1. Policy

Collecting, using and disclosing personal information in accordance with privacy legislation is part of the Agency’s standard practice and the Agency ensures safeguards are in place to protect the security and integrity of the personal information under the Agency’s control.

2. Definitions

Personal Employee Information: defined as an identifiable individual, but does not include business contact information when that information is being used for the purposes of contacting an individual in relation to the individual’s business responsibilities.

3. Procedure

3.1. Collection of Personal Employee Information: The Agency collects personal information from employees for the purposes of establishing, managing or terminating the employment relationship, or managing the post-employment relationship. The types of personal information collected may include, but is not limited to, the following types of information:

contact information and other related information such as name, address, phone number and personal e-mail address;
social insurance number and bank account information;
demographic information such as date of birth, gender and marital status;
financial and tax information
criminal record checks
education and training information
employment information such as employment history, reference information, date of hire, employment status, pay history, tax withholding information, performance reviews, disciplinary records, driver’s abstracts and date of termination; and
benefit program participation and coverage information such as benefit elections, beneficiary and dependent information, claims information, health plan information, accrued benefits and retirement date;
medical information and information about disabilities;
drug and alcohol testing results; and
WCB information including claim status, benefits payment information, medical and testing information and retraining information

3.2. Use of Personal Employee Information: In administering the employment relationship, the Agency will access and use Personal Employee Information to do such things as provide benefits, pay wages and generally manage the workplace and worksites. Specific purposes may include, but are not limited to:

determining eligibility for initial employment, including the verification of references and qualifications
facilitating professional development and training
managing site access systems
performance evaluation and management
managing internal computer and information systems
providing benefits
administering wages and allowance
conducting, managing and responding to workplace investigations, including safety investigations
managing WCB claims
managing response to public health orders
managing sick leave, short term and/or long term disability programs
managing alternate work arrangements (hybrid work)
managing accommodations and/or travel arrangements
developing return to work agreements and modified work programs
overseeing implementation and enforcement of workplace policies, including drug and alcohol testing and other safety policies
managing and addressing grievances, civil claims and insurance matters
handling emergency situations
any purpose required by law (for example, managing Occupational Health and Safety requirements)

The Agency may also use it for managing the post-employment relationship, including the provision of references.
The Agency will advise employees of any new purposes for which collection, use and/or disclosure of Personal Employee Information may occur.

3.3. Disclosure of Personal Employee Information: Personal Employee Information may be shared between various individuals within the organization when required, and/or disclosed to third parties, for the purposes outlined above. When Personal Employee Information is shared or disclosed for the purpose of establishing, managing or terminating the employment relationship, the minimum amount of information reasonably necessary for the purpose is shared or disclosed and only when reasonably required.

As part of the Agency’s processes, Personal Employee Information may be disclosed to the following third parties:

the Agency’s benefit providers and brokers;
the Agency’s professional advisors
the Agency’s auto & liability insurance providers if the employee is assigned a company vehicle or receiving a vehicle allowance ( and to the Agency’s finance companies in the case of company provided leased vehicles);
third parties contracted to assist in administering the employment relationship such as human resource/payroll systems consultants, immigration consultants, etc.; project owners for contract audit purposes and for the purpose of administering site access and safety related procedures;
any third parties to whom the Agency is required or permitted by law to disclose personal information such as, but not limited to, Employment Insurance, Workers Compensation Board, Employment Standards Branch, Canada Revenue Agency, Labour Relations Board and Alberta Human Rights Commission, etc.

3.4. Consent

3.4.1 As the majority of the personal information collected, used and disclosed by the Agency is reasonably necessary to establish and maintain an employment relationship or as part of the required audit process under the Agency’s service provision agreement, employee consent to this collection, use and disclosure is a condition of employment. However, situations may arise when a specific collection, disclosure or use requires employee’s explicit consent. When those situations arise, the employee will be provided with information about the purposes for the collection, disclosure or use of personal information and consent will be requested.

3.4.2 It is important to keep Personal Employee Information as up to date as possible. Employees must notify Human Resource department as soon as possible of any changes in personal information such as marital status, contact information, dependent/beneficiary information, etc.

3.4.3 Employees may access their personal information by making a request to the Human Resource department.

3.5. Access and Storage

3.5.1. Personal Employee Information is safeguarded through both physical and technological safeguards to prevent unauthorized access, use and disclosure. Particularly sensitive information such as medical information is stored separately and is only accessed by those with a need to do so.

3.5.2. Personal Employee Information will be retained for as long as it is reasonably required for the purpose for which it was collected or as dictated by business need. After that, it will be destroyed.

3.5.3. Employees with access to Personal Employee Information are required to keep all personal information confidential except when use or disclosure is required for the performance of their duties and then, any use or disclosure must be in accordance with this Policy. Documents containing Personal Employee Information must be secure and should generally not be removed from the workplace. Similarly, access to files containing Personal Employee Information must be password protected. Personal Employee Information must not be disclosed outside of the workplace for purposes that are not related to the purposes for which the information was created or collected.

3.6 Employee obligation

In order to comply with the requirements of privacy legislation, the Agency must rely on employees to follow this Policy and the law with respect to the collection, use and disclosure of personal information. When acting on the Agency’s behalf, employees are not permitted to collect, use or disclose the personal information of other employees for any purposes other than those provided for in this Policy or as required by law.

Employees in contravention of this Policy may be disciplined, up to and including dismissal.

CSS Policy and Procedure Manual – Document Details
Date of Last Review	04-13-2023		Date of Last Revision	04-12-2023	Revision #:		0
Owner		CAO		Original CEO Approval Date		04-13-2023
Related Policies/Procedures/SOPs		Data Security S6-04