HomeMy WebLinkAbout2010-2045.Union.12-07-10 DecisionCrown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB#2010-2045
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association of Management, Administrative and
Professional Crown Employees of Ontario
- and -
Ontario Public Service Employees Union
(Union)
Association
Union
- and -
The Crown in Right of Ontario
(Ministry of Government Services) Employer
BEFORE Susan L. Stewart Chair
FOR THE UNION Kate Hughes
Counsel for OPSEU
Cavalluzzo Hayes Shilton McIntyre & Cornish LLP
Barristers and Solicitors
Lorne Richmond
Counsel for AMAPCEO
Sack Goldblatt Mitchell LLP
Barristers and Solicitors
FOR THE EMPLOYER Benjamin Parry
Ministry of Government Services
Labour Practice Group
Counsel
HEARING June 28, 2012.
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Decision
[1] This decision follows upon a decision dated June 30, 2011, relating to
the Phase 3 implementation of the Ontario Public Service Personnel Screening
Checks Policy (“the Policy”). Phase 3, as set out in Appendix B of the Policy,
provides for “Harmonization of screening check processes in areas of the OPS
that currently conduct screening checks” and, in relation to the date of
implementation, provides: “Following Cabinet Approval (To be phased-in by
ministry after January 2006)”.
[2] The position of AMAPCEO and OPSEU as described in the June 30, 2011
decision was that: “although a date for Phase 3 is not specifically prescribed,
the fact that in late 2010 the harmonization of pre-existing security check
processes has not commenced could not have been in the reasonable
contemplation of the parties”.
[3] I accepted the position of the bargaining agents with respect to the
obligation of the Employer to commence harmonization, but concluded that it
would be inappropriate for me to order further relief at that time, noting that
the Employer had provided a plan to begin the harmonization process. At the
commencement of the hearing on May 31, 2011, the Employer had presented
the bargaining agents with a written plan for the commencement of
harmonization. I rejected the request of the bargaining agents to establish an
end date for harmonization and further rejected their position that I order that
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any re-checks in areas of pre-existing security checks be conducted in
accordance with the Policy, indicating in paragraph 6 that: “… the process that
the Employer has commenced should be allowed to unfold”. I remained seized.
At that time the process contemplated commencing the harmonization process
with Enforcement/Investigation/Compliance positions.
[4] The Board was subsequently asked to re-convene the hearing and a
hearing date of March 26, 2012 was established. The Employer had
undertaken an extensive review of its approach to security checks and shortly
prior to the hearing date, it provided the bargaining agents with disclosure,
including an audit relating to the Policy which was completed in March, 2012.
In a decision dated March 26, 2012, I directed the Employer to provide full
particulars in writing of the proposed harmonization plan to the bargaining
agents by June 1, 2012. The Board set a further hearing date of June 28,
2012.
[5] Particulars were provided on June 1, 2012, in accordance with my order.
The particulars included a new draft Employment Screening Checks Policy,
accompanied by new Operational Guidelines and a new Risk Assessment Tool.
The implementation process contemplates that all legacy checks would stop no
later than two years from September 1, 2012 and that the central focus of the
plan would be on personnel screening checks at the recruitment stage. I was
advised that the parties have had discussions regarding the new policy,
however, no agreement has been reached. While its components were not
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addressed in detail, the bargaining agents identified certain aspects of the new
policy as fundamentally problematic. The bargaining agents indicated that
they would challenge the policy if it were implemented in its current form. Mr.
Richmond characterized the prospect of its implementation in relation to the
legacy ministries as “disharmonization”, rather than harmonization. Although
the Employer advised that the four tenets that the bargaining agents view as
critical have been incorporated into the current draft of the new policy, the
bargaining agents indicated that from their perspectives, these tenets have not
been incorporated effectively. It was the Employer’s further position that while
the Employer would like to have the agreement of the bargaining agents, its
intention is to proceed with a new policy, which, in its view, accomplishes
harmonization.
