Workforce Screening Procedure

Nomenclature

Term	Definition
ASIC	Australian Securities and Investments Commission.
DISP	Defence Industry Security Program.
DS&VS	Defence Security and Vetting Service.
DSPF	Defence Security Principles Framework.

Purpose

The Defence Industry Security Program (DISP) helps secure Defence capability through strengthened security practices in partnership with industry. It enhances Defence’s ability to manage risk in the evolving security environment. DS&VS manage DISP to support Defence Groups and Services, and defence industry, in managing security risks.

Defence has granted Westlink Logistics Pty Ltd with a DISP Membership at the following levels:

Security Domain	Membership Level
Governance Security	Entry Level
Personnel Security	Entry Level
Physical Security	Entry Level
Information & Cyber Security	Entry Level

Westlink Logistics Pty Ltd is required to continue to meet the ongoing eligibility and suitability requirements, as outlined in the Defence Security Principles Framework (DSPF) Principle 16 and Control 16.1 Defence Industry Security Program to maintain their DISP membership.

Membership in the Defence Industry Security Program (DISP) requires suitable Personnel Security practices, including compliance with Australian Standard AS 4811-2022 for Workforce Screening.

Westlink Logistics has committed to establishing and maintaining compliance with AS 4811-2022. This procedure clarifies the specific requirements for AS 4811-2022 compliance and outlines supporting procedures.

Scope

The objective of the screening process is to reduce the risk of a potential security breach. It confirms the integrity, identity and credentials of personnel within Westlink Logistics.

The focus of AS 4811-2022, this procedure and the supporting processes is to perform the workforce screening process as part of a standard operating procedure.

Definitions

Terms and acronyms used in this document are defined in the Nomenclature table at the front of this document.

Responsibilities

Role	Responsibility
Chief Executive Officer	Holds overall accountability for the workforce screening program and Westlink Logistics’ DISP membership obligations. Acts as the final mechanism in the screening appeals process, or delegates that role.
Security Officer	Oversees Personnel Security under DISP, including ongoing eligibility and suitability under DSPF Principle 16 / Control 16.1, and the alignment of screening practice with AS 4811-2022.
Human Resources	Owns the screening process within the employment lifecycle. Maintains workforce screening records, manages applicant consent and disclosure, and controls access to personal information on a need-to-know basis.
Screening Personnel	Perform identity, integrity and credentials checks (including the 100-point identity check and national criminal records checks for relevant roles). Undergo the same screening process they administer.
Hiring Manager / Supervisor	Defines the role requirements and the level of screening commensurate with the role’s risk, and accesses a specific applicant’s screening information only as needed for the open position.
Line Manager	Performs the independent review of the screening outcome when an applicant initiates a right-of-review, and advises the applicant of the result.
Third-party screening service (external)	Where engaged to conduct screening, complies with the requirements of this procedure and undergoes equivalent screening.

Procedure

Workforce Screening Principles

The workforce screening program has been designed and adopted on a risk management approach. It aligns to the relevant standard, ISO 31000:2018, to support this approach.

The AS 4811-2022 Standard provides for both mandatory and recommended elements. This provides Westlink Logistics with flexibility to adapt AS 4811-2022 to its needs as the business changes over time.

Westlink Logistics has chosen to adopt those AS 4811 recommended elements which are provided below.

Identity

Westlink Logistics shall perform an identification check to confirm that the applicant is who they claim to be. In this process, Westlink Logistics’ screening personnel are required to sight a form of government-issued photo identification such as a driver’s licence or passport.

For permanent and other relevant roles, further identity confirmation using the 100-point formula should be performed.

Westlink Logistics shall not request any applicant to provide a Tax File Number as a form of identification under any circumstances. Doing so is a violation of the Taxation Administration Act 1953 and is strictly prohibited under this procedure.

Westlink Logistics shall not seek access to an applicant’s credit history except in exceptional circumstances and only as provided under the Privacy Act.

Integrity & Credentials

Current and potential trusted persons should be required to sign a declaration that they will notify Westlink Logistics of any significant change in their circumstances.

