Effective Date February 2019
Policy Owner Group Legal
Applies to All GWF employees, contractors, customers & visitors in Australia New Zealand and to all visitors to this site www.gwf.com.au
Contact Officer Your Privacy Officer
This signed statement of Policy confirms our commitment to making George Weston Foods Limited workplaces legally compliant for ALL and is to be displayed at all work locations.
George Weston Foods Limited, George Weston Foods (NZ) Limited and their related companies (GWF, we, us, our) recognise the importance of your privacy and we are committed to protecting the personal information which we hold.
We are bound by a range of privacy laws including applicable privacy principles under the Privacy Act 1988 (Australian Act) in Australia and the Privacy Act 1993 (NZ Act) in New Zealand.
In Australia, “personal information” has the meaning set out in the Australian Act. In New Zealand, “personal information” means information about an identifiable individual. This Policy is also designed to notify you of the types of surveillance that are carried out on our premises or otherwise in relation to the provision of your services to GWF.
If you engage workers to provide services to GWF, you must ensure that they are provided a copy of this Policy.
This Policy may be reviewed, varied, added to or withdrawn by GWF at any time, at our absolute discretion. This Policy, and any amendments to it, does not form part of any employment contract or agreement or your independent contractor agreement (as the case may be).
We will only collect personal information when it is reasonably necessary for us to perform our functions or as otherwise authorised or permitted by law. The kinds of personal information we collect from you will depend on the circumstances in which the information is collected and your relationship with us, including the type of products and services we provide to, or acquire from, you. It may include, for example, the following information:
We will not collect sensitive information from you (being information or an opinion about a person’s racial or ethnic origin, political opinions, philosophical or religious beliefs or affiliations, membership of a political, trade or professional association or union, sexual preferences or practices, criminal record, genetics, biometric identifiers or health information) unless it is required for one or more of our functions or activities and you have provided your consent, or we are required to collect this information by law.
We may collect personal information about you in a number of ways, including:
If you apply for a position with us, we may collect your personal information from third parties such as recruitment service providers, referees, former employers, educational institutions and, if appropriate, health and psychometric testing providers and police. We may use that personal information to assess suitability for positions with GWF and to make contact about relevant positions.
If you are a contractor (or person engaged by a contractor) working at a GWF workplace, we may collect and use biometric information such as a scan of your finger and location data. The information collected will be in accordance with this Policy and will be used for time recording, attendance and payroll purposes. All biometric information will be collected through a secure system, which is electronically encrypted and to which access is strictly limited to staff whose tasks require access. All biometric information is securely destroyed upon termination of a contractor’s engagement with GWF.
GWF also uses location tracking technology for time recording purposes, to ensure the safety and security of contractors, and to assist it to comply with its legal obligations. All location data will be collected through geo location services such as mobile phones, laptops and in car devices and you may be required to turn on location services while performing your contracted services.
If you visit a GWF site, you may be recorded by surveillance cameras which are used in strategically located internal and external areas of the workplace to improve and monitor the safety and security of GWF staff, contractors, property and resources and to monitor and investigate compliance with legal requirements and GWF policies.
For new contractors, location tracking and camera surveillance will start from the date they start providing services to GWF, and will be undertaken continuously and on an ongoing basis.
All information will be collected in accordance with this Policy and where it relates to the provision of your services to GWF, and will be used for payroll, superannuation, health and safety, security, administration, insurance (including Workcover or WorkSafe), contact and staff management purposes. Images may also be used in connection with legal proceedings.
We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, and better understand the visitors to our Platform, we may collect certain information via our Platforms through our advertising service providers. We or our vendors use several common online tracking tools to collect information about our users, such as browser cookies, web beacons, and other similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Platforms, search engine referrals, browsing activities over time and across other websites following your visit to one of our Platforms or applications, and responses to advertisements and promotions on the websites and applications where we advertise.
Our Platforms may include social media features such as the Facebook like button, twitter and widgets, such as the share button or interactive programs that run on our site. These features may collect your IP address, which pages you visit on our platforms, and how long for. If you’re a member of a social media platform, the interfaces may allow the social media platform to connect your visits to this platform with other personal information. Social media features and widgets are either hosted by a third party or hosted directly on our Platform. Your interactions with these features are governed by the privacy notice of the third party providing it and to the maximum extent permitted by law we accept no responsibility for the actions of those third parties.
