v. February, 2022
1.0 EMPLOYEE PERSONAL INFORMATION
Employee personal information refers to personal information that is reasonably needed to establish, manage or end a work or volunteer relationship with us. Personal information may include, but is not limited to, name, address, telephone number, employee identification number, educational qualifications, social insurance number, and employment history. Employee personal information does not include business contact information or work product information.
Contact information refers to information prepared by the employees in the context of their work or business, but does not include personal information about other individuals. For example, a document prepared and signed by an employee is work product information, but if the document contains personal information about the Employer’s clients, that portion of the document would remain the personal information of the client.
1.2 Collection of Employee Personal Information
Whenever possible we collect your personal information directly from you. However, we may obtain or verify your personal information from other sources, such as previous employers, your references, government agencies and/or educational institutions.
During the course of your employment relationship with the Employer, we may be monitoring and collecting personal information about work performance, which includes monitoring of email, video surveillance and telephone usage.
The law allows us to collect, use and disclose employee personal information without consent if it is reasonable for the purposes of establishing, managing or terminating an employment relationship between us.
Whenever possible, we will ask you to specifically consent, if we collect, use, or disclose your employee personal information. Typically, we ask for your consent in writing, but in some circumstances we may accept your oral consent. Occasionally, your consent may be implied through your employment relationship with us.
1.4 Use of Employee Personal Information
We collect and use employee personal information to verify, establish, and maintain employment relationship. This includes collection of employee personal information necessary to process payroll and administer benefits. Primarily, this information is collected at the time of hire on employee forms that are submitted to the Metro Comptroller.
The purposes for which employee personal information is collected will be identified by us on or before the time the information is collected.
The following is a list of specific employee personal information that we will collect and its purpose:
Employment Application Information: This information will be collected to establish, verify and maintain the employment relationship, including but not limited to payroll and benefit administration.
Work Performance Information: This information will be collected to manage, develop and maintain the employment relationship. It will be used to make decisions about promotion, discipline and/or termination.
Medical Information: This information will be collected (if necessary) to determine benefit eligibility, to determine ability to perform work duties, for administering return to work programs, and for determining suitable alternatives as part of our duty to accommodate our employees.
1.5 Access to Employee Personal Information
The following lists the type of personal employee information and who may have access to it:
Employment Application: This information will be accessible by the general manager, the publisher, direct manager to whom the employee reports to, human resources representative, payroll and benefits administrators.
Work Performance Information: This information will be accessible to the direct manager to whom the employee reports to, and general manager in order to manage employee performance and to support decisions of promotion, discipline and/or termination.
Payroll Information: This information will only be accessible to the direct manager to whom the employee reports to, employees responsible for the administration of payroll, human resources manager, general manager, and the payroll service provider.
Benefit Information: This information will be accessible by employees responsible for the administration of the benefit plan, and the third party benefit provider.
Medical Information: This information will be accessible by employees responsible for the administration of the benefit plan, third party benefit provider, and the manager to whom the employee directly reports.
1.6 Disclosure of Employee Personal Information
Employee personal information will be limited to that which is necessary for the purposes identified by the Employer.
Under certain circumstances, we will disclose your personal information. These circumstances include, but are not limited to, the following:
- When we are required or authorized by law to do so, for example a Court Order requires use to do so;
- At the request of the CRA or Service Canada;
- When you have consented to disclosure;
- When your personal information is available to the public from a prescribed source;
- When the collection, use or disclosure is clearly in your interests and consent cannot be obtained in a timely manner;
- When it is reasonable to expect that the collection, use or disclosure with your consent would compromise the availability or accuracy of the personal information, and the collection or use of the information is necessary for an investigation or proceeding;
- When it is reasonable to expect the disclosure with your consent would compromise an investigation or proceeding and the disclosure of information is necessary for an investigation or
1.7 Security of Personal Information
We will take all reasonable steps to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. As such, employee personal information is stored in secured private areas and is only be accessed by authorized personnel.
1.8 Retention of Employee Personal Information
Employment Applications: Unsolicited resumes of applicants will not be retained, unless a suitable future opportunity is foreseen. In this case, electronic copies of resumes are stored only on our managers’ password protected desktops.
