters concerning a worker or in respect of which a worker has been involved, or grievances the worker has raised or which have been raised by others about that worker; and any other information notified to a worker in any of our policies, guidelines, codes of conduct or other communications. INFORMATION PRICACY FEBRUARY

4 2.3 SITA s technology and telecommunications systems will also collect and retain personal information, such as, for example, through our system, through workplace monitoring such as CCTV cameras, vehicle on-board camera systems, vehicle tracking systems, biometric timekeeping, IT monitoring, and use of access passes. Through these systems SITA may collect personal information about a worker, including: (p) personal information contained in personal s and communications using SITA systems; and (q) details of a worker s movements within any SITA premises and, generally, whilst a worker is performing services for or on behalf of SITA and/or using SITA plant and equipment. 2.4 As an employer SITA is required to collect certain information under various workplace relations, tax, superannuation and other legislation. 2.5 If a worker does not provide SITA with any information that is requested, SITA may not be able to perform necessary functions in relation to that person s engagement as a worker (such as, for example, pay the worker or the worker s employer). 3. Purposes of processing worker information 3.1 SITA needs to collect, store, use and disclose personal data about workers for a variety of personnel, administration, contractual, employment, work and general business management purposes. 3.2 These include: (r) administration of the payroll system; (s) (t) (u) (v) (w) (x) (y) (z) the administration of employee benefits (such as bonuses, pensions, leave entitlements); facilitating the management of work and workers; addressing health and safety matters; carrying out appraisals, performance reviews and salary reviews, disciplinary investigations and meetings; receipt and approval of invoices for payment; approval of time-sheets as a pre-requisite to third party payment of workers; to operate and check compliance with our work-related rules and policies; to operate SITA IT and communications systems such as the use of phones and IT, and to check for unauthorised use of those systems (including, where appropriate, monitoring); INFORMATION PRICACY FEBRUARY

5 (aa) (bb) to comply with record keeping and other legal obligations including obligations under workplace relations legislation; and any other purposes notified to a worker in any policies, guidelines, codes of conduct or other communications. 4. Disclosure of worker information SITA may from time to time disclose worker information to its related bodies corporate (including those located in France and Singapore) for the purposes set out in this Policy. Likewise, SITA may sometimes need to make worker information available to legal and regulatory authorities, to accountants, auditors, lawyers and other professional advisers, and to companies who provide products and services to us (such as, for example, IT systems and data hosting suppliers, pension scheme or medical benefit providers and other outsourcing providers), including data hosting providers. 5. Storage of employee information SITA will endeavour to take all reasonable steps to keep secure any information which is held about workers, and to keep this information accurate, up to date and complete. 6. Accuracy and retention of worker information 6.1 SITA will take reasonable steps to ensure that the worker information held is accurate and upto-date. For example, from time to time, SITA may ask a worker to review and update the information held about that person on SITA s databases. 6.2 SITA will also take reasonable steps to ensure that any information kept about workers is not kept for longer than necessary. SITA may, for example, keep details of workers for a reasonable period of time after they have ceased working for SITA. SITA may need to do this in order to ensure compliance with contract obligations, to ensure benefits have been properly administered, to give statements of service if requested to do so, to ensure that tax obligations have been satisfied and to deal with any tribunal or other court proceedings. SITA must also do this to satisfy obligations to retain records under laws relating to taxation, occupational health and safety and workplace relations, amongst others. We will destroy or de-identify information when we no longer need it. INFORMATION PRICACY FEBRUARY

6 7. Future changes to this Policy SITA operates in a dynamic business environment. Over time, aspects of SITA s business may change in response to changing market conditions. This may require policies to be reviewed and revised. SITA reserves the right to change this Policy at any time and notify workers by posting an updated version of the policy on its intranet and/or displaying it at a SITA workplace. If at any point SITA decides to handle worker information in a manner materially different from that stated in this Policy, it will notify workers via a prominent notice on its intranet and at workplaces and, where necessary, it will seek the prior consent of its workers. 8. Contact details If a worker has any questions or concerns relating to this Policy, then, in the first instance, the worker should contact their SITA manager or supervisor. If the SITA manager or supervisor does not respond satisfactorily to the worker s question or concern within 14 days from the date of query, or the worker is dissatisfied with the response provided, then the worker should put their request in writing and address this to SITA s Privacy Officer at SITA will investigate a worker s complaint and will use reasonable endeavours to respond to that worker in writing. If the worker is dissatisfied with the response, that worker has the right, to make a complaint under applicable legislation to the applicable regulator. This information privacy policy for workers was last updated in February INFORMATION PRICACY FEBRUARY

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