HomeMy WebLinkAbout2011-4120.Falco.13-07-03 DecisionCrown Employees
Grievance Settlement
Board
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180 Dundas St. West
Toronto, Ontario M5G 1Z8
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Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB# 2011-4120
OPSEU# 2012-0585-0046
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Falco) Union
- and -
The Crown in Right of Ontario
(Ministry of Labour) Employer
BEFORE Reva Devins Vice-Chair
FOR THE UNION Ed Holmes
Ryder Wright Blair & Holmes LLP
Counsel
FOR THE EMPLOYER Susan Munn
Ministry of Government Services
Legal Services Branch
Counsel
HEARING August 16, September 25, November 29,
2012; February 6 and April 5, 2013
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Decision
[1] The Grievor, Patricia Falco, had over 25 years seniority with the Ministry of Labour when
her position was eliminated. She received a surplus notice and was ultimately advised that
there were no positions for which she was qualified. She grieved the Employer’s failure to
identify a more junior employee whom she can displace and alleges a violation of Article
20.4 of the Collective Agreement.
[2] On consent, and without prejudice to their right to proceed with other grievances regarding
other positions, the parties agreed to proceed with this grievance, which identifies the
position of Secretary to the Director of the Employment Practices Branch as the position for
which the Grievor seeks to invoke her displacement rights. The Employer maintained that
the Grievor was not working level qualified with respect to several core components of the
job. The Incumbent was notified of these proceedings and elected to attend as an observer.
The parties further agreed to proceed under Article 22.16 and that this decision be issued
without prejudice or precedent.
Facts
[3] The Grievor commenced employment with the Ontario Public Service in 1986 and worked
continuously for the Ministry of Labour, progressing through a number of clerical and
secretarial positions. From December 1988 to May 1997 she worked as the Secretary to the
Director, Office of Mediation, and filled in for six months as the Administrative Assistant
for the Office of the Assistant Deputy Minister of Labour, AMAPCEO Level 13.
[4] In May 1997, her position as Secretary to the Director was declared surplus and she was
assigned to a position of Audit Assessment Clerk, OAG 9, in the Employment Standards
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Branch. Between 1997 and 2011 she also worked as an Employment Standards Officer 2,
an Intake Officer and in further assignments as an Audit Assessment Clerk.
[5] The Ministry declared her position surplus on March 14, 2011, with a lay-off date of
September 14, 2011. The surplus notice was put on hiatus during a period of medical
absence and November 30, 2011 was subsequently identified as the Grievor’s final lay-off
date.
[6] The Grievor was contacted after she received her surplus notice by Lissa Jose, an Employee
Mobility Co-ordinator (EMC) and advised to prepare a detailed description of all of the jobs
that she has held. The Grievor recalls receiving an Employee Portfolio Template but did
not remember receiving a copy of the guide that was intended to accompany it. The
Grievor understood that she could contact Ms. Jose if she had any questions, but went
ahead and filled out the Portfolio on her own, without asking any further questions or
requesting further information.
[7] In her Portfolio, the Grievor indicated that she had advanced skills in the area of
Administration Support, including Reception, Data Entry, Filing, Scheduling, Mail
Services, Purchasing Procedures and Keyboarding. S he further noted advanced or
functional skills in Computer Software, with advanced skills in Word Processing,
Spreadsheets, Databases, most aspects of Graphics, and in Communication Skills. She
acknowledged somewhat more limited skills in the area of Financial Processes,
Supervision/Group Leadership and Working with Information and People, Records
Management, Policy Analysis and Purchasing Administration. The only areas in which she
said that she had no skills were Information Technology, Operational Maintenance and in
the Scientific and Technical fields. Ms. Falco knew that she was required to support her
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Portfolio Skills Assessment with information in her Employee Portfolio Resume and she
attached a detailed summary of the key duties she performed in her various job
assignments.
[8] The Grievor provided a two-page summary of the duties she performed as the Secretary to
the Director, Office of Mediation. She prepared this document from memory, without the
aid of the relevant job description, but intended it to cover all of her primary
responsibilities. The duties she listed included typing a variety of documents, scheduling,
making travel arrangements, maintaining an efficient filing system, providing monthly
statistical reports, answering the phone, managing incoming and outgoing correspondence
and providing general secretarial duties.
[9] The Grievor also provided details of her other experience in the Ministry, including her
work with the Employment Standards Branch. In her various assignments as an Audit
Assessment Clerk, she was responsible for assessing multiple files referred to her by an
Employment Standards Officer to determine if there were outstanding wages, vacation pay,
overtime or termination pay. She would analyse the file, prepare a detailed report and
advise the Officer of the results of her analysis. More recently she was responsible for
preparing Writs, requisitioning cheques, corresponding with claimants regarding the status
of their file and preparing files for collection agencies. Performance of these functions
required proficiency in ESSIS, a computer based tracking system that needed to be
maintained and updated on a daily basis.
[10] The Grievor also has experience as an Intake Officer and Resident Auditor in the
Employment Standards Branch. As Auditor, she met with employers and reviewed their
records to determine whether employees were being paid in accordance with the governing
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legislation. She would answer any questions asked of her by those whom she was auditing,
prepare the necessary documentation and follow up with respect to the outcome of the audit
results, as required.
