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Dear Mr. Larocque:
This letter will confirm that the Union has increasing concerns with respect to the manner in which the Company is utilizing GPS technology in the organization. Please find enclosed a copy of the PIPEDA Case Summary 2006-351 which outlines the position of the Office of the Privacy Commissioner of Canada concerning the utilization of GPS systems by an employer.  As you will note, the case involved employees of a telecommunications company who had concerns when they learned their employer had installed GPS units in their vehicles.

There are instances that have come to the attention of the Union that suggest that the employer is utilizing GPS in order to monitor the movements of employees. This monitoring is contrary to the directions issued by the Office of the Privacy Commissioner and represents an improper utilization of the technology. The Commissioner concluded that utilizing GPS technology to evaluate work or performance, based on assumptions it has drawn from GPS information, impinges on individual privacy.

In order to resolve this matter, the Union will require the written assurance from the Company that it will only utilize GPS technology in a manner that is consistent with the recommendations made by the Office of the Privacy Commissioner of Canada. In particular, the Union expects BTS to be zealous in its efforts to prevent “function creep” as outlined in the findings of the Office of the Privacy Commissioner.

The Union looks forward to receiving your written response with respect to this matter. If we do not hear from you, the Union will have no alternative but to initiate legal proceedings with respect to these issues.

Yours truly,

Sean Howes,

National Representative.

SH:lmc/cope-343
cc: Barb Dolan-Administrative Vice President, National Representatives servicing BTS
BTS Local Presidents and Unit Chairs

PIPEDA Case Summary #2006-351
Use of personal information collected by Global Positioning System considered

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