Applicants who are being considered for a position and a decision has been made about their application, will have their information retained for one year.
Former Employees: Information (including payroll records) will be retained for two years, if they are no longer necessary for legal or business purposes.
All of the Metro physical personal files are reviewed for retention or secure shredding, annually. Electronic personal files are culled two years after termination of employment or when such files are deemed as unnecessary.
1.9 Requests for Employee Access to Personal Information
The law permits employees to submit written requests to access and verify their personal information. We will respond to all requests in writing within 30 days of receipt of the same.
Upon written request of the employee, we will provide the employee with the following information:
- Employee personal information under our custody or control;
- Information about how your employee personal information has been used and is being used by us;
- The names of individuals and organizations to which their personal information has been disclosed to and for what
An employee’s ability to access his/her personal information under our control is not absolute. The law stipulates that we must not disclose personal information if:
- The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
- The disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
- The disclosure would reveal personal information about another individual;
- The disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the information does not consent to the disclosure of his/her
1.10 Accuracy of Employee Personal Information
We will make all reasonable efforts to keep employee personal information accurate, complete, and current as possible.
1.11 Procedure for Access to Employee Personal Information
If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of your personal information under our care and control, please contact Marc Gaucher in his capacity as the Privacy Officer. You may refer such items to your store manager, also, if preferred.
If you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If, after our Privacy Officer has reviewed and responded to your concern you remain dissatisfied, you may wish to contact the Office of the Information and Privacy Commissioner at:
P.O. Box 9038, Stn Provincial Government Victoria, B.C. V8W9A4
Telephone: (250) 387-5629
Fax: (250) 387-1696
1.12 Correction of Employee Personal Information
The law permits employees to submit written requests to us as correct errors or omissions in their personal information that is in our custody and control. Upon written request by the employee, we will:
- Correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
- Decide not to correct the personal information, but annotate the personal information that a correction was requested by not
1.13 Privacy Training
As part of the standard Metro Liquor training program for all staff (three full days, plus regular staff meetings), we advise employees that we minimize the collection of their personal data and the personal data of our customers. They understand that such data is only collected where required. Metro policy is to err on the side of caution and avoid collecting personal data unless absolutely required. They understand that they are stewards of customer data, and, as such, they must manage this data as if it was their own.
In addition, as part of the five-day Metro Liquor training program for all managers (five full days, with regular follow-up sessions), we provide education to all managers regarding their responsibility to minimize the collection of personal information and maintain the privacy of such information in secure ways, including password-protecting electronic files and locking filing cabinets for hard copies of employee information.
1.14 Breach Reporting
All of the Metro stores maintain an incident log at each Till and online to document any irregular activities that contravene policies and regulation. Primarily, these relate to our program to avoid serving minors, intoxicated individuals and theft, but our incident log process is used for breaches of privacy, video/website privacy concerns or requests from customers etc. Staff are trained to report any breaches of privacy or related incidents immediately to the store manager.
2.0 USE OF VIDEO SURVEILLANCE CAMERAS/RELATED STORAGE MEDIA
Metro Liquor utilizes video surveillance cameras throughout the store, capturing images of customers and employees 24 hours per day, 7 days per week to help protect the store, employees and customers from criminal activity. Normally, these recordings are stored only for a period of fourteen days, before they are over-written with new data. The DVR’s are located in the manager’s office, password protected, and the door to the office is locked after hours. It is Company policy to post a notice about the use of the cameras visible in the windows, near the entrance of each store stating “Security cameras/video in place throughout the store”, at so that individuals may chose not to enter if they do not wish to consent to being videotaped.
The Company limits the collection, use and disclosure of information collected by the video camera. Cameras are positioned inside the store only, including capturing the images of all individuals entering and leaving the store from every exterior exit.
