Sharing employee ID numbers

Question: Can employee identification numbers be shared with vendors on invoices or with others within the company, or would that be considered a violation of privacy?

Answer: Generally it will be permissible to disclose employee identification numbers (created by the employer) to vendors on invoices, or to others within the company, if such disclosure is reasonably necessary for the efficient operation of the employer’s business.

Except for federally regulated employers, and employers in Alberta, British Columbia and Quebec, there is no specific privacy legislation which deals with the disclosure of personal employee information in the private sector. Public sector employers, and private sector employers in Alberta, British Columbia and Quebec, as well as employers that are federally-regulated, are subject to privacy legislation respecting the collection, use and disclosure of employee personal information. For private sector employers who are not federally regulated, and not operating in Alberta, B.C. or Quebec, the disclosure of an employee identification number is unlikely to be problematic.

For employers in jurisdictions where privacy legislation regulates the collection, use and disclosure of employee personal information, the risk of a privacy violation can be minimized by ensuring that personal employee information is only collected, used and disclosed when it is reasonably necessary to do so to operate the business. It is always a good practice to obtain employee consent before disclosing employee personal information.

However, when it is not practical to get consent, disclosure of employee personal information will be justifiable if such disclosure is reasonably necessary for the operation of the employer’s business. In the specific case of an employee identification number, it is likely that disclosure of a number will be permissible when it is necessary to do so to track or identify an employee’s work in the course of the business’s efficient operation.

While it is likely permissible in most cases to disclose a company-issued employee identification number, employers should take care not to disclose an employee’s social insurance number without an employee’s consent.

Generally a social insurance number may only be properly disclosed for payroll purposes, and then only with certain confidentiality protections in place. Examples of other employee personal information that generally should not be disclosed includes employee birthdates, medical information, and performance records.