HomeMy WebLinkAbout2019-2537.Complainant.20-12-10 Decision
Crown Employees Grievance Settlement
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Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
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Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB#2019-2537
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
The Association of Management, Administrative and Professional
Crown Employees of Ontario
(Complainant)
Association
- and –
The Crown in Right of Ontario
(Treasury Board Secretariat) Employer
BEFORE Owen V. Gray Arbitrator
FOR THE
ASSOCIATION
Marisa Pollock
Goldblatt Partners LLP
Counsel
FOR THE EMPLOYER
FOR CANADA LIFE
Caroline Cohen
Treasury Board Secretariat
Legal Services Branch
Senior Counsel
Dan Shields
Shields, O’Donnell MacKillop
HEARING
Counsel
November 25, 2020
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Decision
[1] This decision deals with a dispute between the parties concerning pre-hearing
production of documents by the Employer. In part, the dispute concerns an Underwriting
Agreement between the Employer and Great-West Life (now Canada Life) dated
November 13, 1997, of which the Employer has produced a copy with some portions
redacted. The Association’s concern about the redactions led to the scheduling of a
hearing. Canada Life says that the redacted portions of the document should remain
redacted because they contain proprietary information and should be kept confidential.
The employer supports that position. There is a dispute about whether Canada Life
should be permitted to formally intervene on this issue. However, the Association did
not oppose the informal participation of counsel for Canada Life in the hearing.
Discussions in that hearing narrowed the production issues as I record here.
Context
[2] The proceeding in which the production issues arise is the arbitration of a dispute
filed by the Association concerning the Employer’s dismissal of the complainant on or
about October 2, 2019. In its letter dismissing the complainant, the employer said that
the complainant had submitted false claims “through Great West Life (GWL)” in relation
to his coverage under what the letter described as “the OPS benefit plan administered
by GWL.” In making its decision to dismiss the complainant, the Employer relied in part
on admissions allegedly made during a meeting the complainant had with a GWL
representative on or about March 8, 2018.
[3] One basis of the Association’s challenge to the dismissal is that the complainant
was not notified of his alleged right to representation by an Association representative at
the meeting with the GWL representative. It says that that right arose under Article 7.1
of the parties’ collective agreement, which provides:
7.1 Where a supervisor or other Employer representative intends to meet
with an employee:
(a) for disciplinary purposes; or
(b) to investigate matters which may result in disciplinary action; or
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…
the employee shall have the right to be accompanied by and
represented by an Association representative. The Employer shall
notify the employee of this right and set the time and place for the
meeting.
The Association says that the GWL representative was an “Employer representative”
within the meaning of Article 7.1, by virtue of the nature of the relationship between
GWL and the Employer. It characterizes that relationship as an “Administrative
Services Only” arrangement in which GWL administers a plan under which risk and
liability for payment of the benefits rests entirely with the Employer. The Employer
denies that the GWL representative was an “Employer representative” under Article 7.1
on the occasion in question. It also disputes that its relationship with GWL concerning
the benefits in question was an “Administrative Services Only” arrangement.
[4] The Association is troubled by the Employer’s denial of its characterization of the
arrangement, because the relationship was characterized that way in Union Grievance,
2005 CanLII 54840, and Union, 2009 CanLII 15416. At this point, however, I am not
called upon to determine whether either of those decisions precludes the Employer’s
denial here. Nor am I called upon to determine at this point whether proof that the
arrangement is as the Association says would be proof, without more, that the
complainant’s meeting with the GWL representative was one to which Article 7.1
applied. The issue at hand is the scope of the Employer’s obligation to produce
documents arguably relevant to the issues in dispute in these proceedings, including the
nature of the relationship between the Employer and GWL at the relevant time.
[5] In correspondence with Employer counsel prior to the hearing, AMAPCEO
counsel said
AMAPCEO seeks production of the current policy, all documentation delineating
the responsibilities of the insurance company and the employer, all
documentation showing who bears the risk and liability for payment of benefits
and all documentation showing payments made to the insurance company by the
employer and the reason for those payments.
[6] As a result of discussions in the hearing, there seems to be no dispute that the
Association is entitled to production from the Employer, prior to a hearing on the merits
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in this proceeding, of all documents in the Employer’s possession, custody or control
that are arguably relevant to any matters in issue.
[7] It seems common ground that the benefits in respect of which the complainant is
alleged to have submitted false claims are benefits under what the collective agreement
describes as “Supplementary Health and Hospital” coverage. There seems to be no
dispute that the Association is entitled to production of the “current policy” with respect
to that coverage. Employer counsel believed she had produced the “current policy” to
AMAPCEO counsel. The Association believed that she had not, because documents
produced contained benefit descriptions that did not appear to it to be “current.” The
parties agreed that “current policy” in this context would not necessarily refer just to a
single document labeled “policy” but, rather, to the collection of documents (however
labelled) that, when read together, set out the policy terms in effect at whatever time is
regarded as “current” time. For purposes of these proceedings the current time would
be any time in the period or periods in respect of which the Employer alleges that the
complainant submitted false claims.
