HomeMy WebLinkAbout1994-0657.Garth.96-05-07
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ONTARIO EMPLOYES DE LA COURONNE G O\/"L
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE ( cS L ,'-
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SETTLEMENT REGlEMENT r' ,0 S {'\ .J'}
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BOARD DES GRIEFS v (}..-\i\ \ . Iv"-
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180 DUNDAS STREET WEST. SUITE 2100. TORONTO ON M5G lZ8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ON) M5G 1Z8 FACSIMILE/TELECOPIE (416) 326-1396
GSB # 657/94, 810/94
OLBEU # OLB121/94, OLB144/94
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ~CT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OLBEU (Garth)
Grievor
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The Crown in Right of ontario
(Liquor Control Board of Ontario)
Employer
BEFORE: E. Marszewski Vice-Chairperson
FOR THE J. Noble
GRIEVOR Counsel
Ontario Liquor Boards Employees' Union
FOR THE J. Baker
EMPLOYER Counsel
Hicks, Morley, Hamilton, stewart, Storie
Barristers & Solicitors
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HEARING October 4, 5, 12, 1995
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This matter involves two grievances of Grover Garth, an employee of the
Liquor Control Board of Ontario The first grievance involves a disciplinary letter dated
May 30, 1994 which suspended the Grievor with pay The second grievance involves
the dissmissal of the Grievor The Grievor seeks re-instatement and full compens~tion
as well as the removal of any disciplinary notes and reports from his files.
Counsel for the Union was advised by Counsel for the Employer prior to the
first day of this hearing that the Employer intended to introduce videotape evidence in
the presentation of its case. Counsel for the Union presented a prelim inary objection to
the Employer's request to the introduction of the videotaped evidence in support of its
case against the Grievor First, Union Counsel submitted that the the videotape evidence
was inadmissible due to the fact that it was the result of surreptitious surveillance of the
Grievor and consequently coutrary to Section 8 of the Charter of Rights. This argument
relied upon the prem ise that the Employer was an arm of the Govern ment of Ontario and
was therefore subject to the provisions of the Charter of Rights. Secondly, and in the
alternative, Counsel submitted that the introduction of the videotaped evidence against
the Grievor would constitute a violation of the Grievor's common law right to privacy,
which violation could only be justified in certain, particular circumstances, circumstances
which were not present in this case. The surreptitions surveillance of the Grievor had
been instituted without judicial authority or order " ;
Counsel for the Employer submitted that the Charter of Rights argument
could not proceed on the day of the hearing as it involved a constitutional question and
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due notice, as required by the provisions of the Courts of Justice Act, had not been
provided to either the Attorney-General of Ontario or the Attorney-General of Canada
It was further submitted that such notice had to be given at least 15 days prior to the
hearing. While the Union disputed the assertion that notice had to be given as submitted,
Union Counsel agreed to proceed only with the submissions alleging the breach of
privacy rights at common law and reserved the right to make submissions with respect
to the Charter of Rights arguments at a later date
The Union subpoenaed Michael Pamieri, the Manager of Store #408, as it's
witness with respect to the preliminary issue. The LCBO Store #408, located at Jane and
Finch, had 11 employees. 10 of whom were bargaining unit members. Palmieri was the
manager at this store from October or November 1993 to September 1994 The following
statement made by Palmieri was filed in evidence:
I am Manager of LCBO Store #408 located at 3865 Jane Street. I have
worked here since November 8, 1993 Mr Garth was a part time and then
permanent full time employee for approx 17 years in total Prior to March
29, 1994, I observed Mr Garth with different customers under ringing their
purchases Later, on another day he would receive money from them for
the shortage from their earlier transactions Mr Garth was cautioned about
this as these amounts were not reflected in his daily cashier balancing
report.
