HomeMy WebLinkAbout1991-1438.Chuan&Prommer.92-04-07 ONTARIO EMPLO ¥65 DE LA GOUF~ONNE
C~OWN EMPLOYEE~ DE L'ONTARIO
GRIEVANCE C,OMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 OUNDAS S'~EET wEST, SUITE 2100, TORONTO, ONTARIO, MSG IZ8 TECE~HONE/TEL£PHONE: [4 ~) 3~- ~388
180, RUE DUNDAS OUEST, BUREAU 2 ~, TORONTO fONTARIO), MSG ~Z8 FACSIMI~/T~COPIE : ~4 ~6) 326-~3~
1438/91, 1439/91
Befo~l
BB~R~
......
The Crown in Right.o~ Ontario'
(Ministry of Community & social Services~
B~FOP~: J. Samuels vice-Chairperson
S. Urbain Member
D. Daugharty Member:.
FOR THB K. Whitaker
GRZEVOR Counsel
(Chuan) Ryder, Whitaker, Wright & Chapman
Barristers & Solicitors
FOR ~B M. McFadden
GRI~VOB Counsel
(Prommer). Koskie & Minsky
Barristers & Solicitors
PORTHB M. Gottesman
EMPLOYER Counsel
Legal Services Branch
Ministry of Community & Social Services
g~]tRING December 17, 1991
The grievors claim that 'they ought .to have been the successful
candidates in a job competition. In order to prepare its case, the union-~'
requested the production of certain documents concerning the other .-
candidates. A summons was issued by the Board to an employee of the
Ministry in the Human Resources Head Office Unit to attend the hearing "
and to produce documents. The Ministry refused to produce some of the
documents without the Board convening and issuing an order to produce.
At our brief hearing, the panel 'issued the requisite o~der, and
requested counsel to submit written argument concerning the Ministry's -
refusal to produce documents unless a panel of the Board was convened.
The~ panel was concerned with what appeared to be an unnecessary waste of
the Board's resources. As the Board said inCheong, 525/90 (Samuels),
This Board is not the creature of the parties. It is
created by ..statute and is funded out of the public
purse. The parties must do whatever is 'necessary
to facilitate the hearing,~ to cooperate in a
reasonable fashion with one another, so that this
Board's time 'and energy are used effectively. (at
page4)
The Ministry's reason for refusing to release the documents without
a Board order is that the Ministry takes the view that it is prohibited from
releasing the documents pursuant to the Freedom of Information and
Protection of Privacy Act, RSO 1.990, C. F.31 ("FIPPA"). The Act defines
"personal information" to include "employment history" (section 2(1)(b)),
and prohibits the disclosure of such personal information as an unjustified.
invasion of personal privacy (sections 21(1) and 61). ...
The Ministry agrees that it must comply with a Board summons, but
points out that the stunmons is simply an order to a witness to appear with"
documents, and does not compel the pre-hearing disclosure of documents.
We agree, with this point, and in doing So, must say that the panel in
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Cheong, chaired by the same Vice-Chairperson as now writes this award,
was incorrect when it said that the Ministry violated the summons by
refUsing to turn over documents befor~ the hearing. _
The Ministrg also acknowledges that this Board can order the pre-
hearing production of dOcuments, pursuant to section 11 (8) of the Crown
Employees Collective Bargaining Act, and the Ministry is quite willing to
comply with such an order. This order relieves the Ministry of
responsibility under FIPPA for~the release of any 'documents called for in
the order, because section 64(2) of FIPPA says "This Act does not ~affect
the power of a .... tribunal to .... compel the production of a document".'
Thus, we conclude that the Ministry is correct when it argues that it
is not compelled to produce documents before a hearing unless this Board
orders such production.
However, in our view, given the very significant concern we hax~eL
that the'parties must do whatever is possible to facilitate a hearing and to .__
~to what can be-done t~ ensure that the' Board's time .and energy are used
effectively and efficiently, it is necessary for the Ministry tO re-evaluate
seriously its refUsal tO PrOduce documents before a hearing, where those
documents are needed by the Union in the preparation of its case.
The Union argues that the Ministry would not violate FIPPA by
producing the documems before the hearing, even in the absence of a
Board order. And we agree with this. Though we are mindful of the
Ministry's care and concern not to violate FIPPA, and though we are not
charged with 'interpreting that Act, we commend the following points to the
Ministry's consideration.
FIPPA's purpose, is to provide for free access 'to information, but
with sufficient protection to ensure that an individual's privacy is not
violated, except where necessary. Section 10(1) of the Act provides that
"Every person has a right of access to a record...in the custody or under
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the control of an institution unless the record falls within one of the
exemptions under sections 12 to 22". Section 21(1) prohibits the disclosure
of personal information (which includes employment history) unless the
disclosure is not an unjustified invasion of personal privacy. In
determining whether there would be an unjustified invasion of personal
privacy, section 21(2). says that one must consider whether, inter alia,
"(d)the personal information is relevant to a fair determination of rights
affecting the person who made the request". This is precisely the
circumstances of our case. The information which the Union requires is
necessary to a fair determination of the grievors' rights, and thus,, we
suggest that the Ministry. would not have violated FIPPA by producing the
documents before the hearing. :.'