[6] At the hearing on June 28, 2012, the bargaining agents sought specific
orders prescribing the immediate commencement of harmonization in
accordance with the March 2005 Policy and Guidelines in prescribed Ministries
or by occupation, and that harmonization be completed in 18 months. As well,
the bargaining agents sought orders requiring that any new legacy security
checks be conducted in accordance with that Policy and that the bargaining
agents be advised in writing every four months of the progress of
harmonization. Counsel for AMAPCEO and OPSEU reviewed the history of this
matter, noting in particular that it has now been over a year since the
declaration and submitted that harmonization needed to be addressed by
specific orders without further delay. Reference was made to the comments in
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the audit report regarding the desirability of alignment of checks in legacy
ministries with the Policy and it was submitted that the orders sought are
consistent with the views of the auditors. On behalf of the Employer, Mr. Parry
referred me back to the jurisdictional argument previously raised and further
argued that it would be premature to make the orders requested, given the
developments that have taken place and the current status of the matter. It
was further argued that any such order could conflict with Cabinet’s statutory
discretion to rescind the existing Policy and implement another. It was the
Employer’s position that the Policy does not reflect a binding settlement on the
part of the Employer and that even if it did, by its terms, the reference at p. 13
to the responsibility for policy development on the part of Cabinet Office
contemplates the authority to develop a new policy. The Employer asked me to
so conclude and to dismiss the requests for orders. If an order were to issue, it
was suggested that I direct that the current Employer proposal proceed. It was
the position of OPSEU and AMAPCEO that the Employer had committed to and
was bound by the existing policy. Given that at this point there is in fact no
policy in place that replaces the existing policy, it was submitted that it would
be appropriate for me to issue the orders requested pursuant to the existing
policy to ensure that the longstanding issue of harmonization is brought to a
timely conclusion.
[7] After considering the submissions of counsel, it is my view that the
Board best serves the parties at this point by neither granting the orders
requested by AMAPCEO and OPSEU, nor granting the Employer’s request for
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what is essentially an advisory opinion in connection with its proposed course
of action. The current circumstances are in a transitory state, with the
Employer’s proposed approach in a draft form upon which further input from
the bargaining agents is welcomed. The draft is recent, the documents are
lengthy and complex, and they were provided in their current version only a
few weeks before the hearing. While there have been some discussions in
connection with the Employer’s draft policy, it is readily apparent that all of the
concepts in the draft have not been fully explored. The draft presented is the
16th
version of the new policy, which is perhaps indicative of the detail and
complexity of the matter. It involves issues of considerable significance and
sensitivity for the Employer and the bargaining agents. Aside from any issue
as to my jurisdiction, it seems to me that the parties are best served by my
deferring any consideration of orders pending an opportunity for the parties to
thoroughly discuss and understand the respective interests and concerns and
attempt to resolve them. I appreciate the legitimate concerns raised by the
bargaining agents in connection with harmonization proceeding with some
dispatch, however movement on the overall issue of security checks seems to
have considerable current momentum. The Employer’s materials indicate a
target date of September 21, 2012 for the approval of the new policy. Of
course, the dispatch that AMAPCEO and OPSEU are seeking is in relation to
harmonization with the existing policy, in relation to which I have made a
declaration. However, the Employer has put forward a position on
harmonization, albeit in a broader context and involving a departure from the
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current policy, but with a view to bringing the issue of harmonization within
legacy ministries to a conclusion.
[8] The parties will or will not come to a mutually satisfactory resolution in
relation to this entire matter, including in relation to harmonization of security
checks in legacy ministries. I continue to remain seized with this matter and
available to deal with it on an expedited basis if a resolution is not achieved. I
refer all issues back to the parties for their review and their best efforts at
resolution.
Dated at Toronto this 10th
day of July 2012.
Susan L. Stewart, Chair