I’m from the U.K. and moved to Ontario, Canada last year. I’m a dual citizen.
I’ve found Canadian workplace rights more influenced & similar to US rights, and the U.K. closer to Europe. Not as good, and maybe getting worse because of Brexit.
I’ve been a bit shocked at the difference as I considered Canada a more progressive country before. Examples: Canada has 10 days of holiday off a year. U.K.: at least 28 not including bank holidays. U.K. sick days are separate (my Canadian employer said they were included in the 10 days), and have more allowance. In Canada, to get private health insurance this is normally through a job. My past job didn’t have any benefits, and many minimum wage jobs don’t apparently. In the U.K. the NHS is available to everyone. Prescriptions are set under £10 for everyone. In Canada as I don’t have insurance, I’ve had some expensive prescriptions. With the NHS you don’t need a job or private insurance. Pensions are usually standard in the U.K.; again this seems to be a “benefit” in Canada that I didn’t get with my old job. Many companies now in Canada seem to hire contract jobs so even if you’re a long term employee you have less rights.
I don’t know that much about Canadian workplace rights and law so correct me if wrong about anything. Some Canadian friends told me they think accommodations are better here than in the U.K. But they have never worked in the U.K.
They said if I disclose my accommodations when I first join in a letter with a Drs note, legally companies in Canada have to take them. This would be better in larger companies with larger HR departments who can’t abuse employment law apparently. In the U.K. this is also true, however past large companies I worked for found ways to delay, manipulate or ignore my accommodations. So I’m not sure if it’s the same in Canada too. As the workplace rights in general seem worse.
Because of all this, I’ve been wondering whether it would be better to go back to the U.K. I’ve been looking into Scotland too even though I’m from England as I’m worried how things might get worse there with the Tories, and I’ve heard some things about how Scotland is better. If I’m wrong about anything please correct me respectfully. I’m just looking for more information and understanding of how workplace rights differ in each country. Especially if you have lived in more than one, your perspective is helpful!