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Practical Analysis

Federal privacy regulator sets a proportionality test for employee monitoring

Monitoring should be specific, necessary, transparent and no more intrusive than the stated workplace purpose requires.

Privacy does not disappear at work

The Office of the Privacy Commissioner of Canada states that employees retain privacy interests on employer premises and equipment. Employee information can include pay and benefits records, attendance, personnel files, video, audio, browsing, email and keystroke data.

The applicable law depends on the organization. PIPEDA covers employee information in federal works, undertakings and businesses, while federal institutions fall under the Privacy Act and several provinces have their own private-sector regimes.

Monitoring and proportionality

The federal guidance says monitoring should serve a specific, targeted and appropriate purpose. It should collect only what is necessary, use the least intrusive effective method, include retention limits and safeguards, and be explained to employees unless exceptional circumstances apply.

The regulator’s test weighs sensitivity, legitimate need, effectiveness, less invasive alternatives and whether the privacy loss is proportionate to the benefit.

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