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Anticipate questions.                their  acceptable  use  policies  to  their  aspects  of  network  security  and
        Although    a   monitoring   policy  new  electronic  monitoring  policies  information governance.
        does  not  need  to  be  too  detailed,  such  that  their  new  policies  become   Member  businesses  will  have
        employers      should     anticipate  the single document that establishes  to  incorporate  a  policy  in  their
        employee  questions  and  prepare  employees’  expectation  of  privacy.  employee policy manuals that details
        to  be  transparent.  For  example,  Since  the  Supreme  Court  of  Canada  how  the  company  is  monitoring
        employees  may  ask  if  an  application  decision  that  recognized  a  limited  employees  on  their  activities  on
        is hosted on premise or in the cloud,  employee  expectation  of  privacy  business  computers,  cell  phones
        and where cloud data is stored.                                           and  in  company  vehicles  if  such
                                                                                  monitoring  is  being  implemented.
        Update your asset map.                     "Bill 88 imposes new           You  will  be  required  to  ensure  all
        Every  employer  ought  to  employ                                        employees  are  aware  of  the  policy
        “information    technology    asset       requirements, but also          including new hires.
        management”    –   a   process   for      creates an opportunity            For  those  businesses  that  employ
        governing  their  network  hardware                                       less  than  25  people,  you  are  not
        and  software.  Organizations  with       to revisit and improve          required  to  have  a  written  policy;
        strong  asset  management  practices        several key aspects           however  it  would  be  suggested  that
        will  have  little  difficulty  identifying                               you ensure your employees are aware
        how  employees  are  “monitored.”  For      of network security           of  any  electronic  monitoring  you  are
        employers with less than strong asset                                     conducting such as GPS on vehicles.
        management  practices,  Bill  88  is  an     and information
        invitation  to  improvement  and  the          governance."
        rooting out unmanaged applications.
        Update your acceptable use policy.    (in  R  v.  Cole),  we  recommend  that
        Given  the  new  electronic  monitoring   employers  stipulate  all  purposes  for
        policy  may  need  to  be  produced  to   which  they  may  require  access  to
        prove  compliance,  it  is  best  written   network  data,  including  information
        as  a  stand-alone  policy,  and  an   in user accounts – e.g., to maintain the
        adjunct  to  any  existing  “acceptable   network,  to  investigate  misconduct
        use  policy”  –  a  policy  that  sets   and to support the continuity of work.
        enforceable  rules  for  employee  use
        of  a  network.  It  is  a  suitable  time,   Bill 88 imposes new requirements,
        however,  to  update  acceptable  use   but  also  creates  an  opportunity
        policies.  Employers  should  consider   to  revisit  and  improve  several  key
        moving  the  privacy  provision  from








            INDEX TO ADVERTISERS



            AFA Forest Products ..................................................inside front cover  Nu-Forest Products (Canada) Inc. ......................................................15
            Atlas Polar ......................................................................................................7  Polytarp Products ................................................................................................13
            Castle Building Centres Group ..........................outside back cover  Programmed Insurance Brokers Inc. ..........................................................15
            Groupe BMR ..................................................................................................5  Sellick Equipment ...............................................................................................11

            LBMAO Directory App ............................................................................19  Taiga Building Products .......................................................................................9
            Nicholson and Cates Limited ................................inside back cover  TORBSA Limited ...................................................................................................18





        22  LBMAO Reporter - May-June 2022                                                           www.lbmao.on.ca
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