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3603-2022 Electronic Monitoring Policy

3603-2022 Electronic Monitoring Policy


Passed by Council December 12, 2022

BY-LAW NO. 3603-2022

WHEREAS the Corporation of the Township of Augusta deems it necessary to comply
with Bill 88: Working for Workers Act that require employers with over 25 employees to
have an electronic monitoring policy in place.

AND WHEREAS the powers of a municipal corporation are to be exercised by its

AND WHEREAS the Council or the Corporation of the Township of Augusta deems it
expedient to adopt an Electronic Monitoring policy;

NOW THEREFORE the Council of the Corporation of the Township of Augusta enacts
as follows:

1. That the Electronic Monitoring Policy attached as, Schedule “A” attached hereto
shall form part of this By-Law.

2. All other By-Laws inconsistent herewith are hereby repealed.

3. This By-Law shall be in force and effect on the date of its passage.

Read a first and second time this 12th day of December 2022.

Read a third time and passed this 12th day of December 2022.

Signed by Mayor Jeff Shaver and Clerk Annette Simonian


Policy: Electronic Monitoring Policy
Date Issued: December 12, 2022
Coverage: Full-time, Part-time and Seasonal Staff and contracted service providers
Revised: N/A

1. Preamble

Augusta Township is committed to maintaining a transparent and fair workplace
which balances the safety, security and risk management benefits of electronic
monitoring with an individuals expectation of privacy in the workplace.

2. Purpose

The purpose of this policy is to provide transparency regarding how and in what
circumstances the use of electronic monitoring of employees may occur and be
used. In addition. ensure computer/network access is appropriate to their role and
their employment status and compliance with the applicable legislation.

3. Application

This policy applies to all Augusta employees, as defined in the Collective
agreement, Employment and Personnel Policy and by the Ontario Employment
Standards Act, regardless of their place of work and contracted service providers
who access Augusta’s IT network.

4. Definitions

Device: a piece of portable electronic equipment that can connect to the Internet,
such as a smartphone, tablet, laptop, computer or GPS (Global Positioning

Electronic Monitoring: using all forms of employee and asset monitoring that is
done electronically such as technological, electronic, or digital means to track,
observe, or monitor actions.

Service Provider: an external firm, agency or vendor hired or retained by
Augusta Township.

User: an individual who accesses the network or uses an Augusta Township
owned device.

Personal Information: any factual or subjective information about an identifiable

5. General Provisions:

Electronic monitoring may be used to collect information to protect the Township’s
legal and business interests as well as to ensure employee compliance with
Township policies.

The information obtained through electronic monitoring may be used in
consideration of legal action and disciplinary decisions in accordance with the
Discipline Policy and respective Collective Agreement, as applicable.

Electronic monitoring data shall only be provided to authorized parties and third party
requests for access to electronic monitoring data is directed to the Clerk as a
MFIPPA request.

Staff shall read, understand and adhere to this policy.

Council Members shall be made aware of the policy and electronic monitoring of
personal devices when accessing the Township’s wireless or network.

6. Electronic Monitoring Practices:

a) Computer Monitoring — Computer monitoring may collect user activity data on
Township owned computers, networks, and other IT infrastructure. This data
may include websites accessed, social media, files downloaded, network traffic,
logons to corporate systems, peripheral device usage and information about the
device. Computer Monitoring may be used to ensure appropriate work
productivity and usage and may include inappropriate usage during off hours.

b) Global Positioning Systems (GPS) in Township vehicles — may be used to
monitor location, route, and appropriate operation of vehicles to support effective
service delivery and may be used to investigate incidents, accidents or

c) Cellular and desktop phones issued by the Township — Cellular and landline
phones may be monitored to capture call source, destination, duration and
amount of cellular data used to ensure appropriate use.

d) Emails and websites utilizing Township issued computers — emails sent through
the Township network or user accounts may be subject to monitoring to ensure
assets are being used for legitimate business purposes, to retrieve information
following suspect computer failures or to investigate alleged acts of wrongdoing.

e) Security cameras —may be utilized at various Township properties to deter theft,
vandalism and other forms of misconduct thereby keeping employees, patrons
and Township owned assets secure.

f) Building Access Monitoring — to monitor building access. The identity, date,
time and location of access are captured by and resides with a third-party
security company. This information is collected and may be used for
investigation of incidents relating to theft, vandalism, other forms of misconduct
or the general safety and security of employees working at Township owned

7. Personal Use of Township Assets

Employees may occasionally wish to use Township systems for personal tasks
during their break periods. This may include non-work web browsing, making
personal phone calls, or sending emails from personal accounts. Occasional
personal use is permitted: employees should be aware that such use is subject to
the same electronic monitoring as described within this policy when the employee
is logged into their Township accounts or networks.

8. Use of Personal equipment

Where employees are permitted to use personal electronic equipment for work
purposes, only activities accessed through the Township’s IT network will be
monitored and captured as described. For example, data collection will occur
when personal electronic equipment is used on Township-owned wireless
networks, virtual private networks (‘VPN”). and any other interaction from
personal electronic equipment with Township-owned IT systems.

9. Posting, Notice and Retention

a. Augusta Township shall provide notice of this Policy to employees of the
Township within 30 calendar days of implementation. Should any changes
be made to the Policy after its implementation. Augusta Township shall
provide notice to employees of the revision within 30 days of the changes
being made.

b. Augusta Township shall advise all new employees of this Policy upon
onboarding and within 30 calendar days of the employee commencing
employment with Augusta Township.

c. A copy of every written policy on electronic monitoring that was required by
the ESA shall be retained for three years after the policy is no longer in

d. All information collected through electronic monitoring will be securely
stored and protected. If any personal information is collected, its use and
disclosure will be limited to achieve the stated purpose of its collection. The
Township will adhere to all privacy and confidentiality legislation that
applies to the collection, use and disclosure of personal information
obtained by electronic monitoring.

10. Reporting Concerns

Questions, concerns or suggestions may be directed to the CAO.


The policy will be reviewed on a regular basis using the four-part
questionnaire that will evaluate the following items:

• Did the legislation change;
• Was the goal of the standard met;
• Were the requirements of the standard met; and
• Were there problems or concerns meeting the standard?

Applicable training needs will also be reviewed and provided as needed to
keep the policy current.

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