What happened

MSS Security employed four security officers at the gatehouse of Thales's Bendigo site, described in the judgment as a secure defence manufacturing facility. The site had a perimeter fence and a single access gate. The officers' work included controlling access by people and vehicles, performing other gatehouse duties, and using computer-based systems. Outside the hours of 8.00 am to 4.00 pm, the officers worked without supervision on the site and acted as security controller for it ([1], [22]).

The dispute was about the officers' classification under clause 20 of the MSS Security Victorian Enterprise Agreement 2017. MSS classified them at Security Officer Level 2. The UWU argued that their work should be classified at Level 3. Commissioner Gregory decided that Level 3 most accurately reflected their skills, responsibilities and indicative tasks ([1], [5]-[9]). The Commissioner referred to, among other matters, the employees' site knowledge, work with limited supervision, computer-based tasks and responsibility for emergencies outside normal business hours ([6]-[9]).

MSS appealed. Its grounds challenged the Commissioner's treatment of the classification definitions and factual findings, including findings about working alone, discretion, computer tasks, fire alarms and emergency-controller responsibilities. MSS also argued that the work substantially involved Level 2 duties ([2], [10]-[15]).

The Full Bench first considered whether permission to appeal was required. It accepted that clause 15.3.6 of the Agreement provided an independent right of appeal to a Full Bench. It then considered whether MSS had shown appealable error, rather than deciding the classification dispute afresh simply because MSS disagreed with the Commissioner's decision ([3], [18], [31]). The appeal was dismissed ([32]).

Why the court decided this way

The Full Bench approached the classification structure as having three elements at each level: a qualification and skills requirement, a general description of duties and responsibilities, and a list of indicative duties ([19]). It explained that an employee need not perform every indicative duty to fit a classification. The listed tasks help show when a role is likely to meet that level's general description.

The structure was also hierarchical. The Full Bench accepted that higher levels “cascade up”: a higher-level employee may perform tasks and carry responsibilities from lower levels. Accordingly, the fact that the officers performed some Level 1 or Level 2 tasks did not settle the question in MSS's favour ([20], [31]). The Full Bench also noted that the pay increments between these levels were small, and said that this did not suggest a significant qualitative change was needed between them ([21]).

Applying those points, the Full Bench identified features that, on their face, pointed towards Level 3. The officers worked primarily at a gatehouse at a large, complex and secure site; had immediate responsibility for access; used computer-based systems; and worked without supervision for part of their shifts ([22]). The Level 3 definition required the ability to exercise skills and possess knowledge of the location where the employee was posted, and contemplated work under limited supervision. The Full Bench considered that description closely matched the site-specific nature of the work ([23]).

The Full Bench also gave weight to the express Level 3 indicative duty of controlling the movement of people, vehicles, stock and material at gatehouses using computer-based systems requiring data input ([24]). It rejected MSS's argument that the Level 1 reference to being stationed at an entrance or exit meant that Level 2 encompassed the officers' work in the same way. The Full Bench distinguished the Level 1 wording, which referred to being stationed at an entrance or exit, from the Level 3 gatehouse duty. It also noted the Level 1 duty's general-supervision context and the absence of a comparable computer-based requirement ([25]).

On spreadsheet use, the Full Bench rejected the proposition that “manipulation” had to involve creating formulae or programming a spreadsheet. It said the ordinary meaning could include handling or controlling a spreadsheet skilfully, and that navigating one to input and extract data could fit. It also relied on the Level 3 requirement for computer skills higher than Level 2 ([24], [27]). The judgment did not say that every instance of data entry qualifies as Level 3 work; it distinguished the facts found in this case from straightforward data entry and assessed the tasks in the context of the Agreement's wording.

The Full Bench rejected the challenge to the finding that the officers worked alone and exercised discretion. MSS's own submissions had conceded that they worked alone, and the UWU had argued that they exercised significant discretion. The Commissioner could reasonably infer limited supervision and discretion from the evidence that they worked alone for much of the day ([26]).

It also rejected MSS's arguments about emergency duties and the Guard Post Orders. The Commissioner had found that the officers assumed responsibility as controller for emergencies outside normal business hours. MSS's witness had accepted that this was a Level 3 duty. The fact that it was required about six times a year did not make it irrelevant: the Full Bench considered readiness and capacity to respond to emergencies an important feature of the employment ([29]). The Commissioner had also considered the Guard Post Orders, finding them rudimentary and not necessarily an accurate account of how work was actually performed. The Full Bench said that finding had not been challenged on appeal ([30]).

