Interpersonal Workplace Relationship Policy
Executive summary
The Interpersonal Workplace Relationship Policy (IWRP) is designed to address potential Conflict of Interest (COI) issues that may arise when RCMP employees become involved in interpersonal relationship within the workplace. In particular, the policy creates an employee obligation to report the existence of a relationship between supervisors/persons in authority and subordinates which may raise COI concerns. The purpose of the policy is to manage conflicts of interest, ensure public confidence in the integrity and management of the RCMP, provide a safe and respectful workplace, protect employees from abuse of authority and harassment that may arise as a result of an imbalance of power between employees in the workplace and support the operational effectiveness of the RCMP. Specific concerns over the nature of the information that is to be collected have been taken into consideration and precautions in the handling of reports are addressed through the application standard document handling security procedures employed to protect IWRP reports which will be placed on the employee Conflict of Interest File.
The PIA Type referenced in this material is Departmental in nature and is restricted to internal RCMP Human Resource (HR) processes. This is a new PIA produced in support of a policy initiative as articulated in paragraph 1. The Government of Canada (GOC) institution is the Royal Canadian Mounted Police which is headed by Commissioner Robert Paulson and the Delegated Officer for this policy is the OIC Access to Information & Privacy, Ottawa. A/Commissioner Craig MacMillan, Professional Integrity Officer, has been assigned overall responsibility for this PIA. Assistance has been provided by the A/Director, Professional Standards & External Review, Ottawa, Insp. John A. MacDonald.
The IWRP is a chapter of a new RCMP Conflict of Interest Directive which provides the framework for dealing with COI and supports measures implemented to address conflicts of interest, preferential treatment, apprehension of bias, and abuse of authority or power in the workplace. Legal authorities are primarily drawn from the RCMP Act & Regulations, the Public Servants Disclosure Protection Act, and Values and Ethics Code for the Public Sector, which in turn are supported by policy and procedures relevant to the collection, use and retention of information. The Privacy Act and the Access to Information Act also impact the management of this policy. Personal information gathered pursuant to this policy will be managed consistent with the existing Personal Information Bank (PIB) governing information pertaining to Public Service Employees (PSE 915) and the modification of an existing PIB governing information pertaining to Regular and Civilian Members of the RCMP (RCMP PPE 815).
The Section II PIA Risk Analysis matrix indicates an average score of 1.83 (on a scale of 1-4) which can be categorized as "low-moderate". Statistically, this suggests that the risk to privacy inherent in this new policy, despite the highly sensitive personal nature of the information that is being gathered, is tolerable. Given that the reporting processes involved in this policy are rudimentary paper-driven reports (highly restricted access) vs. automated, large scale data "vacuuming" across multiple government departments or business lines, the risk is further diminished. Therefore, no further steps, other than what are currently in place in the RCMP to guard sensitive information, are required.
Nevertheless, it is category #2 "Type of Personal Information Involved and Context" which raises the most concern and is therefore given additional weight. This policy requires that employees disclose limited information about romantic/sexual interpersonal workplace relationships (between supervisors/persons in authority and subordinates) to the employer. Extensive consultation has taken place in order to devise appropriate measures to handle this information and to determine to what extent the employer can use it to mitigate risk. Legal advice was sought in this regard and the feedback was incorporated into the overall language of the policy. It was determined through these processes that there are no legal prohibitions against the gathering of this information so long as it is used for the purpose for which it is collected.
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