Electronic monitoring policy
A written policy telling employees whether and how you monitor them electronically, such as by cameras, GPS, email or computer tracking.
Also called: employee monitoring policy, workplace surveillance policy, electronic monitoring of employees
What electronic monitoring policy means
An electronic monitoring policy is a written statement that tells employees whether you monitor them electronically, how you do it, in what situations, and why. Electronic monitoring covers more than cameras: it includes GPS in company vehicles, tracking apps on work phones, keystroke or screen software, email and internet logs, swipe-card entry systems and point-of-sale logs that track who did what.
Some jurisdictions require certain employers to have this kind of policy and share it with staff. Separately, privacy laws in some provinces limit what employee information an employer may collect and how it can be used.
Even when no law requires a written policy, transparency helps. Employees who find out about hidden monitoring tend to lose trust, and secret monitoring can create privacy and human rights problems.
How it works
Start with an inventory. List every tool that collects information about what employees do: cameras, vehicle GPS, door access cards, time clocks with photos, monitoring features in your point-of-sale or software, and any apps on company phones. Many small employers are surprised by how much their existing systems already record.
Then decide and write down, for each tool: what it monitors, how and when, the purpose (security, theft prevention, safety, scheduling, productivity), who can see the information, and how long it is kept. Avoid monitoring places where people expect privacy, such as washrooms and change rooms. Collect only what you need for a real purpose.
Share the policy. Give it to current employees and new hires, date it, and update it when you add or change a tool. Tell employees how to ask questions or raise concerns. If you are in a province with a private-sector privacy law, check what notice or consent it requires.
Common mistakes: hidden cameras in staff areas, using GPS data meant for dispatch to discipline someone for a coffee stop without having told them it could be used that way, keeping footage forever, and letting anyone in the business view recordings.
Electronic monitoring policy by province
Only some jurisdictions require a written electronic monitoring policy, usually based on employee count. Privacy rules for employee information also differ by province.
| Where the work is done | The rule |
|---|---|
| Federal | For federally regulated employers, the federal privacy law PIPEDA covers employee personal information, including information collected by monitoring. |
| British Columbia | The provincial Personal Information Protection Act covers private-sector employers' employee information, and allows some employee information to be collected without consent for employment purposes. |
| Alberta | The provincial Personal Information Protection Act covers personal employee information held by private-sector employers, and allows some of it to be collected without consent for managing the employment relationship. |
| Ontario | An employer with 25 or more employees in Ontario on 1 January of a year must have a written electronic monitoring policy in place before 1 March of that year. It must say whether you electronically monitor employees and, if you do, how and in what circumstances, and the purposes for which the information may be used. The rule does not give employees a right not to be monitored. |
| Quebec | The Act respecting the protection of personal information in the private sector applies to employee information. See the Quebec Law 25 entry. |
Elsewhere, PIPEDA does not cover the employee information of provincially regulated employers. We have not confirmed whether any other jurisdiction requires a written monitoring policy.
Example: Cameras and GPS at a moving company
Ahmed runs a moving company with 14 staff and 4 trucks. He has cameras in the warehouse and loading area, GPS on the trucks and a time clock app on work phones. Until now, none of it was written down.
Ahmed writes a two-page monitoring policy: cameras in the warehouse and yard (not the break room or washroom) for security, kept 30 days; truck GPS for dispatch, routing and safety, which may also be reviewed if a complaint is made about a driver; and the time clock app to record start and end times. Only Ahmed and his office manager can view the data. He gives the policy to every employee and adds it to new-hire paperwork.
Onboarding checklists in Staffkin
Put your electronic monitoring policy on a Staffkin onboarding checklist so every new hire receives it and you can see who has it.
Start freeFree tools and guides for this
Questions about electronic monitoring policy
Can I put cameras in my store?
Generally yes, for legitimate purposes such as security, but tell employees about them, avoid private areas like washrooms and change rooms, and limit who can see the footage.
Do I have to tell employees I track company vehicles?
It is good practice everywhere, and some jurisdictions require a written monitoring policy that discloses it. Check your province's employment standards and privacy rules.
Does a monitoring policy give me new rights to monitor?
Usually not. A policy is about transparency; privacy laws may still limit what you can collect and how you use it.
Related terms
Official sources
- Government of Ontario, Your guide to the Employment Standards Act: written policy on electronic monitoring of employees
- Government of Ontario, ESA Policy and Interpretation Manual, Part XI.1: written policy on electronic monitoring
- Office of the Privacy Commissioner of Canada, Provincial laws that may apply instead of PIPEDA
- Office of the Privacy Commissioner of Canada, Questions and answers on PIPEDA and Alberta's and British Columbia's Personal Information Protection Acts
General information for Canadian employers, not legal advice. Rules differ by province and territory and change over time, so check with your provincial employment standards office (or the federal Labour Program if you are federally regulated) before you rely on it. See employment standards by province.
Checked against official sources on 5 November 2026.