Before and after state of the law

The decision applied the classification wording in this particular enterprise agreement. It did not announce a universal classification test for all security work or all enterprise agreements. Its central contribution in this dispute was to explain how the Agreement's three-part classification descriptions worked together: qualifications and skills, general duties and responsibilities, and indicative tasks ([19]).

Before the appeal was decided, the Commissioner had classified the officers at Level 3, reasoning from their actual work and responsibilities rather than treating the indicative-task lists as exhaustive ([5]-[9]). The Full Bench left that outcome undisturbed. Its reasoning clarified that the indicative duties were guides, not a requirement that every listed task be performed, and that a higher classification could include work described at lower levels ([19]-[20]).

The Full Bench also clarified its reading of the Level 3 computer wording. It did not treat spreadsheet manipulation as necessarily requiring formula creation or advanced programming. It considered that inputting and extracting data through a spreadsheet could meet the wording, where the overall evidence showed computer skills above Level 2 ([24], [27]). This is a reading of the Agreement before it, not a finding that all data-entry roles are Level 3.

The decision discussed the small pay increments between Levels 1, 2 and 3, and observed that they did not imply the need for a major qualitative shift in duties at each level ([21]). That observation supported the Full Bench's reading of the particular structure; it should not be detached from the Agreement's language and used as a rule about other classification systems.

Key passages with plain-English translation

At [19], the Full Bench said it was “plainly not necessary for all the indicative duties for a classification to be performed” to classify an employee at that level. In plain English, the duty list is not a checklist. It helps interpret the general description, but the assessment remains one of the role as a whole.

At [20], the Full Bench said that an employee's duties at a particular level “include those of the lower classification levels.” In plain English, doing some lower-level work does not automatically rule out a higher classification. The question is whether the position, considered overall, fits the higher level's requirements.

At [24], the Full Bench connected the officers' work to the Level 3 gatehouse duty. It said the computer tasks found by the Commissioner could meet the description of computer-based systems requiring data input. It also explained that spreadsheet manipulation did not necessarily involve programming functions. In plain English, the Full Bench did not read “manipulation” as demanding advanced spreadsheet programming.

At [27], it rejected MSS's reliance on a sentence in Carnes suggesting that manipulation involved changing spreadsheet parameters or creating formulae. The Full Bench treated those as possible examples, not essential criteria. It noted that the Agreement separately described Level 3 as requiring computer skills higher than Level 2.

At [29], the Full Bench said that emergency duties remained relevant even if exercised only rarely. In plain English, classification could take account of a responsibility that arises infrequently, where the employee must be ready and able to perform it when needed.

Finally, at [32], the Full Bench said it was not persuaded that appealable error had been demonstrated and dismissed the appeal. The result was that the Commissioner's Level 3 decision stood.

What fact patterns trigger this precedent

The reasoning is most directly relevant to disputes involving this Agreement, or a classification structure with similar wording, where an employee's actual duties span more than one level. The judgment is particularly relevant where the role involves substantial work at a gatehouse, computer-based access or monitoring systems, site-specific knowledge, and work with limited supervision ([22]-[24]).

It may also be relevant where one party argues that the employee cannot fit a higher level because they perform lower-level duties. The Full Bench's response was that the structure was hierarchical, with duties from lower classifications incorporated into higher ones ([20], [31]).

The decision may assist in understanding disputes about what spreadsheet “manipulation” means under the wording considered here. It does not establish that simple data entry alone will always satisfy Level 3. The Full Bench relied on the Commissioner's findings about the range of tasks and the higher computer skills required by Level 3 ([24], [27]).

The emergency-responsibility reasoning may be relevant where a role includes infrequent but important readiness functions. The Full Bench's point was tied to the facts: MSS's witness accepted the emergency-controller function was a Level 3 duty, and the officers were responsible for it outside normal business hours ([29]).

Care is needed before applying the decision to a different instrument or role. The judgment's reasoning depends on the specific words of clauses 20.1 to 20.3 and the evidence about the Thales site and these employees' duties ([4], [22]-[24]).