[11] In her vive voce evidence, the Grievor provided somewhat greater detail of her
responsibilities. She testified that when she served as the Secretary to the Director, she
typed up Briefing Notes and Executive Letters. She would not draft them herself, but did
edit them for spelling and grammar. She also drafted lower level correspondence for the
Director’s signature as well as reports for the Director and for the Deputy Minister when
she acted as his Administrative Assistant. She prepared speeches and memos for the
Director and had some experience with the preparation of spreadsheets, graphics and
presentation software. The Grievor acknowledged that she might not have detailed all of
this experience in her Employee Portfolio Resume, indicating she might have performed
some of these tasks as part of a temporary assignment or that she simply might have missed
some of the many things that she did over her 26 years in the OPS.
[12] The Grievor was also advised during the redeployment process that HR had checked her
corporate file and could not find results for a typing test. Ms. Jose asked her to take a new
test so that she could be matched to vacancies with a typing to standard requirement. The
Grievor refused. She insisted that she had passed the Dicta and Typing tests to government
standards when she joined the OPS. She did not receive certificates and she considered it to
be the Ministry’s responsibility to maintain a record of her results. The Grievor testified
Ms. Jose did not refer to a specific position that required her to meet a typing standard; she
understood that the request was with respect to the job search generally. In the Grievor’s
opinion, she had held the position of Secretary to the Director for several years and had
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therefore adequately demonstrated her typing skills. She felt that there was no need to
retake the test as she had already demonstrated her qualifications in this regard.
[13] Dali Aung, Program Consultant, Redeployment Services Offices (“RSO”) testified to the
normal practice used by RSO staff when they review potential redeployment opportunities
for surplus employees. I n the normal course, the employee would be asked to complete an
Employee Portfolio setting out their previous experience, skills and knowledge. An
Employee Mobility Coordinator would explain the surplus and redeployment entitlements
to employees and provide template documents. The EMC would not verify or authenticate
the contents of the Portfolio, but merely submit it to the RSO on behalf of the surplus
employee.
[14] Once they receive the Portfolio, RSO staff would determine whether there are any
vacancies for which the displaced employee is qualified. If the surplus employee does not
qualify for a direct assignment to a vacant position, RSO staff determine if the surplus
employee is entitled to bump into an existing position by identifying positions within the
Ministry that are held by more junior employees working at or below the surplus
employee’s classification. The Employment Portfolio of the surplus employee is compared
with the Skill and Knowledge section of the position held by the junior employee, and, if
they appear to be a match for the position, staff performs a more detailed analysis and
assess the demonstrated qualifications for the individual duties. All references in the
Portfolio that could be relevant or equivalent to the skills, knowledge and experience
required for each job duty are noted, as are any gaps in qualifications.
[15] Ms. Aung did not assess the Grievor’s qualifications for the position at issue. Two other
programme staff, who were not called as witnesses, analysed Grievor’s qualification for the
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Secretary to the Director of the Employment Practices Branch. Ms. Aung participated in the
displacement search for the Grievor with respect to other positions but only reviewed the
written evaluation regarding this position when she prepared for arbitration. Ms. Aung was
thus familiar with the decision that the Grievor was not working level qualified for the
position but could only testify to her understanding of the reasons for that decision.
[16] The Position Description Report (PDR) for the Secretary to the Director, MOL,
Employment Practices Branch, effective from February 9, 2000, lists the responsibilities,
requirements, knowledge and skills as follows:
3. Duties/Responsibilities
1. Preparing draft responses to queries, keyboarding executive letters, policy
proposals, confidential materials, papers, correspondence, briefing notes, reports, using
various software applications; setting up and maintaining hard copy correspondence files.
Generating correspondence from written drafts and dictation.
2. Opening, logging and perusing mail, assigning and tracking correspondence
requiring a reply to the appropriate manager. Retaining and drafting correspondence in
priority order for own or director’s signature. Editing executive letters and replies prepared
by other sections, i.e. district offices.
3. Receiving and screening telephone calls and visitors, e.g. senior government
officials, senior executives from the private sector and media. Answering client inquiries,
conveying information, contacting branch and field staff to obtain additional information or
explanation. Providing factual information to queries by phone, Internet mail, faxes, regular
mail and walk-ins based on thorough knowledge of OPS, Ministry and regional operations,
functions, activities and personnel, referring to other internal and external sources as
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required; identifying references and contacting sources on subjects as requested by director;
and preparing findings in suitable format for review by requester.
4. Updating a computer based tracking system i.e. CMIS, hardcopy files for all
correspondence actioned or received. Provide training and updates for managers and
administrative staff on CMIS, house notes, briefing notes and common electronic files,
establishing due dates, ensuring quality service standards are met and conducting follow-
ups.
5. Researching and maintaining minutes for ministry and interministerial events,
providing background information and support and compiling information for meetings,
briefings, interministry and inter-government committees, speeches, and presentations.