When I considered this along with the store shortages, I advised Dan Walsh
of this information on April 16, 1994 At this time a CCTV system was
being installed regarding improper cashieriAg procedures of another store
employee, Lloyd Brickley
On April 23, 1994, I removed this first tape and installed a second tape
placing the date, time and my initials on a label on both tapes I followed
this procedure again for 2 more tapes on April 28, "j 994, May 4, 1994 and
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on May 11, 1994 I removed this tape without replacing it with another one
The first tape was turned over to Dan Walsh on April 26, 1994 The other
three tapes were turned over to Dave Hadlow on May 3, May 4 and May
15, 1994
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This concludes my evidence on these matters.
The surveillance cameras were installed to cover the cash area of the store
and were programmed to go on and off at certain times. Palmieri testified that he was
concerned with the store's high losses, a concern which was directly within the scope of
his responsibilities as Manager He had suggested to his District Store Manager that the
surveillance cameras be installed to enable Lloyd Brickley's cashiering procedures to be
observed. The videotaped evidence came from one camera which recorded each of
Brickley and the Grievor as they worked the same cash register but on different shifts.
The cash register in question also happend to be the furthest from Palmieri's office. Lloyd
Brickley, the other employee mentioned in Palmieri's statement, was terminated due to
his improper handling of funds.
Palmieri's statement was given to LeBO security sometime around April
1994 As indicated in the statement, Palmieri testified that the Grievor had been
'under ringing' customer purchases. The term'underringing' was used to describe a
process whereby the cashier, when met by a customer who was short of- the required
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cash for his or her purchases, allowed the customer to take those purchases out of the
store upon receipt of an undertaking by the customer to give the cashier the balance of
the amount owing at a later time. Garth had been "underringing" customer purchases,
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later collecting the remainder of the monies owing by the customers The G rievor' s
behaviour was unusual and different from that of other store employees Palmieri also
testified that the grievor was very friendly with customers He observed numerous times
when customers come in speCifically asking for the Grievor and upon being told that he
was away from the store, they left without making a purchase. Palmieri testified that he
had verbally counselled the Grievor to stop 'underringing' customer purchases Up until
that point, the Grievor had not been disciplined for theft.
On April 16, 1994, Palmieri spoke to Walsh, the LCBO security investigator,
and discussed both the 'underringing' practise as well as the extremely high store
shortages Palmieri also testified that the store was overstocked with 50 ml miniature
bottles. He explained that this situation arose because the cashiers were ringing in
miniatures when in fact they were selling larger bottles. Consequently, there was an
excess supply of the small bottles and a shortage of the large, 40 oz. bottles of liquor
In speaking to his superior, Palmieri noted that the Grievor "did not always take the full
dollar amount for the purchases", that he "was observed receiving money from customers
two and three days after the event and putting his hands presumally with money in his
pocket" and that his ringing off procedues were "irregular" Palmieri recalled discussing
these matters with the Grievor although Palmieri was not sure that he had spoken to the
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Grievor about the fact that the latter had been observed ~utting his hands in his pockets
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The Employer called Yolanda Simone, the LeBO Acting Supervisor of
Benefit Services since September, 1995 Previously, as the Human Resources advisor,
Simone had been involved in disciplinary issues at Steps 2 and 3 of Grievance
proceeding s She testified that the LeBO had been involved in videotaping employees
in its various stores since 1989-1 990 During her work for the Employer in the Human
Resources function, she testified that between three and five employees were discharged
annually as a result of videotaped evidence. She further testified that the Union had not
objected to the use or introduction of videotape evidence
According to Simone, the Manager of a store would normally contact the
District Manager who in turn contacted the Security Services office. Due to the fact that
there are a limited number of surveillance cameras, and their installation and use are time
intensive, cameras are not installed unless there are concrete reasons for doing so. She
did not recall any objections made on behalf of employees involving the employees I right
to privacy argum ent.
