Federal (Canada)Personal Information Protection and Electronic Documents ActSettled

Settled case summary #4 — A federally regulated transportation company

Organization: A federally regulated transportation companyComplainant: Several employees
Plain-language brief

Several employees of a federally regulated transportation company complained that a list of employees receiving severance packages, including names, identification and seniority numbers, and Social Insurance Numbers (SINs), was disclosed to their union without their knowledge or consent. The company admitted that the SINs were included on an electronic spreadsheet provided to the union, though in a hidden column. The employer did not obtain employee consent for this disclosure. During the investigation, the company changed its severance application process to no longer require SINs. The company also agreed to amend its application form to include a consent statement for the release of personal information to the union. The complaint was settled during the investigation.

Key issues
  1. 1Whether the disclosure of employee names, identification numbers, seniority numbers, and Social Insurance Numbers to a union without consent contravened PIPEDA
Outcome breakdownFavours: Applicant / complainant
  • Disclosure of SINs: Disclosure without consent acknowledged
  • Severance process change: SINs no longer required
  • Consent form amendment: Consent statement added to form
  • Complaint resolution: Complaint settled during investigation
Outcome

Complaint settled

Reasoning

The complaint was settled because the company admitted its mistake, took corrective actions by no longer requiring SINs for severance applications, and agreed to obtain consent for future disclosures of personal information to the union.

AI-generated summary for reference only. Always verify against the official decision ↗
Decision notes
Recommended action / remedy

The company agreed to amend its severance application form to include a statement asking employees to consent to the release of their personal information to the union, and ceased requiring SINs for severance applications.

This summary is informational only and not legal advice.

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