HomeMy WebLinkAboutPR 713 HR - Electronic Monitoring Disclosure OTTAWA-CARLETON
DISTRICT SCHOOL BOARD
PROCEDURE PR.713.HR
TITLE: ELECTRONIC MONITORING DISCLOSURE
Date Authorized: 11 October 2022
Last Revised:
Last Reviewed: 11 October 2022
COMMITMENT TO INDIGENOUS, EQUITY, AND HUMAN RIGHTS
The District recognizes its responsibility to ensure that this procedure and the associated work
promotes and protects Indigenous, equity, and human rights and to seek to address and eliminate
racism and structural and systemic barriers for students, staff, and community.
1.0 RATIONALE
To notify Employees of the electronic monitoring systems in place at the Ottawa-Carleton
District School Board (OCDSB), in accordance with the provisions of the Digital Platform
Workers'Rights Act, 2022 and changes to the Employment Standards Act, 2000 (ESA).
2.0 DEFINITIONS
Please refer to Appendix A for a full list of definitions used in this procedure.
3.0 RESPONSIBILITY
The People, Culture and Leadership department is responsible to notify employees of this
procedure and to ensure the OCDSB is compliant with the Employment Standards Act, 2000
by communicating processes around electronic monitoring systems.
4.0 PROCEDURE
Application and Scope
4.1 This procedure applies to all Employees of the OCDSB as defined in Appendix A, when
using information technology, remotely, at a school or office, on school buses, during
field trips, or at school-sponsored events.
4.2 The manner in which employees may be subject to electronic monitoring is generally set
out in other policies and procedures, and this new procedure is not meant to override
those.
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4.3 This procedure does not establish a right for Employees not to be electronically
monitored, create any new privacy rights for employees, or affect or limit the District's
ability to use the information obtained through the electronic monitoring of its
employees.
4.4 This procedure must always be consistent with the Ontario Human Rights Code, Board
Policy P.147.GOV Human Rights, and the Municipal Freedom of Information and
Protection of Privacy Act (MFIPPA).
Electronic Monitoring Rationale
4.5 The District may engage in electronic monitoring for purposes including, but not limited
to, the following:
a) monitoring the individual uses of technology in the learning environment in
compliance with Procedure PR.622 IT Appropriate Use of Information
Technology (Students) and Policy P.100.IT Appropriate Use of Information
Technology;
b) ensuring the safety and security of its staff and students, as per Procedure
PR.615.FAC Video Surveillance;
c) providing for safeguards against vandalism, theft, damage, and loss of property,
as per Procedure PR.615.FAC Video Surveillance;
d) protecting all OCDSB buildings from unauthorized access, as per Procedure PR
524 SCO - Access To School & Board Premises;
e) ensuring the security of information technology in compliance with Procedure
PR.564.IT Information Technology Security; and
f) monitoring the use of electronic communications in compliance with Procedure
PR.672.IT Electronic Communications Systems.
Electronic Monitoring Tools
4.6 The following departments are responsible for the regular monitoring of electronic
systems:
a) Facilities Department:
(i) monitors and control access to all buildings through security codes,
access cards and cameras on exterior doors;
(ii) may use video surveillance in some facilities through cameras and
recording systems as per Procedure PR.615.FAC Video Surveillance; and
(iii) may monitor District-owned vehicles using GPS, in accordance with
applicable guidelines.
b) Business and Learning Technologies Department:
(i) uses enterprise phone systems to monitor phone logs in order to evaluate
call volume and quality, and voicemail storage;
(ii) uses endpoint security tools, management consoles, and mobile device
management to monitor, protect from loss, and enforce security settings
on District desktops, laptops, Chromebooks, and tablets/mobile phones,
respectively;
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(iii) uses authentication servers to monitor staff login to services in order to
protect against unauthorized access;
(iv) uses packet analysis to monitor all network traffic to protect the integrity,
security and availability of the network;
(v) uses firewalls on all internet traffic to protect from harmful and
inappropriate content; and
(vi) filters emails to prevent the transmission of harmful data over the e-mail
system.
