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Electronic Monitoring Policies in Ontario: What are the requirements?

Bill 88, the Working for Workers Act 2022, became law in April 2022. While a large portion of the legislation dealt with workplace rights relating to “Digital Platform Workers”, i.e., app-based drivers and delivery people, the legislation also included a mandatory requirement for Ontario employers relating to electronic monitoring.
When is an Electronic Monitoring Policy Mandatory?
An electronic monitoring policy may be mandatory depending on how many employees your business employs at the start of each year:

If your business is an employer in Ontario that employed 25 or more employees on January 1, 2022, then you must have an electronic monitoring policy in place by October 11, 2022.

If your business is an employer in Ontario that will employ 25 or more employees by January 1, 2023, then you must have electronic monitoring policy in place by March 1, 2023.

In any given year going forward, any Ontario business that employs 25 or more employees by any January 1 will...

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