It is preferable to complete the screening process before making an offer of permanent employment. It is recognised, however, that this is not always possible.

Casual Employee Screening

• Effective employment screening should be done (a) before appointment and (b) prior to moving to permanent.

• CVs should be checked to ensure there are no unexplained gaps or anomalies.

• Employment references should be obtained from persons to whom the applicant has reported directly if possible.

• Employment references should be undertaken with the Human Resources departments of former employers to verify dates of employment and positions held for the 5 years prior to application for relevant roles.

• Screening personnel should verify the person’s declared academic qualifications and licences are current and kept on file.

• National criminal records check issued by an appropriate authority should be performed for relevant roles.

Permanent Employee Screening

• In addition to the screening specified for casual employees above, personal and employment references for a minimum of five years should be sought.

Westlink Logistics shall comply with the Commonwealth Spent Convictions Scheme (Part VIIC of the Crimes Act 1914 (Cth)) and applicable State and Territory spent-conviction legislation. These schemes give an applicant the right to not disclose certain convictions or findings of guilt. A spent conviction is a conviction for a Commonwealth, Territory, State, or foreign offence which satisfies all of the following conditions:

• It is 10 years since the date of conviction (or 5 years for child offenders);

• The individual was not sentenced to imprisonment or was not sentenced to imprisonment for more than 30 months;

• The individual has not re-offended during the 10-year waiting period (or 5 years for child offenders); and

• A statutory or regulatory exclusion does not apply.

Convictions which have been set aside or pardoned are also protected under the Spent Conviction Scheme.

Special Requirements

Westlink Logistics will ensure that they meet all legislated requirements for employment screening related to specific industries or types of work such as working with children, aged care and financial services.

Communications

Employee Communications

All current and prospective Westlink Logistics employees subject to a workforce screening shall be notified that workforce screening is being implemented. They shall also be told how this process will affect Westlink Logistics’ employment process.

Applicant Communications & Disclosure

All personal information collected will be with the Applicant’s acknowledgment and written consent.

The applicant shall be told the following information:

• Which checks/screens will be performed;

• How the information collected will be used; and

• Who may have access to the information collected.

Records

General

Personal information is to be used only for the purpose for which it was collected, i.e. workforce screening, and shall not be used for any other purpose.

Upon request, applicants shall be given access to their personal information and allowed to confirm that it is complete and correct.

Westlink Logistics understands and respects the confidential nature of the personal information used for employment screening. Access to this personal information is restricted as follows:

• Westlink Logistics’ screening personnel;

• Hiring Manager or Supervisor for the open position;

• Human Resources;

• Management; and

• 3rd Party screening services contracted to Westlink Logistics.

Access to Personal Information

Access to personal information is strictly on a need-to-know basis. It is given only to those Westlink Logistics personnel who require a specific applicant’s personal information to fulfil their roles in the workforce screening process.

Records

Westlink Logistics will comply with all applicable legislation regarding the collection, custody and destruction of personal information and workforce screening records.

Record	Location	Responsible	Retention
Workforce screening records (identity, integrity, credentials checks)	HR records	Human Resources / Screening Personnel	Per applicable legislation and QMS
Applicant consent and disclosure acknowledgments	HR records	Human Resources	Per applicable legislation and QMS
Identity verification (100-point) and criminal records check results	HR records (need-to-know access)	Screening Personnel	Per applicable legislation and QMS
Screening review / appeal records	HR records	Line Manager / Human Resources	Per applicable legislation and QMS

Screening Personnel

All personnel responsible for the workforce screening process shall undergo the same screening process.

If screening procedures are conducted by a 3rd party agency, the agency staff shall also comply with the requirements of this procedure.

Right of Review

The competitive nature of the employment application process naturally requires the evaluation of more than one candidate for any open position with Westlink Logistics. As a result, many applications to Westlink Logistics do not result in an offer of employment.

An applicant has the right to appeal the results of the employment screening process when it results in an unfavourable outcome. The following steps outline the procedures to be followed in this situation.

To initiate a review, the applicant must formally request a review of the screening process outcome in writing. For this purpose, written or email requests are acceptable. Verbal requests, in person or over the phone, are not sufficient to initiate a review.

