Workplace Privacy Policy

APPLICATION

This policy applies to individuals whose personal information is collected by WEM Group Holdings Pty Ltd (WEM Civil) in connection with their engagement or potential engagement as an employee, contractor or subcontractor.

Individuals to whom this policy applies include employees, candidates for employment, temporary workers, labour hire workers, work experience students, interns, contractors and subcontractors (including their employees and subcontractors) who perform, or may perform, work for WEM Civil.

PURPOSES

WEM Civil will collect, hold, use and disclose personal information for the purposes of:

·       facilitating recruitment and engagement;
·       assessing suitability for employment or engagement, or work at a particular location;
·       probity and reference checking;
·       pre­employment screening and reference checking;
·       immigration and related checking;
·       facilitating medical checks;
·       arranging training and personal development;
·       facilitating security arrangements;
·       complying with risk management processes;
·       complying with legal obligations;
·       establishing access to and use of information technology systems;
·       administering payroll and vendor payment systems;
·       facilitating and completing travel and secondment arrangements;
·       processing expense reports for reimbursement purposes;
·       management reporting;
·       administering any test or assessment (including medical tests and assessments);
·       audit purposes;
·       obtaining legal and accounting advice;
·       transferring employees between group companies;
·       workers’ compensation claims;
·       outsourcing or in-sourcing services; and
·       ensuring compliance with other policies.

WEM Civil may also collect information about a person because it is required or authorised by law to collect it.

If we hold personal information about you that was collected for a particular purpose, we will not use or disclose the information for another purpose unless:

·       you have consented to the use or disclosure of the information;
·       the secondary purpose is related to the primary purpose; or
·       required or authorised by or under an Australian law or a court/tribunal order.

WEM Civil will only use or disclose personal information for the purposes listed in this policy, unless the individual has consented or we are otherwise permitted or required by law to do so.

THE PERSONAL INFORMATION COLLECTED BY WEM Civil

Personal information collected by WEM Civil includes:

·       first, middle and last names;
·       gender;
·       home phone and mobile phone numbers;
·       home postal and residential addresses;
·       e-mail addresses;
·       date of birth;
·       tax file number;
·       superannuation information;
·       passport and license numbers;
·       visa information;
·       photographic and video images;
·       file notes;
·       emergency contact details;
·       credit card details;
·       bank account details;
·       personal travel preferences; and
·       any other information which may identify an individual in connection with their employment or engagement or possible employment or engagement by WEM Civil.

WEM Civil may also collect sensitive information. The sensitive information collected by WEM Civil may include:

·       dietary requirements;
·       special prayer or religious leave needs;
·       criminal record;
·       trade union membership;
·       accessibility and other needs and limitations due to a person’s disability; and
·       health information (including COVID-19 vaccination status).

WEM Civil will only collect sensitive information where it is necessary for genuine business purposes and/or for the inherent requirements of the position, and only with a person’s consent.

HOW PERSONAL INFORMATION IS COLLECTED AND HELD

It is WEM Civil’s usual practice to collect personal information about a person:

1.     directly from the person (for example, where a person provides information by applying for a job or submitting information through an application form);
2.     where relevant, and with the person’s consent, through a third-party recruitment service provider;
3.     with the person’s consent, from third parties (for example, WEM Civil may seek information about a person’s prior employment history through reference checks, eligibility to work in

Australia through a visa status check, educational qualifications by requesting confirmation of qualifications or results from an academic institution, or a person’s ability to perform the inherent requirements of the position through medical professionals); and
4.     through publicly available information, such as Facebook or LinkedIn.

Personal information received by WEM Civil is held electronically on the information technology systems of WEM Civil and its service providers. Authorised access is limited to authorised employees, contractors and service providers who require access in connection with the purposes described in this policy.

IF INFORMATION OR CONSENT IS NOT PROVIDED

Without all of the required personal information and consent being provided, WEM Civil may not be able to employ or engage or continue to employ or engage a person.

DISCLOSURE OF PERSONAL INFORMATION

WEM Civil may disclose personal information to third parties to perform activities in connection with the purposes listed in this policy.

Some of the organisations to which WEM Civil may disclose personal information are located outside Australia. When you consent to your personal information being collected in accordance with this policy by virtue of executing your employment agreement with WEM Civil, you are providing your informed consent that WEM Civil is not required to ensure that the overseas recipient to which personal information is given complies with the Australian Privacy Act.

ACCURACY AND PROTECTION OF PERSONAL INFORMATION

An individual will need to ensure that the personal information which is provided is accurate, complete and up-to-date at the time it is provided and must notify WEM Civil of any changes.

WEM Civil will take reasonable steps to protect the personal information that it holds from misuse and loss and from unauthorised access, modification or disclosure.

ACCESS TO PERSONAL INFORMATION

An individual may see and have a copy of their personal information that WEM Civil holds.

If an individual is able to establish that their personal information is not accurate, complete and up-to-date, then on request WEM Civil will take reasonable steps to correct it.  If WEM Civil is unable to agree whether personal information is accurate, complete or up-to-date, then an individual may ask WEM Civil to place with the information a statement claiming that particular information is not accurate, complete or up-to-date.

An individual who seeks to exercise their rights of access and correction must contact in writing People & Culture at peopleteam@wem.com.au

WEM Civil may refuse an individual’s exercise of their rights to access their personal information to the extent that:

·       WEM Civil reasonably believes that giving access would pose a serious threat to life, health or safety of any individual, or to public health or safety;
·       giving access would have an unreasonable impact on the privacy of other individuals;
·       the request for access is frivolous or vexatious;
·       the information relates to legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings;
·       giving access would reveal the intentions of the entity in relation to negations with the individual in such a way as to prejudice those negotiations;
·       giving access would be unlawful;
·       denying access is required or authorised by or under an Australian law or a court/tribunal order;
·       WEM Civil suspects that unlawful activity, or serious misconduct, that relates to the entity’s functions or activities has been, is being or may be engaged in and giving access would likely prejudice the tasking of appropriate action in relation to the matter;
·       giving access would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
·       giving access would reveal evaluative information generated within WEM Civil in connection with a commercially sensitive-decision making process.

DESTRUCTION OF PERSONAL INFORMATION

WEM Civil will hold personal information for as long as necessary in order to meet the purposes described in this policy. This will normally be for up to 7 years from the date of collection. When we no longer require your personal information we will de-identify or destroy your personal information.

COMPLAINTS

An individual may make a complaint in writing about how their personal information has been dealt with by contacting People & Culture at peopleteam@wem.com.au. If making a complaint, the individual must describe the nature of the complaint and provide sufficient information to enable WEM Civil to respond.  WEM Civil will generally respond in writing to a written complaint within 28 days of receipt.

DOCUMENT OWNERSHIP AND SIGN OFF

The Workplace Privacy Policy is owned by Michael Ragg, Chief Executive Officer. The current version is dated September 2025.