Using the Information
4.7 The District reserves the right to access the data collected via the regular monitoring of
its information technology or personal devices using Board credentials and/or networks
in situations including, but not limited to, the following:
a) to comply with legislative disclosure or access requirements under the Municipal
Freedom of Information and Protection of Privacy Act (MFIPPA), in accordance
with P 128 GOV - Privacy-MFIPPA;
b) to comply with legislative disclosure or access requirements under the Personal
Health Information Protection Act (PHIPA);
c) to assist with the investigation of Privacy Breaches, in accordance with
Procedure PR 669 GOV - Privacy Breach;
d) to run a regular or special maintenance of the District electronic information
systems;
e) where an employee is not available and there is an urgent/immediate need to
access information in the employee's account;
f) to comply with obligations to disclose information in the course of a legal matter;
and/or
g) in the course of workplace investigations relating to allegations of employee
misconduct or inappropriate behaviour.
4.8 Where there is evidence that information accessed demonstrates that the employee is
not in compliance with Board policies and/or procedures, regulatory requirements of
their professional college where appropriate, or other regulations or criminal matters,
the employee may be subject to disciplinary actions up to, and including, termination of
employment.
Communication
4.9 The People, Culture and Leadership department will ensure employees receive a copy
of this procedure within 30 calendar days of :
a) the date that the OCDSB is required to have the procedure in place;
b) the date an individual becomes an employee of the OCDSB; and
c) any approved revisions.
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5.0 APPENDICES
Appendix A: Procedure Definitions
Appendix B: Electronic Monitoring Tools
6.0 REFERENCE DOCUMENTS
The Employment Standards Act, 2000
The Municipal Freedom of Information and Protection of Privacy Act,1990
The Personal Health Information Protection Act (PHIPA)
OCDSB Policy P.047.FAC Video Surveillance
OCDSB Policy P.074.IT Information Technology Security
OCDSB Policy P.100.IT Appropriate Use of Information Technology
OCDSB Procedure PR.564.IT Information Technology Security
OCDSB Procedure PR.615.FAC Video Surveillance
OCDSB Procedure PR.622.IT Appropriate Use of Information Technology (Students)
OCDSB Procedure PR.672.IT Electronic Communications Systems
OCDSB Procedure PR.701.HR Working from Home (Remote Work
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OTTAWA-CARLETON
DISTRICT SCHOOL BOARD
APPENDIX A: PROCEDURE DEFINITIONS
In this procedure,
Board Property means all school buildings, grounds, and facilities under the jurisdiction of the
Board. It is also applicable, for example, on school buses, during field trips, or at school-
sponsored events.
District means Ottawa-Carleton District School Board.
Electronic Monitoring means all forms of employee monitoring that is done electronically.
Some examples include tracking the use of computers, emails, websites, cell phones, video
surveillance, GPS systems, key card access, keystroke trackers and other electronic devices,
and is applicable in the workplace, in the field or at home.
Employee means all persons who are currently engaged in active employment with the
District, regardless of employment status (e.g., full-time, part-time, regular, term, contract,
occasional, casual).
Information Technology (IT) means a computer, phone, tablet, printer, photocopier, hard
drive or other device, software, or network owned or operated by the District which stores,
transmits, or provides access to information, including personal or sensitive information.
Supervisor means a person who is responsible for the work of another employee including,
but not limited to, those holding the positions of supervisory officer, principal, vice-principal,
manager, and supervisor.
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APPENDIX B: ELECTRONIC MONITORING TOOLS
Tool What is monitored? How Purpose
Web filtering All internet traffic Firewalls Protect from harmful and
inappropriate content
E-Mail filtering All e-mail traffic Safety and Security Prevent the transmission of
confidential data over insecure e-mail
Network Monitoring All network traffic Packet analysis Protect the integrity and availability of
the network
Account Staff login to services Authentication Server Protect against unauthorized access
Authentication
Device Management Installed on all Board Mobile Device Protect against loss/theft, and
(iPad/iPhone) iPads/iPhones Management enforce security settings
Device Management Installed on all Board Management Protect against loss/theft, and
(Chromebook) Chromebooks Console enforce security settings
Device Management Installed on one-to- Endpoint Security Protect against loss/theft, and
(laptop) one/ administrative Tools enforce security settings
laptops
Phone logs Some facilities Phone system Call quality (e.g. bandwidth, latency,
jitter, packet loss, compression), call
volume and voicemail storage
monitoring
Video surveillance Some facilities Video surveillance Safety, theft, illegal activity,
cameras and behavioural/ incident monitoring and
recording systems review.
Access Cards All facilities Through Door Control and monitor access to
Reader buildings.
Electronic sign-in Some facilities Electronic data Maintaining a Visitor's Book per the
collection Education Act and where necessary
for health related purposes.
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