Preparing statistical reports, creating spreadsheets and graphic presentations.
6. Coordinating and attending meetings and conferences, assembling background
information, contacting participants, rearranging schedules, preparing agenda and
generating minutes.
7. Organizing and maintaining director’s meeting schedule; making travel,
meeting and negotiating conference arrangements, including physical and logistical
requirements and preparing and distributing agendas; providing administrative support to
the Director including moveable assets, records management, purchasing office supplies,
maintaining attendance records.
4. Staffing and Licensing Requirements
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Job requires typing to government standards and full proficiency in word
processing, graphics, database, presentation and spreadsheet software applications.
5. Knowledge
Job requires knowledge of the Ministry’s, main offices and region’s role,
objectives, programs and activities including Employment Standards, Health and Safety,
Workers Compensation, Human Rights and Labour Relations legislation in order to:
provide guidance to managers on correspondence and respond to inquiries and to research
and compile information for meetings, briefings, speeches, by researching internet, intranet,
files, policies and precedents.
Job requires knowledge of secretarial functions and established internal office procedures
to provide support to Director. Job requires detailed knowledge of procedures relating to
file storage and retention, movable assets policies and purchasing policies to implement
these initiatives in the Director’s office and provide administrative and purchasing guidance
and support. Job requires knowledge of performance management process including setting
training and development plans in order to process and track these documents. Job requires
knowledge of office equipment such as photocopier and facsimile to copy material and
transmit information.
6. Skills
Job requires analytical skills to determine the nature of calls and to make
decisions concerning the permissibility or confidentiality of information and to research and
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assess information; written communication skills to edit and compose correspondence;
verbal and interpersonal skills to liase with a variety of contacts and to respond to the
public, media, and private sector. Job requires the ability to identify priorities, establish
timeframes and to co-ordinate resources.
[17] The Job Ad for the position at issue set out the responsibilities and qualifications as
follows:
Your responsibilities will include: preparing verbal and draft correspondence responses;
setting up/maintaining correspondence files; managing mail; editing executive letters;
receiving and directing telephone calls and visitors; updating computer based tracking
systems; researching, compiling information, and maintaining minutes for ministry and
inter-ministry events; preparing statistical reports, creating spreadsheets and graphic
presentations; coordinating travel arrangements; organizing and maintaining director’s
meeting schedule; assisting with special projects including healthy workplace and training
initiatives.
Qualifications: Demonstrated organizational skills to coordinate/schedule meetings, draft
responses, prioritize multiple tasks to meet deadlines, resolve conflicting priorities and
demands; Proficiency in the operation of a computer and software such as word processing,
spreadsheet, presentations and database management; Demonstrated knowledge of OPS
secretarial, administrative and internal office procedures including file storage management
and retention, moveable assets policies and purchasing policies; Familiarity of relevant
legislation/regulations such as the Employment Standards, Occupational Health and Safety,
Worker’s Compensation, Human Rights and Labour Relations; Proficient oral
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communication skills to respond courteously and tactfully. Demonstrated written
communication skills to compose correspondence, summaries, statistical reports and
contribute to office communications. Proven interpersonal skills to liaise and maintain
effective working relationships to obtain information and provide advice to management
and co-workers to resolve problems; Demonstrated analytical skills to detect errors in
expense claims and invoices, typed materials, resolve errors, collect background
information and make summaries for the Directors requirements.
[18] Ms. Aung testified that she understood that the RSO Programme Advisor who reviewed the
Grievor’s Portfolio determined that the Grievor was not working level qualified for the
position having regard to the following gaps in her qualifications:
[19] No demonstrated experience preparing draft executive letters, policy proposals, briefing
notes and correspondence from written drafts and dictation (Duty 1).
[20] No demonstrated experience editing executive letters (Duty 2).
[21] No demonstrated experience using CMIS, providing training on CMIS, house notes and
briefing notes (Duty 4).
[22] No demonstrated experience preparing graphic presentations (Duty 5).
[23] No demonstrated experience providing admin support such as moveable assets (Duty 7).
[24] In assessing displacement eligibility, the normal practice would be to consider the number
and size of the qualification gaps without any further contact with the surplus employee.
Staff would simply rely on the information set out by the surplus employee in her
Employee Portfolio. If there was only a minor gap in demonstrated qualifications, they
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might make further inquiries. In this case, Ms. Aung believed that if the Grievor’s only gap
in skills was with respect to moveable assets, then the Programme Advisor might have
exercised her discretion to contact the Grievor for further clarification of her previous
experience. However, since so many gaps were identified, she did not believe that there
was any further contact with the Grievor.
[25] In Ms. Aung’s view, it would not be physically possible to contact every surplus employee
with respect to every position for which they were considered. The RSO is not responsible
for the content of the Employee Portfolio and do not have the resources to ask about
qualifications that are not supported in the required documentation. Ms. Aung noted that
although the Grievor indicated in the Skill checklist component of her Portfolio that she
possessed a large number of skills, she did not provide any corroborating support for that
assertion in the detailed listing of the duties that she had previously performed. Ms. Aung
also testified that, for the purposes of displacement, an individual must have performed the
exact task in a previous position in order to be considered working level qualified to
perform the core components of the position.
