Worker Privacy Act Mandates Quick Sharing of Employee Contact Lists, Limits Union Use to Elections Only

The new Worker Privacy Act lays down some strict rules for how employee contact information gets shared—and protected—during union organizing efforts. Essentially, when the National Labor Relations Board (NLRB) sets a date for a union election, employers have just two business days to hand over a list of eligible voters to any labor organization petitioning for representation. This list must include the employee’s name and, critically, no more than one form of personal contact information, which the employee must have chosen in writing. This tight turnaround and privacy safeguard are the core changes here.

The Two-Day Data Drop

For employers, this bill translates into a new administrative sprint. If the NLRB directs an election, the clock starts ticking immediately. You have 48 hours to compile the list in a searchable electronic format approved by the Board. If you’re a manager at a large company, that’s a significant, sudden demand on HR resources. The bill does allow an employer to certify that they simply cannot produce the list in the required electronic format, but that exception is likely going to be a tough sell to the NLRB. Failure to comply with the timing or format requirements is considered an Unfair Labor Practice (ULP), which is the NLRB’s version of a serious foul.

Privacy Firewall for Employees

For employees, the most important part of this bill is the privacy protection built into the data sharing. If you’re voting in an election, the union only gets your name and one way to reach you (phone, email, home address, etc.)—and only the one you specifically chose. This is a big win for control. You don't have to worry about a union getting every piece of contact info your employer has on file.

Strict Rules for Union Contact

While the bill makes it easier for unions to get in touch with potential members quickly, it severely restricts what they can do with that information. Once a union gets the list, they can only use the contact data for purposes directly related to the representation proceeding (i.e., the election). If they use it for anything else—say, general union business or organizing at another facility—that’s a ULP. Even more strictly, once the election process is over, the union is required to stop using the information entirely. This creates a tight firewall around the data, ensuring it’s not leveraged for long-term organizing outside of the immediate election context.

The Fine Print on Misuse

This bill creates accountability on both sides. Employers face a ULP for not providing the list quickly and correctly. Labor organizations face a ULP if they fail to protect the personal information or use it outside the scope of the election. For the union, this means strict data security protocols are now mandatory. However, the bill is clear: if an employee voluntarily gives their contact information directly to the union, the union can use it for anything—the restrictions only apply to the limited list provided by the employer. The biggest challenge here will be defining the exact boundaries of a “representation proceeding.” Depending on how the NLRB interprets that term, it could either give unions enough runway to campaign effectively or choke off communication prematurely.