Intent

The West Egg Group Corp. (TWEGCO, the “Company”) values trust, discretion, and transparency and believes employees deserve to know when and how their work is being monitored. This policy is to be used in addition to the company Privacy Policy and is intended to establish guidelines for company practices and procedures related to electronic monitoring of employees.

Guidelines

Electronic Monitoring Practices

TWEGCO collects information through electronic monitoring for a variety of reasons, including protecting the company’s legal and business interests. TWEGCO reserves the right to electronically monitor employees, directly or indirectly, at its discretion. Employees should not expect absolute privacy in relation to their use of TWEGCO resources and while on Company time. Employees should not assume that any use of TWEGCO resources or while on the Company’s time is exempt from electronic monitoring in accordance with this Policy. The company will electronically monitor the following activities and procedures:

Asset

• Company-provided vehicles
• Company-provided spaces

System

• Humanity for time and attendance, location radius for job site location
• PARiM for time and attendance, location radius for job site location
• Zoho CRM and Forms to verify location while on shift performing company activities
• Websites, emails, online chats
• GPS within company vehicles
• Zoho Sign software
• Gmail
• Zoom Phone
• Zoom Meetings

Service

• CCTV
• Contact/call centres

Equipment

• Company-provided laptops
• Company-provided cell phones
• Company access cards
• Live monitoring as an extension of quality monitoring programs

This list is not exhaustive and may be updated as policies, practices, and procedures change, or as assets, systems, services, equipment, and devices, are upgraded or replaced.

Any information collected by electronic monitoring may be used during employee reviews or during consideration of disciplinary decisions.

Information obtained through electronic monitoring may be used for all purposes consistent with the Company’s responsibilities as an organization, and any Company practice, or procedure.

Such purposes include but are not limited to employee safety, the protection and security of the Company’s compliance with applicable policies and procedures, and complaint response.

Other purposes may include:

• Workforce management
• Operational auditing, monitoring, and reporting
• Health and safety monitoring
• WSIB or Ministry of Labour investigations
• Coaching and quality improvement
• Labour Relations-related investigations
• Privacy complaints, monitoring, and auditing
• Security incidents, including workplace violence, thefts, vandalism, and threats
• IT related investigations
• Data review and pattern monitoring
• Resolving technical issues
• As evidence for forensic investigations on behalf of the Company or an authorized third party such as law enforcement agencies or other government bodies
• Responding to freedom of information requests, litigation-related requests, or otherwise as required by law.

Information obtained by the Company through electronic monitoring shall be collected, maintained and dispersed in accordance with the Company’s responsibilities as an organization, and any Company, policy, practice, or procedure.

Privacy and Confidentiality

The company’s monitoring is aimed at collecting information related to its business. However, some information collected by electronic monitoring may be considered personal information. When personal information is under The West Egg Group Corp. control, it is the responsibility of the company to protect it.

All information collected through electronic monitoring will be securely stored and protected. If any personal information is collected, its use and disclosure will be limited to achieve the stated purpose of its collection. The company will adhere to all privacy and confidentiality legislation that applies to the collection, use, and disclosure of personal information obtained by electronic monitoring.

Approved By

Natasha MacFarlane, Director of Projects & Innovation

Date Approved

November 18, 2022

Effective Date

November 18, 2022