[26] For example, Ms. Aung noted that the Grievor detailed experience preparing routine
correspondence, but did not list experience editing executive letters, or preparing executive
letters, briefing notes or policy proposals. Similarly, there was no reference to experience
with CMIS in the Grievor’s Portfolio. CMIS is an online correspondence management
system that is primarily used in executive offices to track correspondence, briefing notes
and confidential materials. There are also a number of similar databases, such as OCMS,
however the Grievor did not list familiarity with any electronic correspondence
maintenance system. Nor did she indicate that she had any experience or familiarity with
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presentation software, such as Power Point, or any experience maintaining moveable assets,
such as furniture or electronic equipment.
[27] On cross-examination Ms. Aung confirmed that she considered preparing draft executive
letters, policy proposals and briefing notes as a core component of the position. She then
acknowledged that the duties listed in the PDR only refer to keyboarding these documents
and that the Grievor did have experience keyboarding and editing executive letters in her
former position as Secretary to the Director. She also conceded that the Grievor had
experience with broad based, computer tracking systems, even if it was not focussed on
correspondence management.
[28] The Incumbent, Deanna Roy, held the position of Secretary to the Director for the
Employment Practises Branch for roughly 5 years, until September 2012, at which time, the
position was eliminated and she moved to a new position by direct assignment.
[29] As the Secretary to the Director, her main responsibility was to manage a large amount of
incoming documents and correspondence. A good deal of the correspondence was internal
to the Employment Practices Branch and she used the Online Correspondence Management
System (OCMS), which electronically routes correspondence to the relevant contact for
response, within the appropriate timeline. Some letters would require input from multiple
sources and the system would also record the appropriate party responsible for signing the
letter. Ms. Roy has never worked with CMIS, but believed that it was essentially an older
version of OCMS. She acknowledged, however, that she did not know how to use CMIS or
the manner in which it varied from OCMS, all she knew for sure was that it was an online
correspondence management system. She further testified that OCMS and ESSIS were both
online management systems, but that they perform different functions. OCMS was used
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exclusively for correspondence and ESSIS was used as a claims tracking process with
multiple functions. They can both be used to scan documents and extract information, but
ESSIS can also generate reports or letters, whereas OCMS cannot.
[30] As the Secretary to the Director, she also managed correspondence from the public, other
programmes in the Ministry of Labour and the Ontario Public Service. She was responsible
for printing out the correspondence and ensuring that it required a response from the
Branch. She would also determine if there was a specific claim associated with the author
of the letter, in which case it would be referred to the officer assigned to the file for
response. If the inquiry were of a general nature she would draft a preliminary response
that was then reviewed by the provincial co-ordinator. For more complex issues, the
correspondence would be referred to a specialist. The correspondence would then go to the
Director for review and be routed back to the correspondence unit, through OCMS, for
approval from the Minister, Deputy Minister or Assistant Deputy Minister, as appropriate.
[31] The Secretary to the Director’s other duties included general administrative functions such
as answering the phone, photocopying, logging and distributing documents, and taking any
further action, as required. She was responsible for ordering moveable assets, such as,
office furniture and equipment through an online ordering system, where she would select a
product, order it and track delivery, all on final approval of the Director. With respect to
briefing notes, a programme consultant dealt with the complex matters whereas Ms. Roy
would occasionally draft an update on a specific, straightforward issue for an existing
document, under the direction of the specialist. Ms. Roy would also prepare presentations
from time to time, on average about once per month. She would typically create a chart
using Excel and import it into a Power Point presentation to be used by the Director.
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[32] Ms. Roy estimated that well over half of her time was related to incoming and outgoing
correspondence. With respect to the other half of her time, scheduling occupied the most
time. She would also spend a fair amount of time answering the phone, photocopying and
performing regular secretarial duties; she did not spend a lot of time addressing moveable
assets, updating or revising briefing notes or preparing presentations.
Submissions
[33] The Union submits that the Employer is obliged to identify all employees with less
seniority than the Grievor who are in the same classification, the same Ministry, within 40
kilometres of the Grievor’s headquarters and perform work that the Grievor is qualified to
perform. The Grievor need not demonstrate that she is relatively equal or better than the
Incumbent to exercise her displacement rights. She need only demonstrate that she has the
skills and knowledge to perform the core components of the position at a working level.
Furthermore, she is entitled to a period of orientation, familiarization and integration into
the new workplace, although she would not be considered qualified if she requires training
to acquire new skills.
[34] In this case, the Union maintains that the Grievor is working level qualified for the position
of Secretary to the Director of the Employment Practices Branch and is therefore entitled to
bump the Incumbent, a more junior employee, from that position. The Grievor held the
same position in the same Ministry for several years and the Union submits that she has
experience in virtually all of the required areas. She also has extensive experience in the
Ministry of Labour and, more specifically, with the application, interpretation and
enforcement of Employment Standards legislation.
