HomeMy WebLinkAbout1997-0923.CURRANS_CHAPUT97_1
ONTARIO EMPLOY~S DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
,
SElTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 800, TORONTO ON M5G 1Z8 TELEPHONEfTELEPHONE (41/5) 32/5-1388
180, RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G 1Z8 FACSIMILEfTELECOPIE (41/5) 32/5-13gtJ
GSB # 0923/97, 0924/97
OLBEU# OLB048/97,OLB049/97
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OLBEU (Currans/Chaput)
Grievor
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The Crown in Right of Ontario
(Liquor Control Board of ontario)
Employer
BEFORE P Knopf Vice-Chair
FOR THE G Caroline
GRIEVOR Counsel
caroline, Englemann, Gottheil
Barristers & Solicitors
FOR THE L Johnson
EMPLOYER Counsel
ogilvy Renault
Barristers & Solicitors
FOR THE P Roy
INCUMBENT R Savage
HEARING November 20, 1997
INTERIM DECISION
This case mvolves two gnevances allegmg vIOlations of Article 21 05, the
promotIOn provIsIOns of the collective agreement. The gnevors allege that the Employer
has erred m the way It determmed who would be the successful Job applicant m the case of
two promotional opporturutles for Store Manager m a "e" store At the outset of
proceedmgs, a prelimmary Issue arose between the parties concernmg productIOn.
Pursuant to a subpoena Issued to the Employer, the Uruon was seekmg the followmg
documentatIOn.
The complete contents of each file for Job competitIOns ER 84/96 and 95/96
mcludmg all matenals relied upon by the selectIOn panels, mcludmg all
completed Job questIOnnaires, the selectIon cntena employed, all mtervlew
notes, the results of all mtervlews and those parts of the personnel records
of all candidates relatmg to either or both of the noted Job competitions.
The Employer was reslstmg the production of these documents Accordmgly, the parties
made submtsslons on tlus prelimtnary Issue
In order to set the context, the Board was prOVided with a bnef summary
of the background and Issues that would be put forward m the presentatIOn of the ments
of the case
There were two promotIOnal opporturutles avaIlable for pOSitIOns of Store
Manager m two separate locations. In order for the Employer to deCide who should be
selected, the Employer reviewed all the applIcatIOns that were received m response to the
postmg, the employees' personnel appraisals, their personnel files, as well as their
disCipline and attendance records On the basIs of tlus, five mdlvlduals were selected for
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mtervlews The Employer was willmg to grant the positIOns to the two semor applicants
who achieved a score of greater than 60% m the mtervlew NeIther of the gnevors scored
above 60% and therefore were not granted the positions. The mcumbents have lesser
semonty than the gnevors, but scored over 60% The Umon alleges that this violates
Article 21 05 of the collective agreement by glvmg Improper weight to the mtervlewmg
process. Further, the Umon alleges that the process and the selection method were
unreasonable The Umon also alleges that the mtervlew was conducted m an unreasonable
manner Further, the Umon asserts that the gnevors were quahfied for the positIOn and
that the collective agreement was Violated when their semonty was not used as the
determmIng factor m the promotIOn decIsion.
The Umon seeks productIon of the documentation lIsted above m the
subpoena. The Umon asserts that the mformatlOn contained m that documentatIOn will be
arguably relevant, has been slgmficantly partlculanzed, IS not bemg sought by way of a
"fishIng expedition", IS clearly connected to the matter at hand and will not cause undue
prejudice to the Employer It was submItted that the gnevance IS broad enough to cover
the method that the Employer used m decldmg whether the gnevors are qualIfied and
should be promoted. It was said that the ments of the mqull)' will centre upon the
reasonableness of the Employer's decIsion to give so much weight to the mtervlew and the
reasonableness of the assessment Itself In terms of the Interview, the Umon seeks to
challenge the composItion of the selectIon commIttee, Its conduct dunng the mtervlew and
the questIOns whIch were asked. In addItIon, the weight that was aSSIgned to the answers
will be challenged. It was argued that the documentatIOn bemg sought will cover all these
Issues and IS therefore relevant. In support of Its pOSItIon the Umon relIed on the
follOWIng authontles Children's Aid Society of City Belleville, County of Hastings and
City of Trenton and CUPE Loca/2197 (1994),42 L A.C (4th) 259 (Bnggs), The Crown
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in Right of Ontario (Ministry of Transportation) and OPSEU (1996), 54 L AC (4th) 1
(Kaufman)
In response, the Employer asserted that the Union IS Incorrect In the
allegation that the Employer rehed solely on the mtervtew to determme who would receive
the promotion. The Employer's position IS that the factors of seruonty, performance
appraisal and expenence were considered m deternurnng who should receive the mtervlew
Thereafter, It was the performance at the 10tervlew that deternuned the quahficatlOns
Because of thiS, the Employer argues that the request for productIOn goes beyond what IS
appropnate. It was asserted that If the UOlon IS correct that the Employer gives 100%
rehance on the 1Otervlew, then the UOlon would have no need for the personnel files of
