Breaching Employees’ Privacy Expectations
Are you breaching your employees’ privacy expectations when you use their personal contact, health information or emergency contact information when you conduct employee wellness checks at home? We have been taught under PIPEDA (recall the Personal Information Protection and Electronic Documents Act) that you must generally obtain an individual's consent when you collect, use or disclose an employee’s personal information – and such personal information must only be used by an employer regulated by PIPEDA or who adopted a policy that follows PIPEDA’s principles for the purposes for which it was collected. If you are going to use it for another purpose, you must obtain consent again.