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[35] The Union acknowledged that the Grievor does not have experience with CMIS, however,
neither did the Incumbent and the Grievor does have experience with other tracking
systems. Nor does she have significant experience preparing graphic presentations or with
moveable assets. In the Union’s submission, the Grievor does, however, have demonstrated
experience with comparable duties and would be able to perform these components of the
job with a minimum amount of familiarisation.
[36] The Union rejects the suggestion that an employee can only be assessed against the precise
words used in their Employee Portfolio. The Grievor prepared this document on her own,
from memory and without the assistance of the relevant PDR or input from Human
Resources. It is therefore not surprising that she might have used language that is different
than that used to describe the job duties as set out in a formal job documented created by
human resource specialists.
[37] The Union also maintained that the Job Ad used to hire the Incumbent should be considered
in determining the core components of the position. In this instance, the Job Ad does not
require or mention a number of skills that the Employer now suggests are required but not
demonstrated by the Grievor. The Ad does not refer to CMIS, drafting executive letters,
policy proposals, briefing notes or dictation. In the Union’s submission, if these duties
were not important enough to mention in the Job Ad, then they should not be considered
core components of the position and should not be determinative of whether the Grievor is
working level qualified.
[38] The Union further submitted that the evidence of the Employer established that RSO staff
used a standard that was both inconsistent with the case law and unduly onerous. The
acknowledgment that an individual would have to have performed the identical task in
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order to demonstrate that they were working level qualified ignores their right to a period of
orientation and integration. In the Union’s submission, the standard employed by the RSO
establishes an unreasonable barrier to an employee’s right to displace a junior employee.
[39] The Union also argued that there were other, more specific errors in this case. Notably, it
appears that staff misread the PDR and inserted more demanding requirements than were
contained in the relevant document. Whereas the PDR detailed responsibility to keyboard
complex documents, reviewing staff treated this as requiring experience preparing them.
[40] The Union seeks an Order awarding the position to the Grievor with no loss of income,
seniority, service and benefits. It relied on the following cases in support of its submissions:
OPSEU (Strunc) v Ontario (Ministry of the Environment and Energy) [2000] O.G.S.B.A.
No. 21 (Harris); Elgin County Roman Catholic Separate School Board v. London & District
Service Worker’ Union, Loc. 220 (Xuereb) (1992), 26 L.A.C. (4th) 204 (Rose); PEGO
(Donyina) and Ontario (Ministry of Environment and Energy) (1998), GSB #2897/96
(Briggs); York University v. Canadian Union of Public Employees, Loc. 1356 (Price)
(2008), [2008] O.L.A.A. No. 218 (Chauvin); Children’s Aid Society of Metropolitan
Toronto v. Canadian Union of Public Employees, Loc. 2316 (Xuereb), [1990], 14 L.A.C.
(4th) 403 (Foisy).
[41] The Employer maintains that the main issue before me is whether the Grievor has
demonstrated that she has the necessary experience and knowledge to perform the core
components of the position at a working level. The Employer argued that the core
components of the position should be identified by reference to the PDR and the evidence
from the Incumbent with respect to the tasks that she actually performs. It was submitted
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that the Job Ad was irrelevant as it serves a different purpose and the standard for selection
in a job competition is not the same as the standard that applies in displacement situations.
[42] In the Employer’s submission the Union has not met their onus of establishing that the
Grievor is working level qualified to perform the core components of the position at issue.
The duties that the Grievor performed in her previous position of Secretary to the Director
were sufficiently different from those of the current position that her experience does not
automatically establish that she is qualified to displace the Incumbent. While there is some
overlap between the two positions, there are a number of core components for the position
of Secretary to the Director of the Employment Practices Branch for which the Grievor has
no demonstrated experience.
[43] The Employer submits that despite her past experience performing executive secretarial
duties, the Grievor’s skills are out dated and insufficient for this position. In particular, it
was argued that she did not have demonstrated experience drafting executive letters,
preparing briefing notes, managing correspondence electronically, preparing graphic
presentations or with regard to moveable assets.
[44] The Employer also maintained that the assessment of whether the Grievor has demonstrated
that she is working level qualified should be restricted to the information that she provided
in her Employee Portfolio. The Grievor was aware that she could contact her Employment
Mobility Co-ordinator if she needed assistance in filling out her Portfolio. She did not ask
for any help and refused to co-operate when she was asked to take another typing test. In
the Employer’s submission, the process set out under the collective agreement was
followed and it would be inequitable to permit the Grievor to rely on further evidence after
the agreed to process was completed.
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[45] The Employer argued that the collective agreement entitles the Grievor to a matching
process if her position is declared surplus and the parties have agreed to how that matching
process will operate. The Union failed to establish that the agreed to process was not
followed in this case and therefore there has been no violation of Article 20.4 in that regard.
To the extent that the Union suggested that the process was inadequate because the Grievor
did not obtain any assistance, the Union did not put forward any additional evidence that
was not found in the Employee Portfolio. Therefore, there is no basis to find that the
Employer did not have all of the relevant evidence when it determined that the Grievor was
not qualified.
[46] The Employer referred me to the following cases in support of its position: OPSEU
(Loebel) v. Ontario (Ministry of Finance), GSB #331/82 (Verity); OPSEU (Henderson) v.
