Canadian HR Reporter

www.hrreporter.com 13 Prominent role for HR Human resources should have a prominent role in managing privacy, and confidentiality must be assumed, says Lindner. "HR can take the lead in helping to prepare these policies but also providing people managers the tools to implement those policies and to put in place the processes and procedures that will help them because performance management, for example, is going to look very different in this new environment," she says. "We need to communicate more with employees about our expectations about privacy because employees who have privacy concerns, for example, should also know who they can turn to with those concerns. Whether their concerns are privacy related or whether they're related to accommodation or child-care issues, whether they're looking for a different kind of working arrangement, like a flex-time arrangement, HR needs to be a part of those conversations." And HR should take this opportunity to focus on a privacy and cybersafe culture and developing that, too, says Berger. says Rob Shavell, co-founder of online privacy company Abine.com in Boston. "What we've seen some HR depart- ments do is come to us to say, 'Hey, can we give our employees this DeleteMe service that removes that information from a lot of places that you can find it online, their personal information?' At the same time, we roll out a program to make sure we're tracking and managing the data about [their] newly remote workforce." Before installing monitoring tools, employers should also embark upon a confidentiality checklist, says Abbott. "It's important for employers to look at what they were already doing when employees were in the workplace and what they've identified for employees as the levels of monitoring that they already have in place, and then thinking about what they want to implement; then going through the privacy analysis for whatever it is they think they need. Employers need to be mindful about whether that information is necessary and what they're going to do with it once they collect it." "There's lots of ways they can do that, from educational modules [or] they can be doing sessions about their privacy policy if they're updating things as a result of new technologies or new modes of work. It's a good opportunity for them to engage employees about that and the best practices they'd like them to have." Storing data In addition to establishing policies behind monitoring, employers need to be aware of some of the rules around collection and storage of data, says Abbott, as they vary by region. "In Ontario, there are no specific rules from a privacy perspective in the private sector for provincially regulated employees, so it really is going to come down to common law principles of privacy, and you definitely don't want to be retaining sensitive private information for any longer than is necessary for whatever purpose you've identified," she says. "A lot of employers have already considered a lot of these issues in the "Employers need to be mindful about whether that information is necessary and what they're going to do with it once they collect it." Anna Abbott, Blake Cassels & Graydon context of working in the office, so things haven't really changed in the context of working from home in terms of what you monitor and what you collect. You should be following your basic record- retention policies that most employers already have in place with respect to private information." CHRR

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