How later courts have treated it

The supplied judgment contains no information about later decisions applying or interpreting MSS Security Pty Ltd t/a MSS Security v United Workers' Union. It therefore does not support conclusions about how later courts or tribunals have treated this decision.

The Full Bench did refer to two earlier Commission decisions. In Harland v MSS Security Pty Ltd [2013] FWC 8064, the Commission had considered a highly similar classification structure in the Security Services Industry Award 2010. The Full Bench said Harland treated typical gatehouse duties involving computerised functions that were not particularly complex as fitting within Level 3, and that this was consistent with its approach ([24]).

The Full Bench also discussed Carnes v MSS Security Pty Ltd [2019] FWC 7695. It said Carnes turned on its own facts and rejected MSS's submission that the decision's reference to spreadsheet parameters or formulae established an essential requirement for Level 3 classification ([27]). The Full Bench's treatment was not that formula creation could never be relevant; rather, it was not a necessary element under the Agreement's wording.

Still-open questions

The judgment resolves the appeal on the facts and Agreement before it. It does not set out a comprehensive method for weighing every possible conflict between an employee's actual duties and an indicative-task list. It explains that indicative duties guide the general description and that higher levels include lower-level duties, but the assessment still depends on the relevant evidence and the specific classification language ([19]-[20]).

The decision does not establish a minimum amount or frequency of spreadsheet use that would meet the Level 3 computer-skills requirement. It explains that creating formulae is not essential and that navigating a spreadsheet to input and extract data could fit, but it does not define a universal threshold ([24], [27]).

Nor does the judgment set a general test for how much site knowledge, discretion or unsupervised work is enough for Level 3. Its conclusion relied on the officers' actual conditions at a large and complex site and their responsibilities there ([22]-[23], [26]).

Finally, the decision does not indicate how a later Full Bench or court has treated its reasoning. The source provided ends with the appeal's dismissal on 27 March 2020. Any assessment of subsequent treatment would require later legal sources.

This is general legal information, not legal advice. Zoe can make mistakes. Before acting on this, relying on it, or using any draft, have a qualified Australian lawyer check it.

Judgment (75 paragraphs)

MSS Security Pty Ltd t/a MSS Security v United Workers' Union (108V) [2020] FWCFB 1652 (27 March 2020)

Fair Work Act 2009

s.604 - Appeal of decision

Appeal against decision [2019] FWC 8209 of Commissioner Gregory at Melbourne on 5 December 2019 in matter number C2019/462.

[1] This is an appeal by MSS Security Pty Ltd (MSS) against a decision of Commissioner Gregory on 5 December 2019[1] (decision) made pursuant to s 739 of the Fair Work Act 2009 (FW Act) and clause 15, Settlement of Disputes of the MSS Security Victorian Enterprise Agreement 2017 (Agreement). The dispute the subject of the decision concerned whether four security officers employed by MSS at the gatehouse of the site of its client Thales in Bendigo were correctly classified by MSS at Security Officer Level 2 (Level 2) in the classification structure in the Agreement. The site in question is a secure defence manufacturing facility, and all entry and exit is via the gatehouse. The United Workers' Union (UWU), which lodged the application for the Commission to deal with the dispute, contended that the employees should have been classified at Security Officer Level 3 (Level 3). In the decision, the Commissioner upheld the UWU's position.

[2] In its appeal, MSS contends in summary that the decision was in error and should be quashed because the Commissioner:

erred in his findings of fact about what duties the relevant security officers perform and how they perform their duties;

erred by taking into account irrelevant considerations;

erred failing to take into account, or have sufficient regard to certain evidence, and gave excessive weight to other evidence;

misconstrued the Level 2 classification definition in the Agreement; and

wrongly applied the "principal purpose" test.

[3] There is a dispute as to whether permission to appeal pursuant to s 604 of the FW Act is required. MSS submits that it is not because clause 15.3.6 of the Agreement provides for a right of appeal. The UWU contends otherwise. Clause 15.3.6 provides:

15.3.6 The decision of FWC will bind the parties, subject to any party exercising a right of appeal against the decision to a Full Bench.

