Electronic Monitoring Policy

Purpose

Ontario's Employment Standards Act, 2000 (ESA) requires employers with 25 or more employees to have a written policy on the electronic monitoring of employees. NEO adopts this policy voluntarily, as good practice, so that everyone who works here knows what is monitored, how, when and why.

Who it applies to

• All NEO employees, in the office, at hearings and when working remotely.
• Contractors and students who use NEO's systems. The ESA rule covers employees only, but the same monitoring applies to anyone using our systems, so we tell them too.

Does NEO electronically monitor employees?

Yes. Our systems record some of what people do on them. Each kind of monitoring is listed below, with how and when it happens and what the information is used for.

1. Punch clock and timesheets. The staff portal records when you punch in and out, the hours on your timesheet, and every correction, with who made it and when. Used for: paying you correctly, keeping the records of hours the ESA requires, scheduling and attendance.
2. Time on client matters. The time entries you make on a matter, and when you made them. Used for: billing, client files, supervision and planning workloads.
3. Sign-in place and device. When you sign in to the staff portal, and from time to time while you use it (at most about every 30 minutes), the portal records the time, the device and browser, the internet address, and an approximate place worked out from that address, such as the city. The principal can see each staff member's last place and device in the portal. Used for: security, such as spotting a sign-in that isn't yours, and checking that work arrangements, such as remote work, are followed.
4. The portal's audit log. The portal records important actions: who created, changed, sent or deleted client files, documents, invoices, payments and HR records, and when, and for some sensitive information, such as a Social Insurance Number, who viewed it. Used for: security, finding and fixing errors, investigating unauthorized access, supervision, and NEO's record-keeping and audit duties to the Law Society of Ontario.
5. Phone calls. Calls on NEO's business phone lines and phone app are recorded by our phone provider, which also keeps call logs (numbers, times and length), voicemails and texts, and may produce AI summaries of recorded calls. Our Recording of Calls and Meetings Policy explains this. Used for: an accurate record of client instructions, quality and training, supervision, complaints and our legal duties.
6. Messages to clients. Emails, messages and documents that office staff send to clients from the staff portal are held until the principal approves them, so the principal reads each one before it is sent. Used for: the supervision of non-licensees' work that the Law Society's By-Law 7.1 requires of the responsible licensee, and protecting confidentiality and quality.
7. Email, files and accounts. Our email, storage and other providers keep standard logs, such as sign-ins, messages sent and received, and file access. NEO may review the email, messages and files in firm accounts when there is a business need, for example to find a client document while you are away, to respond to a security incident, to look into a complaint, or to meet a legal obligation. Our Acceptable Use of Technology Policy applies.
8. AI tools. Requests made through NEO's AI tools are logged, with who made them, when, and the cost. Used for: checking use under our Responsible Use of Artificial Intelligence Policy, quality and cost control.
9. Technical logs. The portal records technical errors that happen in your browser, with the page and your account, and measures how fast pages load; our hosting and other providers also keep standard server logs. Used for: keeping the portal working and secure.
10. The building. If the building our office is in uses its own security cameras, access cards or visitor sign-in, those are run by the building under its own rules, not by NEO. NEO would ask the building for its records only to look into a safety or security incident.

What NEO doesn't do

NEO doesn't use keystroke logging, screen recording or screenshots, webcam monitoring, or GPS tracking of phones or vehicles, and the staff portal doesn't run advertising trackers or website analytics such as Google Analytics. Before NEO starts any kind of electronic monitoring not described here, we will update this policy and give you a copy.

Your own devices

When you use NEO's systems on your own phone or computer, such as the staff portal or the phone app, the monitoring above applies to that use. NEO doesn't monitor anything else on your device.

How the information may be used

Besides the purposes listed above, NEO may use information from any of these sources to look into and deal with a security incident, a complaint, a problem with client service, or a possible breach of the law, the Law Society's rules or NEO's policies. That can include performance management and discipline, and bringing or defending a legal claim. Only the principal, and people the principal authorizes for a specific task, can see this information. It is kept as our Employee Privacy and Personnel Records Policy, Recording of Calls and Meetings Policy and File Closing and Retention Policy provide.

What this policy is not

Like the ESA rule it follows, this policy is about being open with you. It doesn't create new privacy rights, or a right not to be monitored. Your duties of confidentiality, and the firm's other policies, still apply.

Giving you a copy

• Each employee receives a copy within 30 days of starting work, and within 30 days of any change, in the staff portal and as an email attachment you can print. You can ask for a paper copy at any time.
• NEO keeps a copy of each version for at least three years after it stops being in effect.

Policy dates

• Prepared: October 24, 2026.
• Changes: none yet. Each future change will be listed here with its date.

Review

This policy is reviewed at least once a year, and whenever our systems or the law change. The principal approves every change.

Questions

Ask the principal, or email info@neolegalservices.com, call 647-200-3526 or toll-free 888-519-2435, or write to us at Unit 236, 1099 Kingston Road, Pickering, Ontario L1V 1B5.