Personal Information Protection Act - Office of the Information and ...

A G u i d e f o r B u s i n e s s e s a n d O r g a n i z a t i o n s o n t h e P e r s o n a l I n f o r m a t i o n P r o t e c t i o n A c t
6 Follow special rules for employee information
Bottom line: An organization may collect, use and disclose employee information without
consent for reasonable purposes related to recruiting, managing or terminating personnel.
An employee is someone employed by the organization or someone who performs a service
for the organization and includes:
▲ an apprentice
▲ a volunteer
▲ a participant
▲ a work experience or co-op student
▲ an individual (not a company) acting as a contractor to perform a service for an
organization or an individual (not a company) acting as an agent for an organization
Personal employee information means personal information that is reasonably needed to
establish, manage or end a work or volunteer work relationship. It does not include personal
information that is not related to the relationship.
Managing personnel means the carrying out of that part of human resource management relating
to the duties and responsibilities of employees. It can also refer to administering personnel, and
includes activities such as payroll and succession planning.
An organization may collect (section 15) or use (section 18) personal employee information
without consent when:
▲ the individual is an employee; or
▲ the purpose for collecting or using the information is to recruit a potential employee.
An organization may disclose (section 21) personal employee information without consent when:
▲ the individual is an employee or was an employee; or
▲ the purpose for disclosing the information is to recruit a potential employee.
The collection, use and disclosure must be reasonable for the purpose, and the personal
information must be limited to the work or volunteer work relationship. Before collecting the
information about a current employee, the organization must advise the employee that it will
collect the information and the purposes for the collection. If the information is about a potential
employee (a job candidate), notification is not required.
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Service Alberta and the Office of the Information and Privacy Commissioner