We may provide an application programming interface (API) to enable third party applications to interface with our Platforms. Some applications enable you to interact with us through the API in a way that requires you to log in. To do this, most of these applications will direct you through a process where you are able to let the application connect to your account.
You may elect not to identify yourself, or to use a pseudonym, when engaging with us. However, if we are unable to collect your personal information we may not be able to provide products or services to you, or otherwise interact with you, effectively or at all.
To the extent permitted by law, we may use or disclose surveillance records and your personal information for the purposes for which we collected it, to provide you with or improve our products or services, to provide you with information about products and services offered or distributed by us, for other purposes to which you have consented, or as otherwise permitted or required by law.
To the extent permitted by law, we may use surveillance records and contractors’ personal information for payroll, superannuation, health and safety, security, administration, insurance (including Workcover or WorkSafe), contractor and staff management purposes. Some of that information we are required to collect under applicable laws. In extreme circumstances we may need to restrict an individual’s access to the workplace or take disciplinary action.
We may disclose surveillance records and your personal information to:
Information processed by these third parties may include sensitive information. We require these third parties to handle any personal information strictly in accordance with applicable privacy laws (the Australian Act and the NZ Act, as applicable).
When we no longer require personal information for any of the purposes for which it was collected we will, subject to any on-going legal requirements to retain it, take reasonable steps to destroy or de-identify it.
The use, collection and disclosure of your information described above may involve us disclosing your personal information to third parties in countries including Australia, New Zealand, Singapore, Germany and the United Kingdom and any other countries where we have related bodies corporate. Where we disclose your personal information to third parties in countries outside the country in which your personal information was originally collected (originating country), we are often subject to specific cross-border disclosure privacy requirements which are designed to provide substantially similar privacy protections as those provided by the originating country.
We will take reasonable steps to protect personal information from misuse, interference, loss and from unauthorised access, modification and disclosure as required by law.
You have certain rights of access to and correction of your personal information under applicable privacy laws (the Australian Act and the NZ Act, as applicable).
You can request access to personal information that we hold about you by contacting the GWF Consumer Information Centre using the contact details listed below. We will respond to requests for access within a reasonable period after the request is made. Requests for a large amount of information, or information which is not currently in use may require further time before a response can be given. You may be required to pay a reasonable charge to access your personal information. We may refuse to give you access to your personal information where we are permitted to do so by law.
If you request us to do so we will take such steps as are reasonable in the circumstances to amend any personal information about you held by us which is inaccurate, incomplete or out of date. We will respond to your request within a reasonable period after the request is made. If we disagree with you about the accuracy, completeness or currency of a record of your personal information held by us, and if you ask us to record your request, we will take reasonable steps to associate a statement to that effect with the relevant record.
By providing us with your electronic contact details (including mobile number and email address) you agree that we, and our related companies, may send you commercial electronic messages for any of the purposes set out in this Policy or otherwise disclosed to you. We will generally ask you to opt in to receiving commercial electronic messages from us. You may opt out at any time.
From time to time it may be necessary for us to change this Policy. We will notify any changes by posting an amended version on our website.
If we become aware of any concerns or problems with information held by us, we will take these issues seriously and work to address them. If you would like to access personal information that we hold about you, or have a question or complaint, please contact us at
GWF Consumer Information Centre (CIC)
PO Box 555 Enfield NSW 2136
Phone (Australia):1800 645 515
Phone (New Zealand): 0508 000 111
In the case of complaints, GWF will endeavour to respond as soon as possible, within 14 working days, to let you know who is responsible for managing your query. GWF will try to resolve the complaint within 30 working days. When this is not possible GWF will contact you to provide an estimate of how long it will take to handle the complaint.
If you have not received a response from GWF within a reasonable time or are dissatisfied with the response, you may bring your complaint to the applicable Privacy Commissioner using the contact details below:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001 firstname.lastname@example.org
In New Zealand:
Office of the Privacy Commissioner
PO Box 10094
Stuart Grainger, GWF Chief Executive
Last Modified: February 2019