Ontario (Ministry of Citizenship) (1992), GSB #1097/91 (Barrett); OPSEU (Ansari) v.
Ontario (Ministry of Agriculture, Food and Rural Affairs) (1998), GSB #0482/97
(Abramsky).
Decision
[47] The Grievor’s position was declared surplus and the Union has identified a position that it
alleges gives rise to her entitlement to displace a more junior employee. The parties agree
on the applicable level of qualifications: “The surplus employee must be qualified to
perform the work of the position identified. This means that the surplus employee must
have the necessary skills and knowledge to perform the core components of the position at
a working level and will not require training in these areas.” The parties further agree that
“training does not refer to the orientation and integration any employee would normally
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receive when entering a new position nor does it prohibit training to raise skills above a
working level.”
[48] The parties’ consensus on the relevant standard to be applied in this case reflects a
longstanding analytical approach taken by the Board. In Loebel, the leading case on this
issue, Vice Chair Verity set out the test to be applied:
To determine if a surplus employee is qualified to perform the work
pursuant to Article 24.2.3, the Board accepts Management’s argument
of “present ability” to the extent of minimum competence in all
components of the job requirements. To adopt any higher test of
present ability would be to destroy the significance of Article 24.2.3. That
Article has been mutually agreed upon by the Parties to benefit surplus
employees by affording them certain preferential rights of
appointment. Few, if any surplus employees would succeed in moving
successfully from one Ministry to another if the accepted test were more stringent
than minimum competence in all of the major components of the job. Such an
interpretation does not mean that a surplus employee must possess skill and
knowledge in all activities associated with the position. However, it does mean
skills and knowledge of the main component of the position. In the subject case,
knowledge of the Ministry’s objectives, policies and programs are all major
components of the position, each of which is essential to a surplus employee to be
deemed “qualified top perform the work”.1
1 Supra, at p. 21.
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[49] Similarly, in Henderson, Vice Chair Barrett described the test as follows:
Article 24.2.3 is not a job competition article and it is clear that surplus
employees need only have the minimal qualifications to perform the essential
duties of the position. This is clear from the wording of article 24.2.3,
and the jurisprudence of this board, and the memoranda from
Management Board of Cabinet referred to above. This does not mean,
however, that a new lower standard of what it means to be qualified has
been introduced into the collective agreement. Article 24.2.3 speaks to
present qualifications, not those that could be obtained through
extensive training. With extensive training, an electrician could become a plumber
and a plumber could become an electrician. Neither has the present qualifications
to perform the other’s job.2
[50] Finally, Vice Chair Harris in Strunc has succinctly restated the test and underscored the
notion of minimal competence: “The qualifications required in order to displace a junior
employee are not those of a fully qualified and experienced incumbent. It is well
established that a displacing employee need only have minimum competence in the major
components of the job.”3
[51] Before addressing the main issue of qualification, there are two preliminary issues that I
must consider:
(a) How do I determine the core components of the position?
2 Supra, at p. 12.
3 Supra, at paragraph 27.
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(b) What evidence should be considered in determining qualifications?
[52] The Employer suggested that I should determine the core components of the job by
interpreting the PDR in light of the Incumbent’s vive voce evidence of what she actually
does. The Union urged me to consider the PDR, the Job Ad and the evidence of the
Incumbent.
[53] I prefer the approach suggested by the Union. While it is appropriate to examine all of the
available evidence to determine what the core components of the job include, the greatest
weight must be given to the PDR, the formal document created by the Employer to outline
the responsibilities, duties, skills and knowledge in respect of this position. The Job Ad
reflects a more limited view of what the Employer considered important when it was
seeking candidates to fulfil those requirements. Similarly, the evidence of the Incumbent is
relevant, however in no way determinative.
[54] In the end, if a duty is not specified in the PDR, I cannot find that it is a core component of
the job merely because the current incumbent performs that function. In order to respect the
jurisprudence of this Board, it is important not to define the core components in a manner
that effectively elevates the minimal qualifications required to do the job to the level of
proficiency demonstrated by an experienced person currently performing in that role.
[55] This should not be interpreted as a negative comment on the ability of the Incumbent. Ms.
Roy is clearly a very intelligent and highly capable employee. However, this is not a
competition between her and the Grievor. If I rely on the evidence of Ms. Roy to determine
the content or required duties of the position, qualification would inevitably be defined on
the basis of her particular strengths and unique abilities. It thus runs the risk of setting an
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arbitrary bar for qualifications that is dependent on the identity of the incumbent at that
particular time.
[56] The PDR states that the purpose of the position of Secretary to the Director is to “provide
secretarial and administrative support to the office of the Director”. Duties include the
kinds of duties one would generally expect of an executive secretary: preparing standard
letters, statistical reports, spreadsheets and graphic presentations; keyboarding; managing
correspondence, including use of a computer based tracking system; receiving and
screening calls and visitors; answering general queries; admin support to co-ordinate,
organise and maintain schedules, meetings, conferences and travel; and providing other
admin support such as moveable assets, purchasing office supplies and maintaining
attendance records.
