Your employees’ data is your liability. Govern it like one.
HR records, performance files, health and accommodation data, monitoring logs — employee personal data is among the most sensitive information you hold, and usually the least governed. 1205 runs an operational people-data governance review and remediation plan: who can access it, how it is stored, where vendors touch it, and whether you are ready for a breach. We are not your lawyer — we make the operations defensible.
— Operational review · Not legal advice · One business-day reply
To be clear: 1205 provides an operational people-data governance review and remediation planning — not legal advice. We do not interpret your obligations under PIPEDA or provincial privacy law, and nothing here is a legal opinion. Where a matter needs one, we escalate to privacy counsel. Treat the items we flag as your obligations to confirm with your counsel — our job is to make the operations behind them defensible.
The most sensitive data you hold is about your own people.
Customer data gets the attention and the budget. Employee data quietly accumulates across more systems, with broader access, and far less governance. These are the four categories where exposure concentrates.
HR & payroll records
The core file on every employee — compensation, banking, SIN, employment history. Often reachable by more people, in more systems, than anyone has actually mapped.
Performance & discipline
Reviews, PIPs, investigation notes, exit files. Sensitive by nature, and the place where "who can see this?" matters most — and is most often unclear.
Health & accommodation
Medical notes, accommodation requests, leave and benefits data. The most sensitive category you hold, and the one with the tightest expectation of need-to-know access.
Workplace monitoring
Email, device, location, and productivity data. Collecting it creates obligations and expectations — how it is stored and who can review it needs a deliberate answer, not a default.
Operational hygiene. Defensible by design.
Six work areas, one outcome: you know what employee data you hold, who can reach it, how long you keep it, who outside touches it, and what happens if it leaks. Each area ends in a named, owned remediation item.
People-data inventory
What employee personal data you hold, in which systems, and why. You cannot govern — or defend — what you have not mapped. We build the map first.
Map what you hold before you protect it.
Access controls
Who can reach each category of employee data, and whether that matches genuine need-to-know. We find the over-broad access and the orphaned permissions, and tighten them.
Need-to-know, enforced — not assumed.
Retention & disposal
How long each category is kept and how it is disposed of. Holding employee data longer than you need is risk with no upside. We set defensible retention and a disposal routine.
Keep what you must; dispose of the rest.
Vendor & processor due diligence
Your payroll, HRIS, ATS, benefits, and monitoring vendors hold your people data. We review processor access, contract data terms, and configuration — the third-party surface is where most exposure now lives.
Most exposure is now third-party.
Breach readiness
Whether you know what you hold, who is notified, and what the first hours look like. We help you build and rehearse an operational plan — and flag where counsel confirms your reporting obligations.
A rehearsed plan beats a scramble.
HR-system rollouts
New HRIS, ATS, or monitoring tool? We sit alongside the rollout so access, retention, and processor terms are set correctly on day one — not retrofitted after a problem surfaces.
Set it right at rollout, not after.
The Human-Attested standard
AI in the workflow. A person on the hook.
AI assists. It never decides.
We use AI to move faster on research, drafting, and pattern-finding. It is a tool in the workflow — not the analyst, not the judgment, and not the author of what we deliver.
A senior human reviews and owns the work.
Every deliverable is reviewed and stood behind by a senior 1205 practitioner. The findings, the recommendations, and the file are human work product — attributable to a named person, not a model.
We escalate when the matter needs it.
Where a question crosses into regulated territory, we say so and route it to privacy counsel. We would rather hand off than overreach.
We are clear about our boundaries.
1205 provides operational privacy governance review and remediation planning — not legal advice.
Start with a review. Act on the plan.
We begin with a scoped people-data governance review and hand you a remediation plan you can act on — yourself, or with us under a separate mandate. Final scope is confirmed after a short intake. Where the work needs a legal opinion, we escalate to privacy counsel rather than overreach.
Part of the broader HR function.
HR Services
People-data governance is one piece of the Ontario HR compliance work we run. See how it sits alongside the rest of the function.
Explore HR ServicesOutsourced HR
Want governance maintained, not just diagnosed? Embedded HR keeps access, retention, and vendor terms current as your organization changes.
See Outsourced HRStraight answers on people data.
Is this legal advice?
No. 1205 provides an operational people-data governance review and a remediation plan — how employee personal data is accessed, stored, retained, and shared, and what to tighten. We do not give legal opinions or interpret your statutory obligations for you. Where a question needs a legal answer, we say so and escalate to privacy counsel.
What employee data does the review cover?
The personal data your organization holds about its people: HR and payroll records, performance and discipline files, health and accommodation information, background-check and recruitment data, and any workplace monitoring data. We look at who can reach each category, where it lives, how long it is kept, and who outside the organization can touch it.
How does this relate to PIPEDA or provincial privacy law?
Canadian privacy law — PIPEDA federally, with provincial regimes in some provinces — sets expectations around how personal information is handled. Rather than interpret which obligations apply to you, we build the operational controls that good governance calls for and flag where you should confirm your specific obligations with counsel. The legal interpretation stays with your privacy counsel; the operational hygiene is what we own.
What about vendors and HR-system rollouts?
Most people-data risk now sits with third parties — payroll providers, HRIS and ATS platforms, benefits administrators, monitoring tools. We review processor access, contract data terms, and configuration, and we sit alongside a new HR-system rollout so access controls and retention are set correctly from day one rather than retrofitted after a problem.
Are you ready if there is a breach?
Breach readiness is part of the review: do you know what data you hold and where, who would be notified, and what the first hours look like. We help you build and rehearse that plan operationally. If an actual breach involves notification obligations or legal exposure, that is a moment to bring in privacy counsel — confirm your reporting obligations with them.
What do we get at the end?
A people-data inventory, a map of access and retention, a vendor/processor risk view, a breach-readiness assessment, and a remediation plan that names each gap, the fix, and the owner. Where you want us to close the gaps, we can scope that work under a separate mandate.
Know what you hold before someone else does.
Tell us the basics — no sensitive data here — and we’ll scope a people-data governance review and remediation plan. We reply within one business day. Operational governance, not legal advice; we escalate to privacy counsel where a legal opinion is needed.
— Operational review · Not legal advice