Implications for Employers: New Alberta Driver’s Licenses and Privacy Obligations

Starting July 2, 2026, newly issued or renewed driver’s licences and ID cards will now display:

(1) personal health numbers (“PHNs”); and

(2) Canadian citizenship markers (when applicable).

A personal health number can only legally be collected by certain organizations for certain purposes. Organizations now risk the over collection of personal information, which creates privacy management risks for employers who regularly collect employee identification information as part of their operations.

Next Steps for Private Sector Employers

1) Check if there a statutory/ legislative requirement for you to collect, copy, or record citizenship markers or the personal health numbers of your employees.

2) If there is no statutory or legislative requirement, review your existing identity verification practices to ensure that you do not over collect personal information.

We recommend:

• Checklists instead of Photocopying: Determine to what extent copies of employee’s driver’s licences need to be retained/ copied, if at all.
  • Ex: Where your purpose for retaining the personal information is simply to confirm that an employee holds a valid licence, it may be sufficient to simply review the employee’s licence, record the licence number, class, and expiry date. Alternatively, have a checklist confirming you reviewed their licence instead of retaining a photocopy or a scan.
• Redacting the PHN: If you need a photocopy of a driver’s licence, redact the personal health number from any photocopies or scans.
  • PHNs can only be collected where it is provided voluntarily and authorized by statute. You cannot ‘accidently’ hold a copy of a PHN.
• Provide direction to staff responsible for collecting personal information.

3) If there is a statutory requirement to collect copies of someone’s driver’s licence:

• Ensure you know how to respond to questions from employees regarding your statutory requirements to collect personal information.
• If appropriate, update collection documents to specify the legal authority relied upon for any collection of citizenship or health information, including PHNs.

A Note on Citizenship

The citizenship marker is not an accurate reflection of working eligibility, and reliance on it for making hiring decisions may expose employers to claims under the Alberta Human Rights Act, which prohibits discrimination based on an individuals place of origin.

The citizenship marker on the driver’s licences does not include permanent residents, holders of a valid work permit, and protected persons—all of whom are eligible to work in Canada. Ensure human resources personnel are instructed to verify working eligibility using a person’s Social Insurance Number and/or relevant immigration documents.

Our Employment Law Group helps you pinpoint and avoid vulnerabilities and liabilities in your agreements,
policies, and practices. Prevent employment issues before they occur so that you can reduce damages,
resolve ongoing employment disputes, and focus on your business operations.

Receive our Employment Law Newsletter with invites to upcoming webinars by contacting Group Lead, Kerry Lynn Okita, KC.