QUALITY DOCUMENT
Name of Form: Surveillance Technology Policy

Surveillance Technology Policy

1.0   OBJECTIVES

This Policy describes the circumstances in which SeaLink Marine and Tourism (SeaLink) conducts surveillance and represents formal notification to employees about the types of surveillance technology used and activities undertaken.

While SeaLink does not intend to use surveillance methods or data to monitor employee movements, it may from time to time, or with cause, access surveillance systems and data records to investigate complaints or conduct workplace investigations as required.

SeaLink is committed to ensuring all surveillance activities are in accordance with appropriate legislation.  The policy outlines the minimum standard and applies to all SeaLink Marine and Tourism employees and contractors. 

2.0   DEFINITIONS

Camera:   An electronic device capable of monitoring or recording visual and audio activities.  

Camera Surveillance: Surveillance by means of a camera.

Surveillance: Observation or monitoring by means of an electronic device such as a camera, computer, GPS system and through electronic access points and security gateways.  

Tracking Surveillance:  Surveillance by means of an electronic device whose primary purpose is to monitor or record geographical location or movement, such as a GPS device

3.0   RESPONSIBILITIES

General Managers

• Ensure the Policy is implemented in their business.
• Promote awareness of and compliance with the requirements of the Policy.

Managers and Supervisors

• Ensure all their employees are aware and understand the Policy.
• Notify the General Manager and People and Culture of any suspected breaches of the Policy.
• Promote awareness of and compliance with the requirements of the Policy.

Employees  

• Comply with the requirements of the Policy
• Notify People and Culture of any suspected breaches of the Policy. 

4.0   TYPES OF SURVEILLANCE TECHNOLOGY

The types of workplace surveillance undertaken across SeaLink Marine and Tourism include:

• Camera Surveillance – SeaLink vessels, offices and carpark spaces are often monitored by continuous camera surveillance for a range of reasons including security monitoring, protection of  people and property, and to collect information for law enforcement agencies. Some passenger vehicles are also fitted with dashboard cameras. Cameras will not operate in areas such as toilets, showers and similar environments.
• Tracking Surveillance – the use of Automatic Identification Systems (AIS) and Global Positioning Systems (GPS) on vessels, as well as Fleet Management Systems (FMS) on selected passenger vehicles for asset tracking, monitoring driver performance and vehicle efficiency. 

​5.0   ACCESS, PRIVACY AND CONFIDENTIALITY

Live camera surveillance may be viewed by the Master and crew of a vessel for monitoring the operating environment (e.g. weather conditions), crew (e.g. while working in engine rooms) and passenger movements (e.g. suspicious behaviour).  

SeaLink will ensure surveillance records remain confidential at all times, and such records are strictly controlled and limited to legitimate business uses.

Access to surveillance files may be granted to Management for the purpose of an investigation and may involve another employee such as a Master, if required.

Access to recorded information is restricted by password where available.

Requests for access to recorded surveillance information to be made in writing in accordance with the below: 

Upon approval of a request, either an appropriate person from within the business involved (appointed by the General Manager) or the IT department will facilitate access to the surveillance information, depending on the source and type of data to be obtained.

6.0   COMPLIANCE

Inappropriate use of surveillance equipment or recordings is a breach of this policy and must be reported to the General Manager as soon as practicable. Inappropriate use will be dealt with as a serious disciplinary matter, up to and including termination of employment.

Tampering or altering surveillance is considered inappropriate use and will be deemed to be in breach of this policy and may result in disciplinary action being taken.