While intentional electronic monitoring is becoming more common, especially with more employees working remotely, many businesses may already be tracking employee activity without realizing it. For example, if you use workplace cameras or a timecard system, you are already engaging in electronic monitoring.
What is Electronic Monitoring?
Electronic monitoring refers to the tracking of employees using electronic means during work hours. This can include online sign-ins, location tracking on work vehicles, or workplace surveillance cameras.
Common reasons employers use electronic monitoring include:
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Security and loss prevention
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Productivity and performance management
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Payroll accuracy and time tracking
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Location tracking for work vehicles or mobile employees
Common electronic monitoring tools include:
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Computer software (keystroke tracking, website monitoring)
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Surveillance cameras
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Employee email activity monitoring
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Commercial vehicle trackers (location, mileage, and fuel consumption)
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Phone apps and trackers on work-provided devices
While electronic monitoring can serve legitimate business purposes, privacy and data security must be carefully considered. For example, if employees are required to install an app on their personal phones, they may have valid concerns. Does the app access personal data? Could it track medical or banking information?
Without clear communication about why monitoring is necessary and how data will be used, employers risk losing employee trust. Additionally, some employees may simply be uncomfortable using personal devices for work purposes.
What are the privacy issues you may encounter?
The Personal Information Protection and Electronic Documents Act (PIPEDA) governs personal privacy for most businesses, while some jurisdictions have their own privacy legislation.
When implementing electronic monitoring, employers should consider the following questions:
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What information are you tracking? And why?
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Where is the information being secured?
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For how long are you keeping this information?
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What is the best way to dispose of the information?
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Should you have a policy?
You can use the PIPEDA Self-Assessment tool to help develop a Privacy Policy that makes sense for your business.
Am I required to have a separate Electronic Monitoring Policy?
Currently, the only province that requires certain businesses to have an Electronic Monitoring policy is Ontario. However, it is best practice to have a policy in place for your business to avoid any fines or issues in the future.
When creating your Electronic Monitoring Policy, include:
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A description of the ways employees are electronically monitored during work hours: surveillance cameras, key logging software, sensor/scanner tracking at checkouts, key cards, etc.
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The reason(s) for electronic monitoring
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When and how the information will be used
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Privacy and security of data
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Where and when electronic monitoring takes place
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An indication of whether the same policy applies to all employees
Need further assistance?
You have questions or need personalized support? Our Business Advisors are here to help:
1-833-568-2342 | hrnow@cfib.ca
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