other apphcants because they were only considered in the assessment of who ought to be
10tervlewed
The Employer also objects to the release of the personnel files of
10dlvlduals other than the gnevors. Refemng to the Freedom of Information and Privacy
Act, R. S 0 Chapter F 31, It was po1Oted out that the personal 1OformatlOn of employees
cannot be revealed unless It IS relevant to "a fair detenmnatlon of nghts affect10g the
person who made the request", SectIOn 21 (2)( d) On thts basIs, It was argued that while
the personnel records of the gnevors may be relevant, It IS mappropnate to seek the
release of the personnel records of anyone other than the gnevors. Further, because the
Employer's positIOn IS that the key Issue 10 the case IS how the gnevors performed at the
1Otervlew, matenal about other mdlvlduals IS not relevant to thiS case
Further, the Employer accuses the Urn on of engaging m a fishtng
expeditIon to deternune whether eVIdence IS available to support the allegations m the
gnevance
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The Employer also objects to the production of the questIOnnaires used by
the selection panel It was pomted out that these questionnaires were carefully developed
by hav10g regard to the cntena in the job postmgs. This 1Ovolved a great deal of time and
effort on behalf of the Human Resources staff of the Employer These questIOnnaires are
used 10 all job competitions for this type of position. The Employer IS concerned that the
10tegnty of the 10tervlew process will be Jeopardized If the questIOnnaires are released and
available for the Umon or others to be able to scrutmlze It was said that tlus could give
an unfair disadvantage to others m the context of a future mterview Accordmgly, the
Employer asked that the questIOnnaires not be ordered to be produced In the alternative,
It was suggested that conditions on the productIOn be Imposed so as to protect the
confidence of the process and the pnvacy of the questions The Employer rehed on the
follow1Og cases OPSEU (Chuan/Prommer) and Ministry of Community & Social
Services, GST Files 1438/91 and 1439/91 (Samuels) dated April 7, 1992, Bell Canada
and Communications Workers of Canada (1980),25 L.A.C (2d) 200 (P C Plcher),
O'Brien and Ministry of Correctional Services, GSB File 1948/93 et al dated July 27,
1994 (Finley), University of Saskatchewan and University of Saskatchewan Faculty
Association (Archer) (1995), 59 L A.C (4th) 273 (Shapiro) and Jackson et al and
Ministry of Housing, GSB File 130/90 dated June 19, 1991 (Gorsky)
By way of reply, the Umon mdlcated ItS willingness to abide by the type of
conditIOns the Employer was seekIng In order to protect the secrecy of the questions. But
the U mon stressed the Importance of the release of such documentatIOn In order that there
be a fair enquiry mto the reasonableness of the mtervlew process Nonetheless, the Umon
mdlcated ItS surpnse that the Employer would conSider It appropnate to use the same
questions m subsequent mtervlews
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Decision
There IS no dispute between the partIes over the fact that the Board has the
power to order the pre-heanng production of documents But thIs IS an exercIse of
dIscretIon requlflng the balancmg of several nghts whIch mclude the nght to pnvacy and
the nght of a full and faIr heanng. The determmatlOn of what mformatlOn ought to be
ordered to be produced must be made on a case by case basIs It depends on the nature of
the dIspute, the desIre to mamtam control over the proceedmgs, and the desIre to mmlmlze
both the dIsruptIon m operations and any mvaslon of pnvacy Hence, all the cases cIted by
both partIes mdlcate arbItrators' mtentlons to act "JudICIOusly" m ordenng productIon of
mformatlOn. In the case at hand, the documents bemg requested have been sufficIently
partlculanzed and the documents have been requested m a tImely fashIon. The Issues are
whether or not the documents are relevant, whether they are bemg sought as part of a
fislung expedItIon or whether productIon would unduly prejudIce the Employer
The first matter to consIder IS that of relevance When the Issues that will
be raIsed In tlus case are compared to the documentatIon bemg requested, It must be
concluded that all the documents bemg sought will be relevant to the Issues at hand It IS
true that the case, as charactenzed by the Employer, would make only the qualIficatIOns of
the gnevors relevant because thIS collectIve agreement's promotIon clause IS not a
competItIve clause. It IS also true that the Employer's case would requIre only an
exammatlOn of the gnevors' performance at the mtervlew and no companson of theIr
qualIficatIOns, performance or overall SUItabilIty With the other mtervlewees. However,
the Uruon charactenzes the case m a much broader way The Umon seeks to attack the
reasonableness of the process, the weIghtmg of the mtervIew, the reasonableness of the
deCISIon and seeks a remedy wluch would award the jobs to the gnevors. All the relevant
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documentatIOn touches directly on the questions bemg raised by the Union's
charactenzatlon of this case Further, all the documentation bemg requested would be
easIly foreseeable as eVidence that would be relevant to the case of the gnevors or the
Employer at any given pomt. For all these reasons, the documents must be considered to
be relevant to the determmatlOn of the Issues raised by these gnevances.