[4] The classification structure in clause 20 of the Agreement provides for five "Security Officer" Levels, and is highly similar to the classification structure found in Schedule C of the Security Services Industry Award 2010. It is only necessary to refer to Levels 1, 2 and 3 in the Agreement, which are defined as follows:

20.1.1 A Security Officer Level 1 is an employee who has completed at least a Certificate II in Security Operations so as to enable the employee to perform work within the scope of this level and who performs work to the level of their skills, competency and training.

is responsible for the quality of his/her own work subject to general supervision;

works under general supervision, which may or may not necessarily be at the site where the officer is posted, either individually or in a team environment;

exercises discretion within his/her level of skills and training; and

assists in the provision of on the job training.

20.1.3 Indicative of the tasks which an employee at this level may perform are the following:

watch, guard or protect persons and / or premises and / or property at sites / locations where the complex use of computer technology is not required;

Be stationed at an entrance/exit, where principal duties will include the control of movement of persons, vehicles, goods/property coming out of or going into premises or property, including vehicles carrying goods of any description, to ensure that the quantity and description of such goods is in accordance with the requirements of the relevant document/gate pass;

basic crowd control functions including at shopping centres, major events, sporting tournaments, nightclubs, sporting venues and other entertainment venues or public areas where events, concerts or similar activities are conducted;

respond to basic fire / security alarms at their designated post;

in performing the duties referred to above the officer may be required to use electronic equipment such as hand-held scanners and simple closed circuit television systems utilising basic keyboard skills which do not require data input; and

provide safety induction to employees, contractors or visitors to the site.

20.2.1 A Security Officer Level 2 is an employee who has completed at least a Certificate II in Security Operations so as to enable the employee to perform work within the scope of this level.

20.2.2 An employee at this level performs work above and beyond the skills of a Security Officer Level 1 and to the level of his/her skills, competence and training.

works from complex instructions and procedures under general supervision which may or may not necessarily be at the site where the officer is posted;

assists in the provision of on-the-job training;

exercises good interpersonal communications skills;

co-ordinates work in a team environment or works individually under general supervision of a more senior security officer who may or may not necessarily be on site;

is responsible for assuring the quality of his /her own work; and

is required to act as first response to security incidents/matters.

20.2.4 Indicative of the tasks which an employee at this level may perform are the following:

duties of securing, watching, guarding, protecting as directed, including responses to alarm signals and attendances at and minor non-technical servicing of automatic teller machines (ATMs). Such work shall not be undertaken alone and shall not include cash replenishment at ATMs;

advanced crowd control functions including at shopping centres; major events, sporting tournaments, nightclubs, sporting venues and other entertainment venues or public areas where events, concerts or similar activities are conducted;

to patrol in a vehicle two or more separate establishments or sites, including where more than one site held by the same business is patrolled;

[1]

monitor and respond to electronic intrusion detection or access control equipment terminating at a visual display unit and/ or computerised printout (except for simple closed circuit television systems). Such work shall not include complex data input into a computer;

[2]

monitor and act upon walk through electromagnetic detectors; and or monitor, interpret and act upon screen images using x-ray imaging equipment;

[3]

the operation of a public weigh-bridge by a Security officer;

[4]

recording and/or reporting security incidents or matters on a computer based system; and

[5]

may be required to perform the duties of a Security Officer- Level 1.

20.3.1 A Security Officer Level 3 is an employee who has completed at least a Certificate II in Security Operations and is able to exercise the skills and possess the knowledge of the location where the employee is posted by the Company so as to enable the employee to perform work within the scope of this level under limited supervision which may or may not necessarily be at the site where the officer is posted.

20.3.2 A Security Officer Level 3 works above and beyond the skills of an employee at Level 1 and Level 2, and to the level of his/her skills, competence and training.

works from complex instructions and procedures under limited supervision;

exercises good interpersonal and communications skills;

exercises computer skills at a level higher than Level 2;

assists in the provision of on the job training;

exercises discretion within the scope of this classification level; and

performs work independently under limited supervision either individually or in a team environment.

20.3.4 Indicative of the tasks which an employee at this level may be required to perform are the following:

control of movement of persons, vehicles, stock and material at gatehouses and similar locations utilising monitoring and operating computer based systems requiring data input, including manipulation of spreadsheet based computer programs or other advanced monitoring system;

monitor and operate, under supervision, building operation systems terminating at a visual display unit or computerised printout, including the monitoring of complex fire alarms, water towers/chillers, temperatures and other similar building operational system functions;

stock and material control at computerised gatehouses and similar locations requiring data input and manipulation of computer programs e.g. Microsoft Excel and other similar computer programs;

provide safety induction to employees, contractors or visitors to the site; and may be required to perform the duties of a Security Officer - Level 1 and Security Officer - Level 2."

