Personal Information Protection Policy

The main purpose of this policy is to ensure the protection of personal information while establishing clear guidelines for the collection, use, disclosure, retention, destruction and management of data within Réseau Vos Oreilles. This applies to all stakeholders, including management, employees, suppliers, etc. In addition, this policy is intended to inform all data subjects, whether customers, employees or other individuals, about how Réseau Vos Oreilles handles their personal information.

RESPONSIBILITY

Réseau Vos Oreilles assumes full responsibility for the preservation of personal information under its jurisdiction. Data collected, used, communicated, retained or destroyed is subject to the provisions of this policy with the primary goal of preserving the confidentiality of each individual.

To ensure the most effective protection of personal information, Réseau Vos Oreilles’ data security officers must:

  • Oversee and review internal practices and procedures for handling personal information, as well as compliance with current legislation;
  • Suggest measures to ensure the ongoing protection of personal information that are consistent with Privacy Impact Assessments;
  • Implement the necessary measures within the company to ensure the protection of information;
  • Ensure staff compliance and training in best practices for protecting personal information.
  • Coordinate, investigate and respond to privacy requests and complaints;
  • Communicate with the person(s) concerned and the Commission d’accès à l’information (CAI) in the event of a data leak or any other incident;
  • Keep a register of incidents relating to personal data.

The protection of personal information is everyone’s business. No reprisals will be taken against an individual who files a privacy complaint or participates in a CAI investigation.

COLLECTION OF PERSONAL INFORMATION

The personal information collected allows Réseau Vos Oreilles to perform its duties and conduct its activities in accordance with applicable laws and standards. Réseau Vos Oreilles collects personal information only when it is necessary and for specific, pre-defined purposes. Personal information is collected directly from the person concerned and with his or her consent, unless an exception is provided for by law.

A non-exhaustive list of the information collected and its intended use can be found in Appendix A. The majority of personal information collected concerns employees in order to meet the company’s legal obligations. The disclosure of personal information of other individuals may be requested to assist employees in an emergency, for example. It is the responsibility of employees to obtain their consent before providing us with their contact details.

As far as customer information is concerned, data is supplied to feed our files, management software, contracts and invoicing. We attach the utmost importance to the confidentiality and security of our customers’ data. All information collected, whether contact details or other personal information, is treated with the utmost rigor and in compliance with current laws and regulations on the protection of personal information. Our team is committed to putting in place robust security measures to prevent unauthorized access, as well as regularly training our staff on best practices in data confidentiality. We regard the protection of our customers’ personal information as a fundamental responsibility to ensure their well-being and their trust in our services.

CONSENT AND ACCURACY OF PERSONAL INFORMATION

Réseau Vos Oreilles ensures that personal information is collected for justified, clear and specific reasons and with the free and informed consent of the individual. Consent is required for any collection, use or disclosure of personal information. Before collecting personal information, we will ensure that we obtain your informed consent in a separate written document, providing you with clear details of the purpose of the collection and how the information will be used. Your consent is essential to ensure the protection of your personal data.

LIMITS ON THE USE OF PERSONAL INFORMATION

We collect and use your personal information only when necessary and for the purposes for which consent was obtained. Réseau Vos Oreilles is required to provide certain information in order to meet legal and regulatory audit requirements and processes. Use may vary, but could include different purposes as illustrated in Appendix A.

Information may be passed on to third parties to the extent necessary for the purposes of the activities mentioned in Appendix A. Réseau Vos Oreilles cannot be held responsible for the behavior and use of third parties.

Personal information will not be used or disclosed for purposes other than those for which it was collected, unless required by law.

