1. Who We Are
This Privacy Policy is issued by 1001328662 ONTARIO INC., operating the workforce management platform known as Workforce Connect (also referred to as WFConnect). References to "we," "us," "our," or "the Company" in this document refer to 1001328662 ONTARIO INC. and the Workforce Connect platform collectively.
Workforce Connect is operated by 1001328662 ONTARIO INC.
Workforce Connect is a workforce management and staffing platform designed to connect hospitality and janitorial workers with employment opportunities at hotels, commercial facilities, and related venues. Our services include a public application portal at https://apply.wfconnect.org, an administrative platform at https://wfconnect.org, a mobile worker application, and associated communication services including SMS and phone outreach.
We are headquartered in Ontario, Canada, and our operations are primarily governed by Canadian federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA).
Scope of This Policy: This Privacy Policy applies to all individuals who interact with Workforce Connect, including job applicants, registered workers (subcontractors), hotel and facility clients, website visitors, and any other persons who submit personal information to us through any channel.
2. Information We Collect
We collect personal information only when it is necessary to operate our staffing and workforce management services. The categories below describe the types of information we collect and the contexts in which we collect them.
2.1 Applicant & Worker Identity Information
- Full legal name (first, middle, and last)
- Date of birth
- Government-issued identification (e.g., driver's licence, passport, provincial ID card)
- Social Insurance Number (SIN) — collected solely for payroll tax compliance purposes under the Income Tax Act (Canada)
- Proof of eligibility to work in Canada (e.g., work permit, citizenship documentation)
- Photograph or scanned image of government-issued ID, where required for identity verification
2.2 Contact Information
- Mobile and home phone number(s)
- Email address
- Home mailing address (street, city, province, postal code)
- Emergency contact name, relationship, and phone number
2.3 Employment & Application Information
- Resume / curriculum vitae (CV), including work history and job-related experience
- Skills, certifications, and training credentials relevant to housekeeping or janitorial roles
- Work availability and scheduling preferences
- Employment references
- Criminal background check results or vulnerable sector checks where mandated by law or client contract
- Signed subcontractor agreements and consent forms
2.4 Payroll & Financial Information
- Bank account details for direct deposit (institution number, transit number, account number)
- Tax filing preferences (TD1 forms)
- Hours worked, shift records, and time-in / time-out logs
- Payment history and pay stub records
2.5 Communication Records
- Text message (SMS) correspondence related to job placement, scheduling, onboarding, and employment updates
- Phone call logs for interview scheduling and workforce coordination
- In-app messages through the Workforce Connect mobile application
2.6 Technical & Device Information
When you access our website or mobile application, we automatically collect:
- IP address and approximate geographic location (city/region level)
- Device type, operating system version, and unique device identifiers
- Browser type and version
- Pages visited, links clicked, session duration, and referral source
- GPS coordinates — only when you initiate a clock-in or clock-out action (see Section 3)
2.7 Information Collected Through Application Forms
When applicants submit forms through https://apply.wfconnect.org, we collect all fields within those forms, which may include:
- Preferred work location and shift type
- Languages spoken
- Self-identified accommodation needs (if voluntarily disclosed)
- Consent acknowledgements and digital signatures
3. How We Use Your Information
We use the personal information we collect exclusively for legitimate staffing, workforce management, employment compliance, and communications purposes.
| Purpose | Categories of Data Used |
|---|---|
| Reviewing and processing worker applications | Identity, contact, application, resume |
| Verifying employment eligibility | Government ID, SIN, work permit status |
| Onboarding workers and completing subcontractor agreements | Identity, contact, signed documents |
| Matching workers with appropriate job placements | Skills, availability, certifications, location preference |
| Scheduling and shift management | Contact, availability, location |
| Processing payroll and issuing payments | Financial, payroll records, SIN |
| Sending SMS, phone, and email communications about interviews, onboarding, scheduling, and shift updates | Phone number, email, shift data |
| Verifying attendance through Time-In / Time-Out (TITO) | GPS coordinates, timestamps |
| Complying with tax, labour, and employment law obligations | SIN, financial, identity records |
| Maintaining audit trails and dispute resolution | All relevant employment records |
| Improving platform functionality and user experience | Usage data, technical data (anonymized where possible) |
| Responding to privacy requests, complaints, and inquiries | Identity, contact information |
3.1 GPS / Location Data (TITO Feature)
When workers use the Time-In / Time-Out feature of the Workforce Connect mobile application, GPS coordinates are captured at the moment of clock-in or clock-out to verify that the worker is at the designated work site. This location data:
- Is collected only when you actively initiate a clock-in or clock-out action — we do not continuously track your location
- Is used exclusively to confirm on-site presence for payroll accuracy and client reporting
- Is retained as part of your employment records and may be used for dispute resolution
- Will not be used for profiling, marketing, or shared with unrelated third parties
4. SMS & Phone Communication Consent
You receive SMS messages from Workforce Connect (WFConnect) / 1001328662 ONTARIO INC. only when you voluntarily opt in, such as by checking the SMS consent box on a website form at https://apply.wfconnect.org or https://www.wfconnect.org, or by otherwise giving express consent to us.
