Electronic Monitoring Guideline

Date prepared: August 31, 2022
Last updated: October 4, 2022

The University of Waterloo is committed to creating a healthy workplace and we strive to achieve our goal of an employee-focused, sustainable work environment by prioritizing the health and well-being of all employees, including respecting, and protecting employees’ privacy.  

The University of Waterloo uses electronic monitoring for the purposes of safety, information security, resource management, and performance metrics for communications and environmental sustainability. The University does not actively monitor employees using electronic means for the purpose of employee performance management and discipline as a normal course of business. This guideline governs the rules with respect to access to electronic monitoring data, no matter the format. The guiding principle is that electronic monitoring data are to be used for the purpose for which the data are collected, in the proper discharge of the University’s business and operational functions. The use of electronic monitoring data beyond the purpose for which the data are collected is prohibited, except as outlined by this guideline.

This guideline should be read in accordance with any relevant and applicable legislation, including the Electronic Monitoring Provisions of the Employment Standards Act, 2000 (ESA) and Ontario’s Freedom of Information and Protection of Privacy Act, R.S.O. 1990 (FIPPA), as well as Guidelines on use of Waterloo Computing and Network Resources and the following policies on the Secretariat’s website:

Nothing in this guideline is intended to amend or supersede any grievance procedure or other aspect of any applicable collective agreement, employment contract or University Policy.


This guideline applies to all employees, as defined by the ESA, including:

  • all staff members as defined in Policy 54, specifically all full-time, part-time, temporary, casual staff and members of unionized groups; 
  • all faculty members as defined in Policy 76 including regular faculty; appointments, other faculty appointments, miscellaneous appointments at any length of term or load; 
  • all student teaching assistants or research assistants; and 
  • all Co-op students employed by the University of Waterloo.


“Workplace” means any University premises, or any other place, where employees work, or any part of such premises or place.

“Electronic Monitoring” means the digital collection of information relating to any of:

  • physical access to a University workplace;
  • operation of a University-owned motor vehicle; 
  • using University-provided telecommunications services;
  • employee time-tracking system for payroll;
  • electronic commerce using a University-issued payment card; and
  • accessing any electronic device or information system that is owned, operated, maintained, or contracted by the University.  

“Footprint data” means any personally identifiable information of employees collected either directly or indirectly by means of electronic monitoring (see Appendix).

“Information steward” means an information steward as defined in Policy 46.

“Information custodian” means an information custodian as defined in Policy 46.

“Supervisor” means a person who has authority over an employee.

“Aggregate data” means a collection of information, normally from multiple sources, expressed in summary form where personally identifiable information has been removed.

Principles and Practices

  1. The University collects footprint data for specific purposes, including: 
  • maintaining the safety and security of the University community; 
  • maintaining the security of University of Waterloo facilities, assets, and digital services; 
  • safeguarding the confidentiality, integrity, and availability of information in the University’s care; 
  • time tracking for payroll purposes;
  • authenticating, and maintaining the integrity of, the University’s financial transactions; and 
  • financial, physical, and electronic management of University resources, including information to support environmental sustainability efforts.
  1. Footprint data will generally only be used for the purpose for which the data are collected.Footprint data may also be used in exceptional circumstances (e.g., law enforcement matters, emergencies or critical situations affecting individuals or public health and safety, and compassionate circumstances[1]). Footprint data will not be used to actively track and monitor employees for the purposes of performance management or discipline, although such data may be used to verify performance management or disciplinary issues which are independently discovered or suspected, including issues discovered or suspected through the course of permitted or required uses of the data. Footprint data may also be used for other purposes permitted or required by law, including conducting workplace investigations to ensure the University complies with statutory obligations.
  2. Footprint data are confidential. That is, data will not be disclosed to anyone except those persons, authorized by the appropriate information steward, who need it in the performance of their duties and where disclosure is necessary and proper in the discharge those duties, or those requiring it for a legitimate purpose as provided for in this guideline. 
  3. Information collected will be stored securely and in compliance with data security standards established by Information Systems & Technology; information will be retained and destroyed in accordance with the appropriate University of Waterloo record retention schedule.
  4. Nothing in this guideline prohibits the use of aggregate data, derived from footprint data, to facilitate decision-making and strategic planning at the University of Waterloo.

[1] In accordance with Ontario privacy legislation.

Roles and Responsibilities

Human Resourcesmust ensure compliance with the ESA and ensure this guideline is disseminated to employees.

In exceptional circumstances, or with the appropriate judicial authority (e.g., search warrant/production order), the University of Waterloo Special Constable Services (UWSCS) may request footprint data from information custodians of footprint data. When doing so, they shall provide the information custodian a case identification number (Occurrence/Report #) for tracking and accountability purposes.

Information stewards and information custodians of footprint data should seek guidance from the Support Resources listed in this guideline, such as the Privacy Officer, when considering the use or release of footprint data, beyond the purpose of collection, as permitted by this guideline.

Employees and supervisorsare not to use digital footprint data to actively track and monitor other employees for the purposes of performance management or discipline and shall comply with the provisions outlined in this guideline. Employees are also required to: 

  • use electronic monitoring data only for the purpose for which it is collected, as permitted by this guideline; and
  • not engage in any form of electronic surveillance of other employees or individuals unless there is a specific business need to do so, as permitted by this guideline.

Reporting Concerns

If you are concerned about employee surveillance, you should report those concerns immediately to your supervisor. If your concerns are not resolved by speaking with your supervisor, you should report your concerns in writing.  If it is not appropriate to report your concerns or issues to your supervisor, or the matter is not resolved by doing so, you should direct your concerns or issues to your supervisor’s manager, Union, or Association Employees will not be subject to reprisal for reporting, in good faith, such concerns as outlined above or for inquiring about, exercising, or attempting to exercise any rights as provided under the ESA.

Support Resources

The following resources are available to assist all employees with understanding the application of this guideline:

  • Privacy Officer, Secretariat
  • Director, Information Security Services, Information Systems & Technology
  • Director, HR Client Services, Human Resources

Legal and Immigration Services (LIS), and the Director, UWSCS, may also be consulted by information stewards and information custodians of footprint data. For example, when the University is served with a court order, guidance must be sought from LIS.

Appendix: Examples of Employee Digital Footprint 

Data Collected


Information Steward

Watcard/Keyfob swipe for building access (excluding Residence)

Physical Security 

University Secretary

Server and application access and activity (e.g., Office365, LEARN and Workday) from any Internet connected device at any location

Service Management 

Information Security 

Chief Information Officer 

Software use on University desktop computers, including mobile devices, at any location

Service Management

Information Security

Chief Information Officer

Telephone records

Financial management 

Chief Information Officer 

Video surveillance

Safety & Security 

University Secretary 

Library card scan

Library resource management 

University Librarian 

University network activity

Network Security 

Chief Information Officer 

Wireless network activity (including campus location data)

Service Management 

Network Security 

Chief Information Officer 

Athletics facility use records

All other Watcard use

Resource management 


AP, Students 

Employee time tracking


Department heads

P-Card transactions

Financial management 

Director of Finance 

E-commerce (University as the merchant)

Authenticity of financial transactions 

Director of Finance 

Telematics from fleet vehicles at any location

Environmental sustainability 

Executive Director of Plant Operations

Director of Sustainability 

Link tracking from University communications

Management of communications effectiveness 

VP, University Relations