[57] The Job Ad focuses on organizational skills, proficiency in the use of a computer and
relevant software, knowledge of OPS secretarial, administrative and internal office
procedures, familiarity with relevant legislation, demonstrated written communication
skills, analytical skills and interpersonal skills. The Incumbent confirmed that the majority
of her time is spent managing correspondence: tracking it on OCMS, referring
correspondence to the appropriate person for response, and preparing some draft responses
on her own that are subsequently reviewed by a more senior staff member.
[58] In her closing argument, Counsel for the Employer suggested that the Grievor was not
working level qualified with respect to several core components of the position: drafting
executive letters, preparing briefing notes, managing correspondence, preparing graphic
presentations and providing admin support with respect to moveable assets.
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[59] Having reviewed the PDR and the other relevant evidence, I am not persuaded that the
Grievor must demonstrate experience or qualifications preparing draft executive letters,
policy proposals, briefing notes or complex correspondence. The PDR indicates that she
would be required to keyboard these documents, but limited the preparation of drafts to
responses to general queries. Counsel for the Employer suggested that I should read in the
responsibility to draft other executive level documents based on the evidence of the
Incumbent. As I have already concluded, that would establish a core component that vastly
exceeds the duties detailed in the PDR or Job Ad. In effect, it would require the Grievor to
demonstrate that she is as proficient as the Incumbent. That is clearly not the standard to be
met in this case.
[60] Nor do I find that familiarity with CMIS is a core component of the position. The PDR
refers to CMIS in the broader context of updating and training others on a computer based
tracking system. In fact, the Incumbent was herself only vaguely familiar with the
programme and does not use CMIS. Correspondence management, including online
tracking is clearly a core component, however, it should not be so narrowly defined that it
frustrates the purpose of Article 20.4.
[61] The Employer also argued that the Grievor was entitled to a displacement process that had
been established with the agreement of the Union. The Employer followed that process in
this case and the Grievor should not be entitled to rely on additional evidence of her
qualifications to in effect do an end run around the process. I was therefore urged to restrict
my examination to the information contained in the Employee Portfolio.
[62] I accept that there is a heavy burden on management and the Grievor to make every effort
to get it right in the first instance. It is very disruptive for the Incumbent and the system
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generally to provide evidence of new qualifications at this late stage. However, the Grievor
is entitled to more than a good faith effort to place her in another position. The Collective
Agreement establishes a substantive entitlement to a position for which she is qualified if it
is held by a more junior employee. In my view, all of the evidence, including the
clarification provided at arbitration, must be considered to determine whether the Grievor
has the requisite qualifications.
[63] I would also note that, in this case, I do not have any direct evidence of the process that was
followed in comparing the Grievor’s qualifications against the core components of the
position. The only witness that the Employer called from RSO was neither the Grievor’s
Employee Mobility Coordinator nor the person who assessed her qualifications for this
position. Consequently, there is only minimal evidence of the process actually followed by
RSO.
[64] What evidence there is, suggest errors in the review and incorrect conclusions regarding the
core components of this job. For example, I have already determined that preparing draft
executive letters, policy proposals and briefing notes should not be considered as core
components. The PDR is clear that the duties include preparing draft responses to queries,
but are limited to keyboarding higher level or more complex documents such as briefing
notes or executive letters. Nonetheless, RSO cited an absence of demonstrated experience
preparing executive documents as one of the main deficiencies in the Grievor’s
qualifications.
[65] There was also evidence that the Employer used an excessively high standard to assess
whether the Grievor was qualified to perform the job. Ms. Aung made it clear that she and
her colleagues operated on the assumption that an individual must have actually performed
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a specific duty in order to be deemed qualified. They did not examine broad duties but
focussed on very narrow and specific individual tasks when they assessed whether there
was match. Moreover, their approach did not take into consideration whether the Grievor
had sufficient experience so that she could perform the major components of the job after a
period of familiarisation and orientation.
[66] In my view, RSO asked whether the Grievor was fully qualified to do every aspect of the
position, at an advanced or senior level. Such a narrow focus gives rise to a real risk that the
preferential rights based on seniority that are granted under Article 20.4 will become
illusory. While Ms. Aung acknowledged that the conclusion in this case might have been
different if the Grievor was considered deficient in only one small aspect of the position,
the orientation was to screen out “possible/potential” matches where ever there was not a
perfect overlap, not to screen in the senior employee where they demonstrated minimum
competence to do the job.
[67] The overly technical view that was taken by RSO was made even more problematic by the
information they relied upon. Employees fill out an Employee Portfolio on their own,
describing their skills and experience, in their own words. RSO employees then compare
that document with a formal Position Description Report looking for precise matches. I
accept that staff make genuine efforts to identify relevant skills and that surplus employees
must take responsibility for ensuring that they provide complete information regarding their
previous work experience. Nonetheless, RSO must take into account the limitations that are
inherent in the process and should seek further clarification where appropriate.