Providing a phone number alone, or submitting a form without choosing SMS consent, does not enroll you in SMS messaging. SMS consent is optional and is not a condition of employment, application approval, or service.
When you opt in, communications may include:
- Application status updates and interview scheduling
- Onboarding instructions and document requests
- Shift scheduling, assignment confirmations, and schedule changes
- Shift reminders and last-minute updates
- Payroll notifications and payment confirmations
- General employment-related announcements
Message frequency may vary. Message and data rates may apply. Reply STOP or CANCEL to opt out of text messages at any time. Reply HELP for assistance. For additional support, contact us at privacy@wfconnect.org or call +1 (437) 475-6699.
For assistance, reply HELP or contact support@wfconnect.org.
4.1 Nature of Consent
Consent to receive SMS communications is optional and is not a condition of employment, application approval, or service. You may withdraw SMS consent at any time by replying STOP or CANCEL to any text message, by contacting us in writing, or by updating your preferences within the Workforce Connect platform. Please note that opting out of SMS may affect our ability to communicate by text regarding active assignments, but it does not withdraw consent for communications required by law or by an active work relationship through other channels.
4.2 Messaging Platform
Our SMS and calling services are operated through registered messaging service providers and are subject to applicable 10DLC (10-Digit Long Code) and A2P (Application-to-Person) carrier registration requirements. All messages sent through our platform are staffing, workforce coordination, support, or operational communications registered under our authorized campaign use case.
4.3 Opt-Out Instructions
- SMS: Reply STOP or CANCEL to any message to immediately stop receiving text messages.
- Phone Calls: Verbally request removal from calling lists, or submit a written opt-out request to privacy@wfconnect.org.
- Email: Use the unsubscribe link in any email or send an opt-out request to privacy@wfconnect.org.
5. We Do Not Sell Your Personal Information
We do not sell, rent, share, transfer, or distribute personal information, including phone numbers, mobile opt-in data, and SMS consent records, to third parties or affiliates for marketing, lead generation, or promotional purposes.
This commitment applies fully and without exception to all categories of personal information we collect, including but not limited to:
- Names and contact information (phone numbers, email addresses, mailing addresses)
- Social Insurance Numbers (SIN) and government-issued identification
- Payroll and financial data
- Employment history, resumes, and credentials
- Location and attendance data
- Any other personal information collected through our application forms, mobile app, or website
We do not participate in data broker relationships, data monetization programs, or any arrangement in which personal information is exchanged for consideration. Your data is used exclusively to provide, operate, and improve Workforce Connect's staffing and workforce management services for employment purposes.
The above non-sale commitment is absolute. No carve-out exists for marketing, advertising networks, lead generation companies, affiliates, or data aggregators. Phone numbers, mobile opt-in data, and SMS consent records collected through SMS consent flows are used solely for Workforce Connect operational communications described in Section 4 of this policy.
SMS Communications & Personal Information
Workforce Connect does not sell, rent, share, or disclose consumer personal information, including phone numbers, to third parties or affiliates for marketing, promotional, or lead generation purposes.
Phone numbers collected for SMS consent are used only for Workforce Connect service-related communications, including job opportunities, shift updates, scheduling, reminders, and support.
Users may opt out of SMS communications at any time by replying STOP or CANCEL, or request assistance by replying HELP. Message and data rates may apply.
6. Disclosure to Third Parties
We do not disclose your personal information to third parties except in the limited circumstances described below. All third parties who receive personal information from us are bound by contractual confidentiality obligations and are permitted to use the data only for the specified purpose.
6.1 Client Hotels and Facilities
When you are placed on an assignment at a client hotel, resort, or facility, we share operationally necessary information with that client, which may include your name, contact information, certifications, and attendance records. This disclosure is necessary to facilitate your work engagement and is covered under your subcontractor agreement.
6.2 Payroll & Financial Service Providers
We work with payroll service providers and banking institutions to process payments and issue pay stubs. These providers receive the minimum necessary financial data to complete transactions on your behalf.
6.3 Technology & Infrastructure Providers
We use reputable cloud hosting, database management, and communication technology providers to operate our platform. These providers process data on our behalf as data processors and are contractually prohibited from using your data for any purpose other than providing services to us.