PROTECTING YOUR PERSONAL INFORMATION

Réseau Vos Oreilles takes all reasonable precautions and implements significant physical and technical measures to prevent unauthorized or unlawful use of or access to personal information. These measures include, but are not limited to, the following:

  • Use information only when necessary;
  • To ensure the confidentiality and protection of personal information that comes to the attention of a person in the course of his or her duties, unless the person concerned authorizes the disclosure.
  • File protection with selective access limited to authorized persons;
  • Secure office access with locked doors and access codes;
  • Secure shredding of paper files;
  • Double authentication for all platform connections;
  • Immediate withdrawal of access following termination of a business relationship.

All individuals are required to contribute to the protection of personal information. If you suspect that sensitive information has been compromised, you must immediately notify a privacy officer.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Réseau Vos Oreilles is committed to respecting the minimum retention periods stipulated according to the category of personal information and applicable laws. However, if the information collected is no longer useful to Réseau Vos Oreilles and its retention is not necessary or mandatory under the various legislative frameworks, it will be destroyed, erased or converted so as to remain anonymous.

COMMITMENT TO TRANSPARENCY

Réseau Vos Oreilles is committed to being transparent about the processing, procedures and purposes for which personal information is collected from customers, employees, interns and business partners.

ACCESS TO YOUR PERSONAL INFORMATION

An individual may request access to his or her personal information and the means by which it was collected. Depending on the content of the individual’s file, exceptions may apply, such as personal information about a third party, but the individual will be informed. In the event of inaccurate information in the file, the person concerned may ask for it to be corrected.

For any consultation, withdrawal and/or modification of personal information, you may write to the e-mail addresses listed below. You may withdraw your consent to the disclosure of your personal information at any time. A written request should be submitted to one of our Privacy Officers by e-mail. A response will be provided within 30 days of receipt. Where it is not possible to share the requested information, legal justification and support will be provided to support the decision with the requestor.

COMPLAINTS

An individual who believes that his or her personal information has been collected, retained, used, disclosed or destroyed in a manner inconsistent with the provisions of this policy, may make a confidential complaint to a Privacy Officer at the e-mail address indicated below. The individual will be asked to provide his or her name, contact information, including a telephone number, as well as the purpose and reasons for the complaint. It is necessary to provide sufficient detail for the complaint to be properly evaluated. A response will be provided within 30 days of receipt of the complaint. If the complaint is insufficiently specific, a Privacy Officer may request any additional information deemed necessary to assess the complaint. A Privacy Officer will investigate complaints received, minimize damage and take any necessary corrective action.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec. However, Réseau Vos Oreilles encourages those concerned to contact one of our privacy officers first, and to await the conclusion of the planned treatment process.

Links to other sites

This policy has been approved by Réseau Vos Oreilles’ Privacy Officers. Persons responsible for the protection of personal information

Judith Dupras
1130 Avenue Beaumont #110
Mont-Royal, QC H3P 3E5

1-514-737-1616
j.dupras@vosoreilles.com

 

Justin Tremblay
669, rue Laviolette
Trois-Rivières, QC G9A 1V7

1-819-379-5715
j.tremblay@vosoreilles.com

 

François Sasseville
15, rue Montclair
Gatineau, QC J8Y 2E2

1-819-771-5029
f.sasseville@vosoreilles.com

If you have any requests, questions or comments regarding this policy, please contact one of our managers by e-mail.

APPENDIX A

Persons concernedCategories of informationTypes of informationPurposes for which information is retained
EmployeesStaffingRecruitment information, such as curriculum vitae, educational and professional background, details of previous employers for employment verification for potential recruitment.Internal management (assessment of candidates)
Hiring (Employees and internships)Employee file information such as first and last name, contact details, SIN, remuneration, bank details, employment or internship contract, emergency contacts, etc.Internal management (payroll operations, legal obligations, CNESST, RRSPs, pay equity, performance management, etc.)
Customers and suppliersAccounting, CRM and project management systemsInformation relating to services requested and/or rendered.

Billing and financial information, such as billing address, bank account information or payment data.
Internal management (IT services, cybersecurity, billing, project management, communication management, program information collection, contracts and service agreements)