[68] This was not a case where RSO was assessing an Electrician against a Plumber, or even a
Metallurgic Engineer seeking the position of a Civil Engineer. This is a case where the
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comparison is between a former Secretary to a Director in the Ministry of Labour and a
current Secretary to a different Director in the same Ministry. It seems surprising that the
two positions would be so dissimilar that an employee could have lengthy experience in one
position and not be working level qualified to perform the core components of the other.
[69] Counsel for the Employer suggested that the positions were not identical because the job
had evolved since the Grievor served in the role and because different duties were required
to meet the needs of this particular Director. The PDR for the Grievor’s former position
was not available, however, the PDR for the position at issue was developed in 2000, three
years after the Grievor left her former position. One wonders how much of an evolution in
the position could have occurred in that intervening period. Nor was there evidence to
explain why there would be a significant difference in the same position, classified at the
same level, in the same Ministry, simply because it was for the Director of a different
Division. In these circumstances, the Employer should have contacted the Grievor to clarify
the information contained in her EP. That was doubly true where, as here, the Grievor
indicated that she possessed certain skills essential to the performance of the position under
review, but her EP did not include detailed information to support her self-assessment.
[70] For all of these reasons, I find that it would not be appropriate to restrict the evidence that I
consider to that found in the Employee Portfolio. In my view, the Union is entitled to rely
on the vive voce evidence of the Grievor that was given at arbitration to establish that the
Grievor is qualified for the position held by the Incumbent.
[71] Has the Union established that the Grievor has the minimum competence to perform the
core components of the position at issue? I find that it has. She has experience working in a
similar position and performed a myriad of general administrative support and secretarial
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duties over many years. While it has been a number of years since she held the position of
Secretary to the Director, she has provided detailed support for the vast majority of the core
components of this position in her Employee Portfolio. The Grievor’s qualifications might
be wanting with respect to a couple of minor aspects of the position, however, she has the
necessary skills and experience to be considered working level qualified after a modest
period of familiarisation.
[72] The Grievor’s evidence clearly establishes that she has experience keyboarding and editing
executive correspondence. She also has extensive experience preparing basic
correspondence, functions that she performed when she previously held the position of
Secretary to the Director and in her subsequent positions with the Employment Standards
Branch. She also acquired significant experience with Employment Standards legislation
when she worked as an Audit Assessment Clerk, Intake Officer and Resident Auditor with
the Employment Standards Branch. She gained further experience analysing data, drafting
reports and responding to related inquiries in these later positions with the Branch.
[73] In argument, the Employer suggested that preparing executive documents was one of the
main functions of the position and that the Incumbent “takes the lead” in drafting responses
that raise policy issues under the Employment Standards Act. Since the Grievor did not
have demonstrated experience preparing a range of executive level documents, including
complex correspondence, briefing notes and policy papers, the Employer took the position
that she was not qualified for the job. I accept that the Grievor has not drafted complex or
executive level correspondence, or prepared briefing notes, however, I have already found
that they are not in fact core components of the job.
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[74] The Employer also challenged the Grievor’s qualifications to prepare presentations and
provide administrative support to the Director for moveable assets. The Grievor testified to
some experience creating charts, graphs and spreadsheets but acknowledged that she did
not have experience creating illustrations. She also admitted to limited experience with
presentation software, but noted extensive experience with other, comparable software,
including Excel. The Grievor further acknowledged limited experience regarding moveable
assets.
[75] I do not regard either of the above noted gaps as determinative of whether the Grievor is
minimally qualified for the position. First of all I note that moveable assets and preparing
presentations comprise only a small part of the overall responsibilities, according to the
Incumbent. More importantly, the Grievor has all of the necessary skills and demonstrated
experience to establish that she will be able to perform these duties after a relatively brief
period of orientation. She has a broad range of computer based skills and familiarity with a
wide array of software. The Grievor would undoubtedly be able to master these tasks after
familiarisation with the relevant computer programme, office procedures and protocol. In
my view, she does not need to be trained to develop new skills, but rather to build on her
existing skills through a period of orientation, integration and familiarisation in the new
position.
[76] Finally, I find that the Grievor is working level qualified with respect to correspondence
management. The Grievor has several years experience with manual file retention and
correspondence tracking systems from the period when she was a Secretary to the Director
and the Assistant Deputy Minister. She thus has the demonstrated conceptual skills
associated with correspondence management, having assumed that responsibility in her
former position. While she does not have any familiarity with the specific computer
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programme now in use within the OPS, she has experience in other computer based
tracking systems. Her experience with ESSIS, in a claims based environment, was
described by the Incumbent as a more sophisticated system that used multiple functions.
Despite the absence of actual experience with CMIS or OCMS, I find that the Grievor’s
experience is sufficient and that she is qualified to manage and update a computer based
tracking system, including a correspondence management system.
[77] I would allow the grievance and Order that the Grievor be placed in the position of the
Incumbent and that she be made whole with respect to her pay, benefits, seniority, service
and pension. The matter is remitted back to the parties to determine the manner in which
my order will be executed. I will remain seized in the event that an issue arises with respect
to the interpretation or application of this Decision.
Dated at Toronto this 3rd day of July 2013.
Reva Devins, Vice-Chair