Cohere Centre Electronic Monitoring Policy

1. Purpose

Cohere Centre uses electronic systems to operate and secure its facility, administer scheduling and attendance, maintain accurate workplace records and support legitimate operational and employment functions.

This policy explains whether and how Cohere Centre electronically monitors employees, the circumstances in which monitoring may occur and the purposes for which information obtained through electronic monitoring may be used.

This policy is intended to address Cohere Centre's written electronic-monitoring obligations under Ontario's Employment Standards Act, 2000.

2. Application

This policy applies to Cohere Centre employees and, where applicable, assignment employees performing work for Cohere Centre.

Not every employee is subject to every form of electronic monitoring described in this policy.

3. Does Cohere Centre Electronically Monitor Employees?

Yes.

Depending on an employee's position, workplace activities and systems used, electronic monitoring may occur through:

• VenueWorks;
• Time Clock location verification;
• CCTV video surveillance;
• electronic key-card access systems;
• Microsoft 365 / Office 365;
• workplace Wi-Fi and network infrastructure;
• the facility alarm system; and
• related security and audit systems.

4. VenueWorks

VenueWorks electronically records workplace activity necessary to operate Cohere Centre's workforce-management functions.

Depending on the features used, this may include:

This information may be used for scheduling, staffing, attendance administration, payroll preparation, workplace management, security, troubleshooting, audit, investigating discrepancies and maintaining employment records.

• schedules and shift assignments;
• shift changes and confirmations;
• availability;
• time-off requests;
• clock-in and clock-out activity;
• timesheet activity;
• corrections and approvals;
• employee or manager administrative actions;
• authentication and security events; and
• system audit records.

5. Time Clock Location Verification

Employees who are eligible for VenueWorks Time Clock may be required to allow device location access when attempting to clock in or clock out.

The system may compare the device's location to an authorized Cohere Centre work location or geofence.

VenueWorks is not intended to continuously track employee movement or continuously monitor an employee's device location in the background.

Location verification occurs in connection with a Time Clock action.

Information associated with an attempt may include:

This information may be used to:

• the time of the attempt;
• location information required for geofence verification;
• location accuracy information;
• whether the attempt was accepted or rejected;
• relevant system or security information associated with the attempt.
• verify attendance;
• verify the location of a Time Clock action;
• maintain accurate work-time records;
• prepare and review timesheets and payroll;
• investigate disputed, missing or unusual punches;
• identify suspected misuse or attempted circumvention of Time Clock controls;
• troubleshoot technical issues; and
• where appropriate, support workplace investigations, coaching, corrective action or discipline relating to timekeeping.

6. CCTV Video Surveillance

Cohere Centre operates CCTV cameras in and around portions of the Cohere Centre facility.

CCTV may record employees when they are present in areas covered by the cameras.

CCTV may operate continuously or according to the configuration of the security system.

Video surveillance may be used for:

Access to CCTV footage should be restricted to individuals or service providers with a legitimate need to review it.

This policy describes video surveillance. It should not be interpreted as notice that Cohere Centre routinely records employee conversations or uses CCTV audio for employee monitoring. If audio-recording functionality is introduced or intentionally used for employee monitoring, the practice and this policy must be reviewed before relying on that functionality.

• safety and security;
• protection of employees, visitors and property;
• facility and event security;
• investigation of accidents, incidents, theft, property damage or suspected misconduct;
• verification of events relevant to a workplace or security investigation;
• emergency response; and
• other legitimate safety and security purposes.

7. Electronic Key-Card Access

Some Cohere Centre areas use electronic key-card access.

Employees who are issued or use an electronic access credential may generate system records showing information such as:

Access-control information may be used for:

Key-card information is not intended to be used as continuous employee location tracking.

• the credential used;
• the door or access point;
• the date and time of the access attempt;
• whether access was granted or denied.
• building and workplace security;
• controlling access to restricted areas;
• investigating security incidents;
• reviewing unauthorized or unusual access;
• emergency or safety investigations; and
• administering access permissions.

8. Microsoft 365 / Office 365

Cohere Centre uses Microsoft 365 / Office 365 for workplace email and related business technology.

Microsoft 365 and associated administrative systems may generate account, authentication, security, access and audit information.

Authorized personnel may review information from these systems when reasonably required for purposes such as:

This policy does not mean that Cohere Centre routinely reads employee email or continuously reviews individual employee activity for performance purposes.

However, workplace accounts and systems may be reviewed where there is a legitimate business, security, legal or investigative reason to do so.

• account administration;
• cybersecurity;
• investigating suspected phishing, malware or unauthorized access;
• troubleshooting;
• legal or regulatory requirements;
• business continuity;
• responding to a legitimate workplace investigation; or
• protecting Cohere Centre information and systems.

9. Workplace Wi-Fi and Network Systems

Cohere Centre's workplace Wi-Fi and network infrastructure is managed with assistance from a third-party service provider.

Network systems may automatically generate technical or security information such as:

Network information may be reviewed for:

Cohere Centre does not describe this system as continuous employee productivity or browsing surveillance.