As' well, we share the view expressed by this Board in Cheong,
1_895/90 (Gorsky), that FIPPA permits the disclosure of personal
information when· it is for the Purpose of. complying 'with the provisions of
the collective., agreement. At pages 23 and 24, tl,/e Board said:
We would also note that section 32(e). of the
Freedom of Information and Protection of ..:.
Privacy Act, 1987, permits an Institution to ~
disclose "personal information in its custody or
under its control" where it is "for the purpose of
complying with an Act of the Legislature or an
ALt of Parliament, an agreement or arrangement
under such an Act or a treaty .... "The collective
agreement between the parties is, in our view "an
agreement...under such an Act." Section 7 of the
Crown Employees. Collective Bargaining Act
gives an employee organization authorization to
bargain with an employer with a view to
concluding, the collective agreement. The
procedure for realizing the collective agreement
is provided for in the latter Act and section 19(1)
mandates arbitration provisions for effecting a
f'mal and binding decision where the parties are
unable to effect "a settlement of any differences
between them arising from the interpretation,.
application, administration or alleged
contravention of the agreement..." In the absence
of the power in a Board to order production of
docUments pursuant to a ~l;bpoena duces tecum,
the purposes of section 19(1) would, in many
cases, remain unrealized. We find that a
collective agreement under the Crown Employees
Collective Bargaining Act represents such "an
agreement.., under such an Act" as is referred to
in section 32(e) of the Freedom of .Information
and Protection of Privacy Act, 1987, gnd that the
disclosure of what would otherwise be
impermissible personal information under the
latter Act would be permitted as being for the
.purpose of complying with the provisions of the
collective agreement.
In line with Vice-Chairman GorskY's reasoning, we suggest that the
Employer should obtain permission in advance from candidates for posted
bargaining unit posiliions to l~roduce necessary documents to the Union
the event of a grievance after the -~:ompetition is concluded. The''posting
could include the following notice (and the notice could be repeated in a
release form which every candidate submits along with the application for
the posted position):
By applying for the posted position, applicants
acknowledge that they understand that the
competition is subject to the provisions of the
collective agreement between the Ministry and the
Ontario Public Service Employees Union. An
unsuccessful candidate may griev, e under the
collective agreement. If such a grievance is filed,
the Union may request the Ministry to produce,
before or at an arbitration hearing at the Ontario
Crown Employees Grievance Settlement Board,
documents concerning the. employment records
and applications of all the candidates in order to
prepare its case. Applicants give permission to
the Ministry to produce to the Union Or its
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counsel documents concerning their employment
records or their applications for the' posted
position. '
We offer these comments in the hope that the Ministry will see its
way clear to produce most, if not all, of the necessary documents to the
Union before any hearing so that the Union can prepare its case adequately.
It may also be helpful if we make some suggestions concerning the
administration of the production of documents, so that the Board's
resources can be Used most effectively in these cases. A number of these
suggestions have been made. before by others, but we think they bear
repeating. - ......
Firstly, the Union must make. its request for documents as far in
advance of the scheduled hearing as is practicably, possible. The request
should be: reasonably circumscribed, so that only necessary informati6n is:
requested. .
Secondly, the 'Mir~stry ought to re~pond/t~ quickly as possible to the
Union's request.. In particular, if the Ministry feels that it is unable to'~
produce certain 'documents without_ a Board order, the Ministry ought_to
identify these documents very early on, so that the Union can request the
Board to order the production of the documents well in advance .of the
scheduled heating day. it is very important that the Union have in its
hands all the documents which the Board is prepared to order in plenty of
time to prepare the grievors' cases.
Thirdly, where there is a disput.e between the parties' concerning the
pre-hearing production of documents, the Board will try to schedule a
mini-hearing well in advance of the day scheduled for the full hearing, and
the Board may issue its orders for production verbally so that the
documents can be exchanged as' early as possible, again to give the Union
plenty of time to prepare the case for the scheduled full hearing.
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Fourthly, it may be possible in some cases for the parties to agree on
a "Consent Order" which can be issued by the Chairman or a Vice .......
Chairman of the Board, without the neea to convene a panel.
Fifthly, it may be 'possible in some cases for the parties to make bri_ef
written argument concerning the few docttments over which they have a
disagreement, and this argument can be considered by the Chairman 'or a
Vice-Chairman of the Board and a decision 'can be given to the parties
quickly.
Done at London, Ontario, this ?ca day of lpril , 1992.
anuels, Vice-Chairperson
S. urbain, Member