[5] In his decision the Commissioner, after identifying the subject matter of the dispute and summarising the evidence of the witnesses, described the task involved in determining the dispute as follows:

"[72] Clause 20 of the 2017 Agreement sets out the classification structure. It involves an escalating level of skill, responsibility, authority and complexity of duty from the lowest level to the higher levels. There is also some commonality of tasks and functions which are carried out to varying degrees at each classification level, and there is inevitably some overlap between each level, with no definitive border or boundary between any two classification levels. There is also a description at each level of the skills and responsibilities required to be exercised at that level. This is followed by some examples of the indicative tasks an employee at each level may be required to perform.

[73] The task of establishing which is the correct classification level for the Security Officers at the Bendigo site accordingly involves having regard to the evidence and submissions regarding the work performed and the responsibilities undertaken. It is then necessary to make a comparison with the job descriptions and indicative tasks set out at each classification level..."

[6] The Commissioner then proceeded to make findings of fact concerning the work of the employees in question. He initially found as follows:

"[87] The evidence makes clear that the Bendigo site is relatively large and has a diverse range of facilities. The Security Officers work alone, and this requires them to exercise a degree of discretion in terms of how they carry out their responsibilities, given that they have limited immediate supervision or support available.

[88] It is also clear that there are a number of duties and responsibilities that the Security Officers can be required to carry out, and while some may only be performed infrequently, it is still necessary that they are familiar with what is required in the event that they need to be carried out."

[7] The Commissioner then referred to a contest about the nature of computer-based tasks performed by the employees, and found:

"[89] Much emphasis has been the placed on the requirement to carry out computer-based tasks. UWU submits that these do involve a degree of complexity and in some cases do require the manipulation of data. MSS has attempted to downplay the significance of these requirements and submits that they only involve straightforward data entry. It also submits that there are still a number of paper-based processes. However, it is clear from the evidence that the preparation and issuing of ID cards, for example, involves a number of different computer-based processes and steps. There are also a range of other computer-based duties and responsibilities that have been identified in the evidence including:

• the loan register which is maintained on a Microsoft Excel spreadsheet;

• the MEX OPS for recording necessary maintenance and other issues that arise from time to time during the course of the shift;

• the control database of visitors and contractors working at the site which utilises Lotus Notes. This is a computer-based system which is used to record the site entry and departure of contractors and visitors;

• the pool car register which is maintained on a Microsoft Excel spreadsheet.

[90] ... the evidence also makes clear that the Security Officers are required to silence a fault alarm and identify the location of any fault alarms. Any actual fire alarms are also required to be recorded in ISOPRO. They are also required to respond to the fire panel when necessary. The Security Officers also assume the responsibility of controller at the site outside of normal business hours in relation to any emergency situations that might arise, and this is acknowledged by MSS to be a significant responsibility which is appropriately classified at Level 3."

[8] The Commissioner also found that the employees:

• are required to have a significant degree of knowledge about the site, given its size and diversity, which is encompassed by the Level 3 classification;[2]

• are required to work independently with limited supervision and consequently are required to exercise a significant amount of discretion;[3] and

• the Guard Post Orders relied upon by MSS as dictating how the employees are to perform their duties cannot necessarily be relied on to provide an accurate representation of how the employees carry out their work and provide only a rudimentary description of how they carry out their duties and responsibilities;[4]

• the principal purpose of the employees' employment was to perform a range of duties and responsibilities at the gatehouse which include both data entry, the manipulation of computer programs such as Microsoft Excel and also important responsibilities in relation to fire alarms and out of hours emergency situations.[5]

[9] In relation to the last of these factual findings, the Commissioner noted that the classification definition for Level 2 makes no reference to work in a gatehouse or similar location in the list of indicative duties, unlike Level 3, and instead refers to work at other locations such as a shopping centre, nightclub or sporting or entertainment venues. The Commissioner also noted the qualification attached to gatehouse duties in the Level 3 definition, but made it clear that this was satisfied by this last factual finding.[6] He then concluded:

"[99] I am satisfied, in conclusion, that the work being carried out by the Security Officers at the THALES Bendigo site is most accurately reflected by the skills and responsibilities, and the indicative tasks, set out in the Security Officer Level 3 classification in the 2017 Agreement, and they should accordingly be classified at this level."