An employee's right to privacy can arise by virtue of the application of a
specific provision in a Collective Agreement which may set out the right explicitly or give
rise to its inference by implication In addition, the right to privacy might arise by virtue
of the application of statutory provisions, such as the apt)lication of the Privacy Act in
British Columbia, the provisions of which were considered in the decision in Re Doman
Forest Products Ltd., New Westmister Division and International Woodworkers,
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Local 1-357 (1990) 13 L.A.C (4th) 275 (0 H Vickers) Employees may also claim a right
to privacy in circumstances where their employment relationship is subject to the
provisions of the Canadian Charter of Rights
In the instant case it has been recogn ized by the Union that there is neither
a provision in the parties' collective agreement nor a legislative provision which might give
rise to a right to privacy Moreover, the parties have agreed to defer their submissions
with respect to the applicability of the provisions of the Charter of rights pending an
interim determination with respect to the issue of the adm issibility of the videotaped
evidence and the question of whether or not there is a common law right to privacy which
might apply in the instant case. The Union has asserted that an employee can also have
a right to privacy which is grounded in the common law and supported by arbitral
jurispruden ce, The Union thus took the position that the common law right to privacy
applies in the instant case, precluding the admissibility of the surreptitious videotape
surveillance evidence of the Grievor While the Union agreed that such a common law
right is limited by legitimate needs of an Employer, such as the need to maintain the
honesty and integrity of employees in positions of trust, it did not feel that such limitations
were appropriate in this case. The Union relied upon the decisions in Re Labatt Ontario
Breweries (Toronto Brewery) and Brewery, General & Professional Workers Union,
Local 304 (1994) 42 L.A.C (4th) 151 (G J Brandt), Re UniJersity Hospital and London
& District Service Workers' Union, Local 220, (1981) 28 L.A.C (2d) 294 (P C Picher),
Re Accuride Canada and Canadian Automobile Workers, Local 27 (1992) 29 L.A.C
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(4th) 137 (B Welling), Re United Automobile Workers, Local 386, and Com co Metal
Products Ltd (1972) 23 L.A.C 390 (H D Brown), Re Royal Oak Mines Inc., Yellowknife
Division and Canadian Association of Smelter & Allied Workers, Local 4 (1991) 24
L.A.C (4th) 221 (R.B Bird, Q C), Re Toronto Star Newspapers Ltd. and South'ern
Ontario Newspaper Guild, Local 87 (1992) 30 L.A.C (4th) 306 (I Springate),
In the Employer's submissions, there is no overriding common law right to
privacy which can be derived either from any of the traditional sources or from any arbitral
awards. In this context, Counsel for the Employer cited the old common law rights of the
privacy of the body and the privacy of one's personal property, breaches of either of
which led to the traditiona I torts of assault, tresspass to body or tresspass to property
The underlying principle referred to by Counsel for the Employer is that the employment
contract does not extend to the private life of an employee away from work unless there
is a good business reason for it. In support of its submissions, Counsel for the Employer
relied upon the decisions in. Re Cameo (supra), Re University Hospital(supra),
Meszaros v Simpson Sears (July 18, 1979) 19 A.R. 239 (Alta Queens Bench), New
Dominion Stores (Division of Great Atlantic & Pacifio Co of Canada Ltd.) and Retail,
Wholesale & Department S10re Union, Local 414 (1992) 28 L.A.C (4th) 53 (R.A.Grant)
LCBO vs. OLBEU (Linton), June 29, 1995 (0 Gray), LCBO vs OLBEU (Campanaro)
January 13,1995 (M Watters), Greenough v Woodstr'~m Corp. (Jan. 17, 1991, Ont.
Ct (Gen Div), Fleury J )
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The issue that is raised in this case is whether the admission of
surreptitious videotape surveillance evidence as real, substantive evidence (and not
merely as corroborative evidence) against the grievor constitutes a breach of the grievor's
general common law right to privacy, absent considerations of the provisions contained
in the Charter of Rights.
