This Wisdom of the Crowd, compiled from responses posted on the Small Law Departments eGroup, addresses the issues underlying company-wide sharing of employees' personal information.
(Permission was received from the ACC members quoted below prior to publishing their eGroup comments in this Wisdom of the Crowd resource.)
Question:
Yesterday, one of our admins circulated an "Employee Directory" via e-mail to all staff, which included the name, spouse, address, and phone number(s) for every employee. I had no idea this was coming. I"m a brand new GC here, for a small company that has never had a GC before; I understand this is something they have just always done for Christmas card and hurricane/disaster planning purposes. I have had a few employees ask why all this information is so freely shared company-wide, however. They have questioned the necessity and safety of the sharing (i.e., "Would you want a subordinate to know where you live?"; "What if you have to terminate the subordinate?"; "Would you want them to know how to find you?"), so it seems worth looking at this a bit more.
Specifically, I am interested to hear whether other small companies (under 100 employees) maintain and share company-wide a directory of employee personal contact information. Why or why not?
Wisdom of the Crowd:
Response #1:
We have under 200 employees. We do not distribute this type of information, and I would be concerned if I were in your shoes too. However, realize that much of the information is in public record anyway, at least for homeowners.
Our company policy is that if the company pays for your cell phone, it must be included on our phone list that is distributed to all employees. Other than that, our employees do not have access to such information. i
Response #2:
We have 300 hundred employees and would not circulate such a list for those reasons you cited. Before my time here but in the memory of a number of employees, there was a situation where a disgruntled fired employee threw a brick through his supervisor's living room window nearly hitting his child and same former employee vandalized cars, stalked former co-workers, etc.
Employees who are friends will share that information amongst themselves. If someone had death or serious illness, HR usually can coordinate sending a large envelope of cards from co-workers.
I know some might think the information is not a big deal as a determined snoop can get a lot via the web, but I say that the employer doesn"t want to facilitate that.ii
Response #3:
Rick Engineering Company was once the same size as your organization and did the exact same thing. Every year as December rolled around out went the address list. It worked well when the corporation was family owned and small. But, as the organization grew and became geographically and otherwise diverse we realized that some traditions needed to be updated.
There are a number of legal reasons to stop almost anything, including this practice, but when dealing with employees, more than legal issues should be considered - in my opinion. And now that one of your employees has asked the question you"re at the cusp of needing to review the tradition. When we got to this point we decided that we would allow the circulation of addresses but each employee had to opt into participation each year. And each year in November a reminder is sent out to all asking if they would like to be included in the annual holiday address exchange. Most participate, some do not. We handle it through the Accounting Dept. because it provides one more opportunity to make[] sure we have updated addresses for all employees. The list is then circulated by HR as the final vetting to make sure we only added those who asked to be added to the list.
When implementing the change we did it through our internal monthly meeting process associated with a process we call RQE (Rick Quality Enhancement) that has each division (or smaller groups if the division is large) meeting periodically to go over division and corporate news, goals and other issues. That way questions could be asked and answered.iii
Response #4:
Our very small company circulates an employee directory for hurricane and other disaster preparedness which includes phone numbers and email addresses only.iv
i Response from: Sarah Hicks, General Counsel, Humphreys & Partners Architects, LP, Dallas, TX (Small Law Departments eGroup, Feb. 7, 2014).
ii Response from: Brandy Olson, General Counsel, Dir. Legal and Reg. Svs., Muscatine Power and Water, Muscatine, IA (Small Law Departments eGroup, Feb. 7, 2014).
iii Response from: Dennis Stryker, General Counsel, Rick Engineering Company, San Diego, CA (Small Law Departments eGroup, Feb. 7, 2014).