The next question IS whether the Union's request for production amounts
to a fishmg expedition. The Union candidly adrrutted that some of the documentatIOn
contams mformatlOn that IS not otherwise known to the Union at tlus time Indeed, that IS
partly why the documents are bemg requested. But the concept of a "fislung expedition"
m the legal context ImplIes a search for documentation for the sake of a search, or a
request that IS bemg made for the sole purpose of determining whether a case can be made
out agamst the Employer In the situation at hand, the mformatlon wluch IS bemg
requested IS solely wltlun the control of the Employer The Information IS relevant to the
Issues bemg raised. The documentation bears directly on the essence of the dispute and
goes no further than IS necessary for the Union to be able to present ItS own case and
challenge the appropnateness of the Employer's actions For all these reasons, It must be
concluded that the Uruon IS not engagmg m a fislung expedition by the request for these
documents.
Finally, we must address the questIOn of prejudice In tlus regard, It IS
Important to lOOK at both the Issues of pnvacy and any Impact that the release of the
documentation would have on the Employer It IS Important for an arbitratIOn board m a
case such as thiS to protect the pnvacy of mdlvlduals who wIll be affected as much as
possible The Protection of Privacy Act puts 5tnct hrrutatlOns on an employer regardmg
the release of documentatIon deahng With personal InformatIOn about an employee But
the Privacy Act also enables a tribunal such as thiS to compel the production of
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documentation that IS available and appropnate to a party In htlgatlOn (Section 64) I have
ruled above that the documentation beIng requested IS both appropnate and necessary to
be produced for the proper conduct of a heanng Into these gnevances Any concerns
about the pnvacy of Individuals other than the gnevors can be protected by way of
ensunng that there IS no release of confidential mformatlon m the deCISion that IS bemg
published. Further, the UnIon has undertaken to protect the confidentialIty of the
documentatIOn It obtains
There IS also concern about any prejUdICe that may be caused to the
Employer If the questIOns bemg used In the selectIOn intervIews become avaIlable to the
UnIon and could thereby JeopardIze the mtegnty offurther competItIon mtervIews It
must be remarked that It IS unusual for an employer to use the same questIons m a senes
of Job competItIOns Although It IS difficult to deSIgn a set of questIons to fit the cntena of
a Job, It IS not Impossible to redesIgn the questIOnnaIres so that no one IS gIven a greater
advantage havmg been asked the questIOns In prevIous competitIOns
But m consIdenng tlus matter, It must be concluded that the Employer's
concerns do not outweIgh the need for the questions that were asked at the IntervIew to be
subjected to scrutmy m thIS heanng. The IntervIew was, by the Employer's admtsslOn, a
key deCISIOn m decIdmg whether or not these gnevors were qualIfied. The mtervIew must
be subject to analysIs m the heanng. Full scrutmy of the mtervIew IS necessary for a full
and falr hearing for all partIes concerned. Agam, the UnIon has undertaken to respect the
Employer's concerns about the use of thIS documentatIon. The UnIon has voluntarily
agreed to the condItIOns the Employer has sought regardmg the control of the
documentation. Accordingly, I have concluded that It IS both necessary and appropnate to
award productIon of these documents
,
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For all these reasons, I have ordered compliance WIth Schedule A of the
subpoena Issued to the Employer with respect to the five candidates 10 the Job competitIOn
who were mtervlewed ThIs order was given orally on November 20, 1997 and was
Immediately complied with by the Employer This decIsion confirms and explams the
reasons for such an order The matter IS adjourned to dates agreed upon by the parties.
ThIs Vice-ChaIrperson remams seIzed wIth the matter
DATED at Toronto, Ontano, thIs 1st day of December, 1997
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~ i Paula Knopf - Vi~~-ChaJ.rperson