6.4 Legal and Regulatory Requirements
We may disclose personal information when required by applicable law, court order, search warrant, or government authority, or when necessary to:
- Comply with legal obligations under Canadian federal or provincial law
- Respond to lawful requests from law enforcement or regulatory bodies
- Protect the legal rights, property, or safety of Workforce Connect, our workers, clients, or the public
- Investigate fraud, security incidents, or policy violations
6.5 Business Continuity
In the event of a merger, acquisition, corporate restructuring, or sale of assets involving 1001328662 ONTARIO INC., personal information may be transferred to a successor entity. Any such transfer will be subject to equivalent privacy protections and, where required by law, individual notice.
6.6 Aggregated and Anonymized Data
We may use aggregated, de-identified, or anonymized data (from which individual identities have been irreversibly removed) for operational reporting and service improvement. Such data cannot reasonably identify any individual and is not considered personal information under PIPEDA.
7. Data Security
We implement a layered set of technical, administrative, and physical safeguards proportionate to the sensitivity of the data we hold.
7.1 Technical Measures
- Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 / 1.3.
- Encryption at Rest: Sensitive records including government ID data, SIN, and financial details are encrypted at rest using AES-256 or equivalent.
- Password Security: User account passwords are hashed using bcrypt or equivalent one-way algorithms and are never stored in plaintext.
- Access Controls: Role-based access controls (RBAC) ensure staff can only access personal information relevant to their specific function.
- Multi-Factor Authentication (MFA): Administrative portal access is protected by multi-factor authentication.
- Regular Security Updates: Our systems undergo regular security assessments, dependency updates, and vulnerability patching.
7.2 Administrative Measures
- Confidentiality obligations for all staff and contractors with access to personal data
- Internal privacy training for staff handling sensitive applicant information
- Documented data handling procedures and incident response protocols
7.3 Limitations and Breach Notification
While we employ industry-standard measures, no system is perfectly secure. In the event of a confirmed data breach affecting your personal information, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA's mandatory breach reporting rules.
8. Data Retention
We retain personal information only for as long as necessary for the purposes described in this policy or as required by Canadian law.
| Category of Data | Retention Period | Basis |
|---|---|---|
| Active worker employment records | Duration of engagement + 3 years | Operational / legal |
| Payroll and tax records (T4, earnings) | Minimum 7 years | Income Tax Act (Canada) |
| SIN records | Minimum 7 years post-last tax filing | CRA requirement |
| Signed subcontractor agreements | 7 years from signing date | Contract law / dispute resolution |
| Resumes and application forms | 2 years (non-successful); duration of engagement (hired workers) | Recruitment / operational |
| SMS and communication logs | 2 years | Regulatory / dispute resolution |
| GPS / attendance records | 3 years | Payroll / audit |
| Website analytics / cookies | Up to 13 months | Technical / operational |
| Inactive accounts (no activity) | Deleted after 2 years of inactivity | Data minimization |
Upon expiry of applicable retention periods, personal information is securely deleted or anonymized such that it can no longer be attributed to an identifiable individual.
9. Cookies & Website Analytics
9.1 What Are Cookies?
Cookies are small text files placed on your device by a website you visit. They help the website function properly, remember your preferences, and collect anonymous analytical data about how the site is used.
9.2 Types of Cookies We Use
| Type | Purpose | Duration |
|---|---|---|
| Essential / Functional | Required for login sessions, form submissions, and basic website operation | Session / up to 30 days |
| Analytics | Anonymized data on page views, traffic sources, and user flows to improve our website | Up to 13 months |
| Security | CSRF protection tokens and fraud prevention signals | Session |
9.3 No Advertising or Tracking Cookies
We do not use advertising networks, cross-site tracking cookies, retargeting pixels, or behavioural advertising technologies. Your browsing activity on wfconnect.org is not shared with advertising platforms or data brokers.
9.4 Managing Cookies
Most web browsers allow you to manage cookie preferences through their settings menus. Disabling essential cookies may impair your ability to use certain features of our website or application portal.
10. Your Rights & Opt-Out
As a Canadian resident, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
10.1 Right of Access
You have the right to request a copy of the personal information we hold about you, and to receive information about how it is being used and disclosed. We will respond to verified access requests within 30 days, as required by PIPEDA.
10.2 Right to Correction
If personal information we hold about you is inaccurate, incomplete, or outdated, you may request a correction. We will update records promptly and, where appropriate, notify any third parties to whom we have disclosed the information.
10.3 Right to Withdraw Consent
You may withdraw consent for the collection, use, or disclosure of your personal information at any time, subject to legal and contractual restrictions. Withdrawal of consent for non-mandatory purposes will not affect employment decisions.
10.4 Right to Deletion
Subject to applicable legal hold requirements, you may request deletion of your personal information. Where records must be retained under statutory obligations, we will inform you of the applicable retention period.
