Indigenous reconciliation TRC Call 92 and workforce data ethics
June 25, 2026 · 5 min
Your major mining client has asked, in writing, what your company is doing to implement Call to Action 92 of the Truth and Reconciliation Commission across the workforce engaged on the project. The procurement team wants the answer in your next submission. The HR director points to the land acknowledgement on the website. The client’s Indigenous community liaison reads it, and the silence that follows is its own answer. The conversation about workforce data and reconciliation has just stopped being a statement on a page and become a question you have to answer with substance.
That gap, between an acknowledgement and a practice, is where most corporate reconciliation work currently sits. Closing it is not a communications task. It is an operational one, and for an employer with a deskless workforce it reaches directly into how time and location data are handled.
What Call 92 actually asks of business
The Truth and Reconciliation Commission’s final report issued ninety-four Calls to Action, and Call 92 is the one addressed to the corporate sector. It calls on Canadian business to adopt the United Nations Declaration on the Rights of Indigenous Peoples as a reconciliation framework, to commit to meaningful consultation, to ensure that Indigenous peoples have equitable access to jobs, training and education opportunities, and to give management and staff genuine education on the history of Indigenous peoples.
The federal legislation that made the United Nations Declaration a commitment of the Crown, and the action plan that followed it, have moved this from aspiration toward obligation for business operating in federally regulated sectors, and provincial declarations extend the framework further. What Call 92 means for workforce data specifically is that the data practices applied to Indigenous workers, to the communities on whose territory the work takes place, and to Indigenous suppliers in the chain, have to carry the reconciliation principles rather than contradict them. The practical framework most often applied is the set of principles known as Ownership, Control, Access and Possession, developed by the First Nations Information Governance Centre, and it sits alongside the Declaration’s affirmations of the right to participate in decisions and of free, prior and informed consent.
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These principles apply most directly to data that is collective, at the level of a community, rather than purely individual. For workforce GPS data the principle that bites first is Control: where a workforce is predominantly Indigenous, on a project on Indigenous land, the community has a legitimate interest in how its members’ data is collected, used and stored. A number of Indigenous Nations have negotiated impact-benefit agreements that already include explicit data-governance clauses, and those clauses expect the platform to support community-level access, retention and consent, not merely the employer’s.
The operating model that genuinely answers Call 92 rests on four things. Transparency, so that the Indigenous worker, and the community where it is relevant, knows what data is collected and why. Consent that is meaningful and informed, and that can be withdrawn without any retaliation following. Access, so the worker, and the community where an agreement provides for it, can see the data and challenge it. And retention that ends when the purpose ends, rather than data warehoused indefinitely because storage is cheap. None of those four is exotic. What is new is the expectation that they are demonstrated, not asserted.
Joint ventures and the data clauses in the agreement
Where a workforce is engaged through a joint venture between a proponent and an Indigenous economic-development corporation, the data-governance clauses in the agreement have become noticeably more explicit. Common provisions include community-level reporting on aggregate hours, training participation and safety performance, a community right of audit, an individual right of access, restrictions on any use beyond the agreed purposes, and destruction of the data when the contract ends.
A platform has to be able to support those clauses operationally, not just acknowledge them in a signature. Community-level reporting needs aggregation views that protect individual privacy while still being useful. A right of audit needs immutable logs. A right of access needs a real self-service path for the worker. Destruction at the end of the contract needs retention rules tied to the contract term, so it happens by design and not by anyone remembering.
Why this is a procurement question
This is not only an ethical matter, though it is that. Indigenous communities and Indigenous-affiliated procurement bodies increasingly procure services on terms that require Call 92 to be implemented in practice, and they condition supplier eligibility on reconciliation evidence rather than reconciliation statements. A supplier who can put forward a workforce-data-governance framework consistent with the OCAP principles and the Declaration has a real procurement advantage. A supplier who can offer only a website paragraph is, more and more often, screened out before the conversation begins.
GeoTapp’s data-governance model is built to support that configuration: community-level aggregations, transparent worker access, retention rules tied to the contract, immutable audit logs. It lets the reconciliation conversation move from a line on a homepage to operational evidence a client and a community can examine. That shift, from acknowledgement to practice, is what Call 92 asks of corporate Canada. Start a free fourteen-day trial, with no card, and be ready to answer the procurement question with substance.
Has a client or a community partner asked you to show how your workforce-data practices align with reconciliation commitments, and could you answer with more than a statement? Tell us in the comments below. It is a question moving steadily up the procurement checklist, and what you write helps other employers prepare a real answer before it is asked of them.
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