The Canadian Imperial Bank of Commerce (CIBC) had implemented word recognition software, Assentor, in its U.S. brokerage arm to ensure its employees were not acting inappropriately in their dealings with customers and to protect company systems from viruses. This software scanned e-mails for flagged business words and archived the e-mails in a central database. The manager of compliance at CIBC's head office in Toronto, found that the decision to implement the Assentor software was much easier than deciding what to do in the event the software found something improper. Issues related to company ethics and employee privacy were raised. Acknowledging that occasional personal e-mails would be sent and received, he wondered what the legal ramifications would be if a manager found out about a private situation because Assentor had found a flagged word in a personal e-mail. He felt that clear communication with and upfront understanding from employees would help prevent negative impressions of this process so he had to determine the best way to inform employees about the e-mail scanning while enforcing CIBC's e-mail policy.
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