Policy - IPC WHS Policy

Read the document below or download it here: Policy - IPC WHS Policy July 2025

1. IPC WHS Policy Objective

Work health and safety (WHS) forms the basis of all sound decision-making and behaviours within the Information and Privacy Commission NSW (IPC).

The CEO/Information Commissioner, Privacy Commissioner, Directors and Managers are committed to ensuring the health, safety and welfare of all employees and workplace visitors, including customers, agency staff and contractors.

The IPC recognises that achieving a safe and healthy workplace relies on implementing a quality WHS Management System (WHSMS) that is aimed at both preventing injuries and illnesses from occurring, actively supporting injury management and a timely and sustainable early return to work for injured or ill workers.

Maintaining compliance with relevant WHS legislation, standards, codes of practice and guidelines is paramount and provides a basis for continuous improvement.

The IPC will demonstrate its success by:

• accepting responsibility and accountability for ensuring a healthy and safe workplace at all levels
• establishing clear and measurable WHS goals and targets as detailed in IPC’s WHS Plan 2024-26
• allocating appropriate resources to effectively manage WHS
• meeting legislative requirements, standards, codes of practice and guidelines
• increasing awareness of the importance of prevention
• providing competency-based WHS education and training in accordance with workplace needs
• encouraging employee participation and recognising persons who demonstrate excellence in their WHS performance and who develop innovative WHS solutions
• regularly monitoring, evaluating, and continuously improving WHS performance.

2. Roles and Responsibilities 

Our objective is that the IPC is a safe and healthy workplace for all staff and visitors through the implementation of effective WHS systems, quality procedures and a strong health and safety culture. 

Everyone at IPC has an important role to play in creating and maintaining a safe and healthy workplace, including the reporting of any hazards or incidents. Reporting for the IPC is done via the Department of Customer Service’s mySafety portal in SAP. 

People managers at the IPC play a particularly important role in managing WHS risks in their area of responsibility. They do this by identifying hazards, assessing risks, being active in eliminating or controlling those risks in consultation with their team members, reviewing any incidents and putting in place measures to minimize the risk of the incident re-occurring. 

By promoting a culture of regular and open communication, our people managers will engage their teams in meaningful consultation and disseminate relevant WHS information that enables our staff to contribute to the making of decisions that affect their health, safety and welfare. This includes ensuring that all members of staff are encouraged to report hazards and incidents in a supportive environment.

Extra requirements for “officers”

Our senior people leaders (Commissioners, Directors and Managers) each have a personal duty as an “officer” to exercise due diligence to ensure the IPC complies with the Work Health and Safety Act 2011 and Work Health and Safety Regulation 2017 (WH&S Act and Regulation). Anyone in a management role within the organisation, however, MAY be considered an officer under the WH&S Act in a particular context, depending on the decision they are making and whether that affects the whole, or a substantial part of the business or undertaking of the IPC. 

Officers under the WH&S Act are responsible for exercising due diligence by taking reasonable steps to:

• acquire and keep up-to-date knowledge of WHS legislation, policies and procedures
• understand the business of the IPC and generally the hazards and risks associated with those operations
• ensure appropriate resources and processes are applied to eliminate or minimise risks to health and safety
• ensure there are appropriate processes for receiving and considering information regarding incidents, hazards and risks to health and safety (the process for reporting incidents and hazards is through SAP)
• ensure the duties in the WH&S Act and Regulation are complied with, including reporting notifiable incidents, consulting with workers, complying with notices issued under the WH&S Act, providing training and instruction to workers about health and safety and ensuring Health and Safety Representatives receive training
• verify the provision and use of the resources and processes associated with these responsibilities.

Directors, Managers and Supervisors are therefore responsible and accountable for the safety of workers and others affected by the conduct of the business (such as visitors to our offices) and have the responsibility to, as far as reasonably able, ensure:

• the workplace under their control is safe and risks to health are controlled
• the behaviour of all persons in the workplace is safe and without risks to health
• all problems relating to work health and safety are remedied. 

If a Director, Manager or Supervisor does not have the authority to fix a particular problem, they must report the problem promptly - together with any recommendations for remedial action - to a person who does have the necessary authority. A Director, Manager or Supervisor who does have the necessary authority, will be held accountable for taking prompt remedial action to eliminate any unsafe or unhealthy conditions or behaviour, where reasonably practicable to mitigate the risk.

Everyone has a safety duty under the WH&S Act

All staff at IPC have a duty to:

• take reasonable care for their own health and safety
• take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons
• comply with safety instructions of Directors, Managers and Supervisors, including the use of safety equipment
• report any incidents, injuries and hazards through the mySafety reporting system; and
• cooperate with any reasonable IPC policy or procedure relating to health and safety at the workplace that has been notified to them.

3. Commitment

This policy is endorsed by both the Information Commissioner and Privacy Commissioner, in recognition of their roles as statutory officers and therefore persons conducting a business or undertaking (PCBU). Additionally, as agency head of the IPC, which is also a PCBU, the CEO is an officer for the purpose of the WH&S Act with overall responsibility to ensure requirements are met for staff employed by the IPC.

The IPC relies on the Department of Customer Service Employee Safety and Wellbeing Team, as a service provider to the IPC, in meeting its requirements as a PCBU.