[10] MSS submitted that the Commissioner erred in six respects. First, it submitted that the Commissioner misconstrued the classification definition of Level 2 by finding that it did not encompass work in a gatehouse or similar location, but rather was concerned with other types of locations. These locations, it was submitted were only mentioned in the context of advanced crowd control duties, and the Level 2 definition was not confined to these but encompassed a broad range of security duties. The Level 2 definition also included the control of the movement of goods to and from premises and the use of non-complex computer technology, which implied the use of a gatehouse facility.

[11] Second, MSS submitted that the Commissioner erred in finding that the employees worked alone, since the evidence demonstrated that for the vast majority of the site's operation they worked under the general supervision of an on-site Senior Security Officer (SSO). Nor did the employees exercise a significant amount of discretion. There was no evidence to support his nor was it even suggested by the UWU; rather the evidence showed that the employees worked closely from complex written instructions.

[12] Third, it was submitted that the Commissioner's findings about the performance of computer-based tasks was in error, in that:

the employees did not prepare and issue ID cards; only one did so and only rarely; and

• the employees did not manipulate computer programs (in the way discussed in Carnes v MSS Security Pty Ltd[7]) but only performed printing, simple data entry and checking of online registers/databases.

[13] Fourth, MSS submitted that the Commissioner erred in finding that the employees monitored and operated building operation systems merely because they responded to fire alarms and the fire panel, which is auto-monitored.

[14] Fifth, MSS submitted that in finding that the employees are required to assume the role of controller at the site outside business hours in relation to emergency situations that might arise, the Commissioner erred by failing to consider that this was only required about six times per year, that employees performed this duty under the direction and supervision of Thales, and failed to consider the Guard Post Orders. Further, it was submitted, this task fell within the Level 2 duties.

[18] We accept MSS's submission that it does not require permission to appeal. Clause 15.3.6 confers in the clearest of terms an independent right of appeal. Accordingly our only task is to consider the merits of the appeal - that is, whether MSS has demonstrated that the decision is attended by appealable error.

[19] Before we turn directly to MSS's six contentions of error, it is necessary first to consider the key characteristics of the classification structure in clause 20 of the Agreement and the task involved in applying the structure to the positions and work of the employees the subject of the dispute. In our view, there are three main features of the classification structure relevant to the determination of this appeal. The first is that each classification is defined by three elements: (1) a qualification and skills requirement; (2) a general description of the duties and responsibilities at the classification level; and (3) a list of indicative duties. It is plainly not necessary for all the indicative duties for a classification to be performed in order for an employee to be classified at a particular level. However, the purpose of statements of indicative duties in classification structures of this nature is to indicate when it is likely to be the case that a particular position meets the general description of duties and responsibilities in the second element of a particular classification. Thus, subject to what we say immediately below, where the indicative duties for a given classification are a significant element of a person's position, that points to the position being one which involves the general duties and responsibilities for that classification unless there is some other disqualifying factor.

[20] The second is that the classification structure is a hierarchical one which, as the UWU described it, "cascades up" in terms of the duties required to be performed. As stated by the Commissioner in the decision, at each level of the structure beyond Level 1, an employee works above and beyond an employee at the previous levels and exercises the skills, and may perform the tasks, at the previous levels. That means that the mere fact that an employee may be required to discharge the general responsibilities or perform some of the indicative duties of a particular classification does not preclude them being properly classified at a higher level. To put this another way, the duties and responsibilities of an employee at a particular classification level include those of the lower classification levels.

[32] For the reasons given, we are not persuaded that any appealable error in the decision has been demonstrated. The appeal is therefore dismissed.

Seal of the Fair Work Commission with Member's signature.

Mr J Nolan of counsel with S Leung for the Appellant.

[1] [2019] FWC 8209

[7] [2019] FWC 7695

[8] This was conceded by one of MSS's witnesses, as recorded in paragraph [58] of the decision

[9] Harland v MSS Security Pty Ltd [2013] FWC 8064 at [33]- [37]

[10] [2019] FWC 7695

Printed by authority of the Commonwealth Government Printer

MSS Security Pty Ltd t/a MSS Security v United Workers' Union

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