After a review is initiated, the Westlink Logistics screening personnel who performed the initial employment screening will review their work. They will provide an updated recommendation to their line manager. The line manager will perform an independent review of the screening process and advise the applicant accordingly per the steps that follow.

If ALL of the following apply:

• the outcome of the review process is favourable; and

• the original position applied for remains open or the applicant is deemed the top candidate for another open Westlink Logistics position,

then an offer of employment will be made to the applicant and the review will be closed.

If ANY of the following apply:

• the outcome of the review process is unfavourable; or

• the original position applied is no longer open or the applicant is not deemed the top candidate for another open Westlink Logistics position,

then the applicant will be advised accordingly, an offer of employment will not be made, and the review will be closed.

References

This procedure is read in conjunction with the internal documents listed in the Related Documents table in the front matter. It also draws on the following external sources: AS 4811-2022 (Workforce Screening); ISO 31000:2018 (risk management); the Defence Security Principles Framework (DSPF) Principle 16 / Control 16.1; the Privacy Act 1988 (Cth); the Taxation Administration Act 1953 (Cth); and the Commonwealth Spent Convictions Scheme (Part VIIC of the Crimes Act 1914 (Cth)).

Appendix A — Extract from AS 4811-2006

The source document reproduces an extract from the superseded AS 4811-2006 edition as a table image. The current best-practice recommendations under the in-force AS 4811-2022 edition are set out in Appendix B.

Appendix B — AS 4811-2022 Employment Screening Best-Practice Recommendations

The following checklist contains several recommended elements of the AS 4811-2022 standard. For minimum-effort compliance these elements are not required. In many cases, however, these elements represent best practice, and this is why they have been included in the AS 4811-2022 standard.

• Effective employment screening should be done (a) before appointment and (b) prior to moving to permanent.

• Current and potential trusted persons should be required to sign a declaration that they will notify their employer of any significant change in their circumstances.

• For permanent and other relevant roles, further identity confirmation using the 100-point formula should be performed.

• CVs should be checked to ensure there are no unexplained gaps or anomalies.

• Personal and employment references for a minimum of five years should be sought.

• Employment references should be obtained from persons to whom the entrusted persons have reported directly.

• National criminal records check issued by an appropriate authority should be performed for relevant roles.

• Verify the person’s declared academic qualifications, licences, and professional memberships.

• Employment references should be undertaken with the Human Resources departments of former employers to verify dates of employment and positions held for at least the 5 years prior to application.

• Probity should be monitored during the term of employment, at time of transfer, and upon promotion.

• Consideration should be given to screening current employees.

• Level of screening conducted for the role should be commensurate with the level of risk posed by that role.

• Effective employment screening should be done (a) prior to completion of the probationary period and (b) upon promotion or change of employment circumstances.

• There should be systemic and regular reviews of (a) positions with particular risk exposures and (b) changes in an employee’s personal circumstances.

• Where the entrusted person has resided overseas for a substantial period, the equivalent overseas check should be undertaken.

• Verify address history for a minimum of five consecutive years prior to application.

• For relevant roles, undertake a search of ASIC’s database to determine if the candidate is a current or former officeholder within an Australian company.

• If an applicant fails to meet the employment screening standards, they should be advised of the grounds for the rejection of their application and any avenues of appeal open to them.

• The employer should do everything possible to ensure that there has been no breach of human rights, natural justice or discrimination legislation before advising an applicant of their failure to gain a position.

• Legal or other professional advice should be sought before establishing a policy for psychometric, drug and medical testing of potential employees.

• Once an organisation has determined that there is no longer a need to keep personal information, it should be destroyed.

• Staff responsible for the employment screening process should possess the necessary qualifications and experience to conduct employment screening on behalf of the organisation.

• Personnel regularly employed in interviewing, screening and testing duties should undergo suitable internal and external training.

• For organisations with fewer than 50 employees, the appeals process should include the proprietor or board of management (or its equivalent) as the final mechanism.

• For organisations with greater than 50 employees, there could be an appeals committee, or an appeal could go to the CEO or their delegate.