More specifically, we:
- do not use cameras where people have a heightened expectation of privacy, such as in washrooms and ensure that the set-up of cameras does not allow employees to change or adjust the direction or focus to capture these types of images; the camera angle are stationary
- do not use video surveillance to record personal information such as Driver’s licenses or other personal data
- ensure that the recording is used or disclosed for authorized purposes only such as to minimize and enable verification of illegal activity or store activities that contravene policies and regulations;
- employees, please note that video surveillance is only used in the retail area, warehouse and cooler area and in offices. Video footage may be used to monitor employee compliance to Metro and BCLCRB policies such as refusing service to minors and intoxicated individuals, to monitor employee theft, employee consumption of alcohol or drugs that cause intoxication or other activities that are inappropriate in the workplace. This information may be used for training purposes and to support disciplinary action or employment termination.
- ensure that store managers are trained to understand their obligations under privacy law;
- protect the security of the information;
- ensure, when granting access, that the personal information of others which might be contained in the same recording is protected;
- retain the recording for a minimum of one year if it was used to make a decision about an individual, to enable the individual to request access.
- are ready to answer questions from the public, regarding the purpose of any video surveillance, its use and what is being done with recorded images.
- ensure that individuals whose images are captured on the recording have a right to request access to that recording under privacy laws.
- review our video surveillance program and policies, annually and as required.
Collection, use, disclosure and retention of information must comply with provisions of the Freedom of Information and Protection of Privacy Act and the Document Disposal Act. Collected personal information will only be used by those authorized to fulfil the purpose for which it was originally collected or for a use consistent with that purpose. We do not disclose information to other public bodies or individuals except as authorized by law. We keep the information only for the length of time necessary to fulfil the purpose(s) for which it was collected.
3.1 COLLECTION OF PERSONAL INFORMATION
Personal Information is information about you that identifies you as an individual, for example, your name, address, email address, or telephone number. We collect information that you voluntarily provide to us through when purchasing or in responses to surveys, search functions, questionnaires, feedback, Contact Us forms etc. We may ask you to provide information such as your email address if you want to obtain additional services, information, participate in a contest or to resolve complaints or concerns. For purchases, we will require your phone number, full name, physical address, email address and credit card information. This information is stored on encrypted servers, behind physical and software firewalls, managed 24x7 by our professional IT service provider.
3.2 HOW DOES THE COMPANY USE INFORMATION GATHERED ABOUT ONLINE VISITORS?
Before forwarding us any personal information, please be advised that any information gathered on our Sites may be used in the aggregate for research and development relating to our Sites and/or for future site development and, if you ask us to send you promotional materials. In particular, we may use information gathered about you for the following purposes: to monitor interest in our range of products and to assist us to tailor the content of our Sites to your needs by collecting information about your preferences through tracking of patterns page views on our Sites; to create a profile relating to you in order to show you the content that might be of interest to you and to display the content according to your preferences; and, in circumstances where you have indicated that you wish to receive additional information, to send you information about us and promotional material about our products together with details of any offers we may have available from time to time.
3.3 PROMOTIONAL AND INFORMATIONAL OFFERS
With the permission of an online visitor, information submitted at the time of registration or submission may be used for marketing and promotional purposes by the Company provided notice of this fact is made available online. If a visitor objects to such use for any reason, he/she may prevent that use, either by email request or by modifying the registration information provided. The Company uses reasonable efforts to maintain visitors' information in a secure environment. If you have submitted personal information and want to change it or opt-out, please contact us as described below.
3.4 DISCLOSURE OF INFORMATION
The Company, in common with many web site operators, may use standard technology called "cookies" on its Sites. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser; however, some areas of the Sites may not function properly if you do so.
3.6 PROTECTION OF CHILDREN ONLINE
The Company considers the protection of children's privacy, especially online, to be of the utmost importance. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, our Sites or help-seeking information lines. Our sites are for the use of adults aged nineteen years or older. We ask all users of our website(s) to confirm their age when using our site(s).
3.7 ADDITIONAL TERMS FOR CERTAIN WEBSITES
The following additional information applies to our Sites that require registration. Generally, you are not required to provide personal information as a condition of using our Sites, except as may be necessary to provide you with a product or service that you have requested to purchase.
3.8 PROTECTION OF INFORMATION
3.9 POLICY CHANGE
Metro Liquor Stores
Units 1828-4949 Canoe Pass Way
7180 West Saanich Road
1747 Ross Road, West Kelowna
1175 Ellis Street, Kelowna