10.5 Right to Opt Out of SMS / Phone / Email Communications
- Reply STOP or CANCEL to any SMS message to immediately unsubscribe from text messages
- Reply HELP to any SMS message to receive contact support information
- Email privacy@wfconnect.org to opt out of phone or email communications
- Submit a written opt-out request through the Workforce Connect worker portal
10.6 Right to Lodge a Complaint
If your concern has not been resolved through our internal process, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC):
- Website: www.priv.gc.ca
- Toll-free: 1-800-282-1376
10.7 Account Deletion Request
Workers may request full account deletion by navigating to account settings within the Workforce Connect app or by contacting privacy@wfconnect.org. Payroll and tax records may be retained as required by law regardless of account deletion.
11. Children's Privacy
The Workforce Connect platform and application portal are intended exclusively for individuals who are legally eligible for employment in Canada — a minimum of 18 years of age (or the applicable provincial minimum working age, whichever is higher).
We do not knowingly collect personal information from individuals under 18. If we become aware that we have inadvertently collected personal information from a minor, we will promptly delete that information. If you believe a minor has submitted information through our platform, please contact us immediately at privacy@wfconnect.org.
12. Legal Basis for Processing (PIPEDA & Canadian Privacy Law)
Workforce Connect's collection, use, and disclosure of personal information is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, as well as applicable Ontario and provincial employment and privacy legislation.
We collect and use personal information on the following bases:
- Consent: You have given express consent (e.g., by completing an application form, signing a subcontractor agreement, or voluntarily opting in to SMS communications)
- Contractual Necessity: Processing is necessary to perform our obligations under your subcontractor agreement
- Legal Obligation: Processing is required to comply with applicable Canadian law (e.g., tax reporting, employment records under the Employment Standards Act)
- Legitimate Interest: Processing is in our legitimate interest to operate a staffing platform, prevent fraud, and maintain platform security — where those interests are not overridden by your privacy interests
Cross-Border Note: Our servers are located in Canada and/or the United States. If you are located outside Canada, by submitting information to us you acknowledge that your data may be transferred to and processed in Canada or the United States, which may have different privacy laws than your country of residence.
13. Terms & Conditions
This Privacy Policy should be read alongside our Terms and Conditions (available at www.wfconnect.org/terms) and the Subcontractor Agreement that all registered workers are required to sign prior to commencing assignments. In the event of any inconsistency between this Privacy Policy and those documents with respect to privacy matters, this Privacy Policy shall prevail.
By submitting an application through https://apply.wfconnect.org, creating an account on the Workforce Connect platform, or signing a subcontractor agreement, you acknowledge that you have read, understood, and agreed to this Privacy Policy and our Terms and Conditions.
14. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:
- Update the "Last Revised" date at the top of this page
- Post the updated policy at https://www.wfconnect.org/privacy
- Send notice by email or in-app notification to registered workers where the changes materially affect their rights
Your continued use of Workforce Connect services following the posting of changes constitutes acceptance of the revised policy. If you do not agree, you must discontinue use of our services and may request account deletion as described in Section 10.7.
SMS Communications
By voluntarily opting in through our website forms, you consent to receive SMS communications from 1001328662 Ontario Inc. regarding staffing opportunities, interview scheduling, onboarding updates, shift coordination, operational notifications, and customer support communications. SMS consent is optional and is not a condition of employment, application approval, or service.
Message frequency varies.
Message and data rates may apply.
Reply STOP or CANCEL to unsubscribe at any time.
Reply HELP for assistance.
We do not sell, rent, or share mobile opt-in data or consent with third parties for marketing purposes.
SMS Data Protection and Non-Transfer Policy
We do not transfer or share consumer SMS opt-in data, phone numbers, or consent records with any external organization, third party, or affiliate for marketing or promotional purposes.
Trusted service providers may process SMS data only to operate messaging services on our behalf, under confidentiality obligations, and may not use the data for their own marketing or promotional purposes.
We never sell consumer SMS opt-in data or use it for third-party marketing.
We maintain administrative, technical, and contractual safeguards designed to protect user data against unauthorized access, disclosure, alteration, or misuse.
15. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices — including requests to access, correct, or delete your personal information — please contact our Privacy Office:
Privacy Office — Workforce Connect (WFConnect)
Legal Entity: 1001328662 ONTARIO INC.
Email: privacy@wfconnect.org
Phone: +1 (437) 475-6699
Website: www.wfconnect.org
Ontario, Canada | Response time: within 30 days as required by PIPEDA
This Privacy Policy was last reviewed and approved by 1001328662 ONTARIO INC. on April 22, 2026.
Document version: 2.0 — Production / Compliance Release