Employer breached duty to bargain in good faith by refusing to disclose individual employee salaries.
The union filed an unfair labour practice complaint alleging the employer breached its duty to bargain in good faith under section 15 of the Labour Relations Act by refusing to disclose the individual salaries of bargaining unit employees during collective bargaining.
The employer argued the information was confidential and that the union had waived its right to the information through past bargaining practices.
The Board held that a trade union is entitled to the wage rates of employees in the bargaining unit it represents, as this information is necessary to fulfill its role as exclusive bargaining agent.
The Board found the employer breached section 15 and directed it to provide the requested salary information.
Southern Ontario Newspaper Guild, Local 87 The Newspaper Guild (AFL-CIO-CLC) v. The Globe and Mail, Division of Canadian Newspapers Company Limited, 1987 CanLII 3137