• device or connection information;
• network addresses;
• connection times;
• security alerts;
• authentication or access information;
• other technical logs required to operate or secure the network.
• cybersecurity;
• network administration;
• troubleshooting;
• detecting unauthorized or malicious activity;
• investigating security incidents; and
• maintaining reliable workplace technology.

10. Alarm System

Cohere Centre uses an electronic alarm system for facility security.

Full-time employees may be assigned individual alarm codes or credentials.

The alarm system may generate electronic records associated with activities such as:

Alarm-system records may therefore identify an employee associated with a particular security-system action.

This information may be used for:

• arming the facility;
• disarming the facility;
• alarm activations;
• access or security events;
• the code or credential associated with an event.
• facility security;
• identifying who armed or disarmed the facility;
• investigating alarm activations;
• responding to security incidents;
• administering alarm access; and
• investigating suspected misuse of security credentials.

11. Account, Security and Audit Records

Cohere Centre's electronic systems may automatically maintain records of user and administrative activity.

These records may be reviewed to:

• protect systems and information;
• investigate unauthorized access;
• determine who performed a particular administrative action;
• investigate suspected misuse;
• troubleshoot software or account issues;
• maintain audit history;
• respond to security incidents; or
• support legitimate workplace investigations.

12. When Electronic Monitoring Occurs

Electronic monitoring may occur:

• when an employee uses VenueWorks;
• when an eligible employee attempts to clock in or out;
• while an employee is in an area covered by CCTV;
• when an electronic key card is used;
• when an employee uses a Cohere Centre Microsoft 365 account;
• when a device connects to or uses Cohere Centre's workplace network;
• when an employee uses an assigned alarm credential;
• when electronic systems automatically generate security or audit records; or
• when authorized personnel review existing records for a legitimate operational, security, employment, legal or investigative purpose.

13. Purposes for Which Monitoring Information May Be Used

Information obtained through electronic monitoring may be used for legitimate purposes including:

• employee and public safety;
• facility security;
• protection of Cohere Centre property and information;
• scheduling and staffing;
• attendance and timekeeping;
• payroll administration and verification;
• access control;
• cybersecurity;
• incident investigation;
• investigation of suspected misconduct or policy violations;
• resolving discrepancies or employee questions;
• technical troubleshooting;
• legal or regulatory compliance;
• workplace investigations;
• emergency response;
• maintaining appropriate business and employment records; and
• where relevant and appropriate, coaching, performance management, corrective action or discipline.

14. Access to Monitoring Information

Electronic monitoring information should only be accessed by persons who require it for an authorized purpose.

Depending on the information and circumstances, this may include:

Access does not mean that every authorized person can access every monitoring system or record.

• authorized managers;
• the General Manager;
• authorized administrative personnel;
• security personnel;
• authorized information-technology personnel;
• payroll personnel where appropriate; or
• authorized third-party service providers acting on Cohere Centre's behalf.

15. Personal Devices

Employees may access certain Cohere Centre systems from personal phones, tablets or computers.

Use of VenueWorks or another authorized workplace application on a personal device does not provide Cohere Centre unrestricted access to the employee's personal device.

Device permissions required by a particular workplace function, such as location permission for an eligible VenueWorks Time Clock action, are used for the purpose associated with that functionality.

16. Accuracy and Employee Questions

Employees who believe an electronic Time Clock, attendance, timesheet, access or other workplace record is inaccurate should contact their manager or an authorized Cohere Centre administrator.

Cohere Centre may review relevant system records and, where appropriate, make a documented correction or adjustment.

17. Employee Responsibilities

Employees are expected to use workplace systems truthfully, securely and in accordance with Cohere Centre policies.

Employees must not:

• falsify time records;
• clock in or out for another employee;
• deliberately circumvent Time Clock location or security controls;
• share individual alarm or access credentials when prohibited;
• improperly access another person's account or information; or
• intentionally misuse workplace systems.

18. Distribution of This Policy

Cohere Centre will provide this policy to employees within the timeframes required by applicable Ontario employment standards legislation.

An electronic copy may be made available through VenueWorks or another online location where employees have reasonable access.

Making the policy available online does not prevent Cohere Centre from also distributing it by email, printed copy or another appropriate method.

19. Retention

Cohere Centre will retain copies of written Electronic Monitoring Policies for the period required by applicable Ontario employment standards legislation.

Where the statutory retention requirement applies, required policies will be retained for at least three years after the policy ceases to be in effect.

20. Changes to This Policy

Cohere Centre may revise this policy as workplace technologies, monitoring practices or legal requirements change.

Each revision must identify the date the policy was changed.

Superseded versions will be retained where required for legal, operational or audit purposes.

Date prepared: August 31, 2026

Changes: None — initial Version 1.0

21. Questions

Questions regarding this policy or Cohere Centre's electronic monitoring practices may be directed to:

Cohere Centre

Attention: General Manager / Privacy Officer

4899 Uplands Drive

Ottawa, Ontario K1V 2N6

Canada

Email: info@coherecentre.ca

Telephone: 613-822-8800