[8] There seems to be no dispute that a document would be arguably relevant and
producible if and to the extent that it delineates the responsibilities of the insurance
company and the employer in respect of Supplementary Health and Hospital coverage
as of the time of the impugned meeting between the GWL representative and the
complainant, including any document that shows who, as between GWL and the
Employer, bore the risk and liability for payment of benefits in respect of that coverage
as of that time. The Association acknowledges that anything that specifies only how the
insurance company is compensated for its services in administering that coverage
would not be relevant, and that “documentation showing payments made to the
insurance company by the employer and the reason for those payments” would only be
relevant if and to the extent that they fall within the description of relevant documents in
the preceding sentence. It also appears the Association is content that portions of
otherwise relevant documents be redacted if the redacted contents are not are not
themselves either arguably relevant as aforesaid or needed to understand the arguably
relevant portions.
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[9] Part of the Association’s concern about the redactions arose from its inability to
find in the document the “no-risk provision” to which the following unredacted portion of
the Underwriting Agreement seems to refer:
Risk Charges
The Company will waive the risk charge due to the no-risk provision.
Neither the Employer nor Canada Life could identify anything in the unredacted text that
could be the “no-risk provision” to which this refers. They had a similar difficulty when I
asked about the “Hold Harmless” provision to which the following passage refers:
The obligation of the Group Policyholder is to pay premiums as due under the
policy numbers referred to above, and to comply with the terms of the “Hold
Harmless” provision as outlined by the underwriting basis in this agreement.
Although there is a provision under which GWL agrees to indemnify and save the
Crown harmless with respect to certain claims that might arise from GWL’s conduct,
neither the Employer nor Canada Life could identify in the unredacted text any provision
that is either entitled “Hold Harmless” or could be said to impose on the Group
Policyholder (that is, the Employer) an obligation to hold GWL (or anyone) harmless.
[10] In any event, the Employer and Canada Life say that nothing in the redacted
portions of the Underwriting Agreement produced by the Employer could be
characterized as being the, or a, “no-risk provision,” or as creating or defining the, or a,
“hold harmless” obligation of the Employer.
[11] It appears that if the redacted portions of the Underwriting Agreement are as they
were described to her before and during the hearing, AMAPCEO counsel is content that
they remain redacted, but may wish there to be a process to verify that the redacted
portions are as they have been described. It may be that the Employer wishes to redact
portions of other producible documents that it has not yet produced, to similarly protect
commercially sensitive information, or information about benefits recipients, that is not
itself relevant. It seems premature to devise and enter into a process to review the
propriety of redactions until the Employer has produced all the documents it intends to
redact.
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[12] As I understand it, Employer counsel is of the view that there are categories of
document in its possession that are repetitive with respect to arguably relevant matters
– that is, that the evidentiary value of any one document in the category would be the
same as any of the others, which would differ only in irrelevant details – and she would
like to have the option of procuring example documents in those cases.
Order
[13] In these circumstances, I order and direct that, with respect to “Supplementary
Health and Hospital” coverage referred to in the collective agreement, the Employer is
to produce to Association counsel
a) the document or documents in its possession, custody or control that constitute
the insurance policy or policies current during the period in issue, as described in
paragraph 7 above, and
b) all documents in its possession, custody or control delineating the responsibilities
of GWL and the Employer with respect to that coverage as of March 2018,
including all documentation showing who bore the risk and liability for payment of
benefits under coverage at that time.
[14] In the event that the Employer wishes to redact document contents that it
considers either a) legally privileged from production, or b) irrelevant and sensitive, it
may do so provided that it also provides a written description of each redacted portion
sufficient to show which of these two bases for redaction is relied upon and the facts
that it says support redaction on that basis. Such a description shall also be provided
with respect to each of the redactions in the Underwriting Agreement already produced,
or in any less redacted copy of that document that it may choose to substitute. In the
event that the Association challenges any redaction, there will be a further hearing to
deal with such challenges.
[15] In the event that the Employer considers the relevant content of a producible
document or documents to be the same, in substance, as that of another document that
it has produced or intends to produce, it need not produce such duplicative document(s)
for the time being, provided that it produces a written description of each such
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unproduced duplicative document sufficient to identify the differences between the
duplicative document(s) and the produced document said to exemplify them sufficient to
show why the Employer says those differences are irrelevant. In the event the
Association thereafter nevertheless demands production of any allegedly duplicative
document and the Employer resists production, there will be a further hearing to deal
with such disputes.
[16] The production of documents pursuant to this order shall be treated as subject to
an undertaking by the Association on its own behalf and on behalf of the complainant
that they will be used only for the purpose of these proceedings and for no other
purpose.
Dated at Toronto, Ontario this 10th day of December, 2020.
“Owen V. Gray”
Owen V. Gray, Arbitrator