HomeMy WebLinkAbout2003-0001.Union.09-03-04 Decision
Commission de
Crown Employees
Grievance Settlement
règlement des griefs
Board
des employés de la
Couronne
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GSB#2003-0001
UNION#2003-0999-0012
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association
Association of Management, Administrative and Professional Crown
Employees of Ontario
and
Ontario Public Service Employees Union Union
(Union)
- and -
The Crown in Right of Ontario
(Ministry of Government Services)
Employer
BEFOREChair
Susan L. Stewart
FOR OPSEU
Kate Hughes
Cavalluzzo Hayes Shilton McIntyre & Cornish LLP
Counsel
FOR AMAPCEOLorne Richmond
Sack Goldblatt Mitchell LLP
Counsel
FOR THE EMPLOYER
Brian Loewen
Ministry of Government Services
Counsel
HEARINGFebruary 17, 2009.
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Decision
[1]At issue before me is a request by AMAPCEO and OPSEU for interim relief. The
request arises in the context of a challenge to new security checks for employees that
originate in new rules under the Western Hemisphere Travel Initiative. The bargaining
agents have raised a number of objections to the new security checks and point out that
there is a comprehensive existing OPS Personnel Screening Checks Policy that does not
contemplate the security checks that are being proposed here. It is argued that the security
checks should not proceed pending the resolution of the challenge to the validity of the
checks. The Employer did not dispute that there is an arguable case in this instance and
thus the question to be addressed is where the balance of convenience or harm lies.
[2]At the conclusion of his submissions Mr. Loewen, on behalf of the Employer, requested
that I delay the issuance of my decision on this motion, pending further discussions
between the parties to attempt to resolve the dispute. I granted Mr. Loewen?s request and
advised the parties of my intention to issue my ruling on March 4, 2009, unless I was
advised beforehand that the parties had resolved this issue. I was advised on March 3,
2009 that the parties had not resolved the matter and that a ruling on the motion was
required.
[3]The Western Hemisphere Travel Initiative has been established by the United States
Department of Homeland Security and relates to documents required for travelers
departing from or arriving from ports of entry within the western hemisphere. Since
January 23, 2007, a passport has been required to enter the United States by air.
Effective June 1, 2009, new requirements will extend to land and sea ports of entry. An
alternative to a passport acceptable to the Department of Homeland Security is a
document establishing the bearer?s identity and nationality that meets their prescribed
security standards. Those security standards include requirements relating to security
checks for personnel involved in the production of those documents. As would be
anticipated, this is a matter that has been addressed between the Department of Homeland
Security, the Federal Canada Border Services Agency and Citizenship and Immigration
Canada and in turn has been addressed between the Government of Canada and the
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provinces, including the Province of Ontario. There is a draft Memorandum of
Understanding between the Government of Canada and the Province of Ontario, however
as of the date of the argument on the interim relief motion it had not been finalized.
Notwithstanding the obvious vigour with which the matter has been pursued by counsel
for the Employer, production of documents relevant to the dispute has been hampered by
virtue of the fact that there have been issues of sensitivity of information and the need to
follow protocols for release in relation to documents to which other governments are
signatories.
[4]An Enhanced Driver?s Licence and an Enhanced Photo Card have been developed by the
Ministry of Transportation, ServiceOntario, and the Cabinet Office-Intergovernmental
Affairs, in collaboration with the Government of Canada. This document has been
developed as an alternative to a passport, which will meet the Department of Homeland
Security standards. While there will be an additional cost associated with the acquisition
of an Enhanced Driver?s Licence in comparison to a regular Licence which will still be
available, the cost will be less than the cost of obtaining a passport. The Employer,
noting that it is anticipated that the new requirements will have a significant impact on
cross border land travel, where most travelers have used documents such as driver?s
licences and/or birth certificates, wishes to ensure that travel and trade are not disrupted
and wishes to ensure that its citizens who would like to obtain documentation which will
be an acceptable alternative to a passport are able to do so prior to the June 1, 2009
effective date of the new rules for land border crossings.
[5]In connection with the implementation of the Enhanced Driver?s Licence Program,
employees and bargaining agents have been advised as follows with respect to security
checks:
The Government of Canada requires that all employees
who can manipulate EDL records, process EDL applications
or produce and handle EDL cards have to meet the Government
of Canada?s personnel security requirements for their employees
using similar types of documents (e.g. a passport). They are
requiring that Ontario implement a two-step process:
A reliability check, conducted by the province, consisting
of a criminal background check and a financial (credit)
check.
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A Level 2 (secret) security check conducted by the Canadian
Security Intelligence Service.
The new security checks have also been described as consisting of three components: a
Criminal Records Name Check, Credit Check and Canadian Security Intelligence Service
(CSIS) Indices Check.
[6]In the course of their submissions, counsel for the bargaining agents emphasized that the
issue of interim relief in connection with the Employer?s intent to implement security
checks was previously addressed by me and their request for relief granted, in Ontario
th
(Management Board Secretariat) and OPSEU (2003), 117 L.A.C. 4 128 (Stewart). Both
Ms. Hughes and Mr. Richmond emphasized the considerations of privacy at issue and
that as noted in that decision, incursions of privacy cannot be reversed if the position of
the bargaining agents were ultimately to prevail. Reference was also made to the
involvement of CSIS in the security checks program and that it is a federal agency
beyond provincial regulation.
[7]In his submissions, Mr. Loewen emphasized that the requirements with respect to
security checks has been imposed on the Province and that the Province must operate
within the framework that has been imposed. He made reference to the statutory
framework within which CSIS operates, as well as the fact that there is an agreement
being developed between the Province and CSIS (in draft at the time of the motion) that
he submitted will address concerns raised by the bargaining agents. Mr. Loewen
emphasized that the timing of the effective date of the new requirements for
documentation for border crossing, June 1, 2009, is a matter beyond the Province?s
control. He argued that a delay in the ability to implement security checks will
jeopardize the Province?s ability to meet its objective of reducing the impact of the new
initiative by allowing its citizens to obtain acceptable documentation at a lower cost than
if they had to obtain a passport.
[8]The Employer?s interest in proceeding with the security checks with dispatch is
understandable, in that security checks constitute an important element in its preparation
to have the EDL program in effect before June 1, 2009. Its objective is clearly motivated
by a wish to provide the best possible service to the citizens of the province and to make
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the transition to the new regime of land border crossing to the United States as seamless
as possible. However, as the bargaining agents have noted, even if the EDL program is
not in place before June 1, 2009, citizens of Ontario will still be able to cross the border
to the United States with a passport, just as is currently the case with the relatively recent
requirement in connection with air travel. The interests of the Employer, while real and
understandable, must be balanced against the concerns advanced by the bargaining
agents. They have raised concerns that, as noted in my earlier decision granting interim
relief, cannot be effectively remedied on a retroactive basis in the event that the
bargaining agents are ultimately successful in their challenges.
[9]With the cooperation of the bargaining agents, an early date has been established to deal
with the merits of the case. The parties have been successful in resolving issues relating
to security checks in the past and I have no doubt that they will continue to work
diligently to achieve a prompt resolution in this case, whether by settlement or through
the adjudicative process. It is my view that a weighing of the balance of convenience or
harm in this case clearly compels the conclusion that the Employer ought to be precluded
from proceeding with the proposed security checks pending the resolution of the dispute
on its merits and I so order.
th
Dated at Toronto this 4 day of March 2009.
Susan L. Stewart, Chair