In the civil context, the Greenough decision (supra), a 1991 Ontario General
Division case, is said to be the first civil case in Canada which permitted a videotape to
be admitted as real, substantive evidence. In that case, the videotape camera was
concealed in the ceiling of a specific area of the plant and recorded the activities in its
field of vision, including the activities of Greenhough, one of the employees at the plant.
As a result of the videotape evidence, Greenhough was dismissed for having engaged
"in the theft of company property" The trial judge viewed the evidence and concluded
that Greenough's conduct amonted to 'I aiding and abetting the commission of an
offence. II
Approximately one year ealier, in the labour relations context in British
Columbia, a similar issue involving the admissibility of videotape surveillance evidence
was considered in what was cited by Union Counsel as one of the leading cases, Re
Doman (supra) However, in that case, the arbitrator incr'dded consideration of both the
fundamental values enshrined in the Constitution in the Charter of Rights and of the
provisions of the British Columbia Privacy Act. The considerations in that award are
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therefore marginally helpful in the instant case, given the lack of equivalent legislation in
Ontario and given the parties agreement to defer consideration of Charter issues.
However, even in the context of the Charter consideration s and the B C privacy
legislation, the award took into account that the right to privacy is not absolute. In'that
context, it had to be balanced against various considerations set out in Section 1,
Subsections (1) to (3) of the statute, including whether the surveillance was "reasonable
in the circumstances" , whether "due regard [is] given to the lawful interests of others"
and that "regard shall be given to the nature, incidence and occasion of the act or
conduct and to any domestic or other relationship between the parties. II The final
subsection of Section 1 provides that "Privacy may be violated by surveillance but this
subsection shall not be construed as restricting the generality of subsections (1) to (3)
The arbitrator concluded
I cannot determine whether the grievorls right to privacy has been abused until
I have heard all of the evidence, including what was done and what was observed,
whether visually or electronically It would be dangerous at this stage of the
proceedings to rule evidence inadmissible where I have not had a full opportunity
to consider all of the circumstances Only then can I truly balance the interests.
If, upon hearing the evidence, I am satisfied that there has been an invasion of
privacy in circumstances which were unreasonable, I would then not hesitate to
rule the evidence inadm issible.
Accordingly, my decision at this point in the proceedings is that the evidence
is to be called subject to the objections of the union, which I will rule upon in my
final award.
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I agree with the procedu ral conclusions set our by arbitrator Vickers in the
Re Doman award and follow them in the instant case If there is no common law right
to privacy applicable in Ontario, then this hearing would inevitably continue with the
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Employer's evidence, which in this case involves the production of its videotapes subject
to the usual technical evidentiary requirements. If there is some type of common law
right to privacy in Ontario, and this does not appear
to be clear from the cases that have been cited herein to date, such a right to privacy
must be, inevitably, balanced by various considerations such as, perhaps, those listed in
the B C legislation. 1 will allow the parties to make such submissions as are deemed
to be appropriate or necessary upon the completion of the evidence in the circumstances
of this case. This procedural ruling must be specifically restricted in its applicability to
the very specific facts before me, including:
1 the absence of statutory or collective agreement provisions,
2. the deferral of submissions with respect to the applicabilityof the Charter of
Rights
3 we are not dealing, at least as the case has been argued to date, with the
traditional tort situations involving assault, trespass to body or trespass to
property, issues raised in the inspection of locker cases or the medical or other
physical examinations of employees, to cite but two types of cases,
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4 the fact that the videotape surveillance appears to have been carried out in a
public place fully accessible to customers and the public, so that we are not
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dealing with surrep titious surveillance of an employee's private office or private
residential space,
5. the grievor was working at the cash register and therefore is clearly operating
in a significant position of trust vis a vis his employer
In the context of my conclusions as set out above, the introduction of the
videotaped evidence is hereby allowed subject to any further objection s by the Union
and subject to the parties' final subm issions in this case.
Dated at Toronto this 7th day of May, 1996.
~-'lr(e/;'cY'.{?~7 r!
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Eva E. Marszewski - Vice Chairperson
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