Protection of Personal Information Policy

The purpose of this policy is to guarantee the protection of personal information, as well as to define the procedures for the collection, use, communication, retention, destruction, and management of information by ImpecZone, which includes management, employees, suppliers, etc. Furthermore, it aims to inform any concerned individual about the processing of their personal information by Couvertures Beaupré & Fils, whether it pertains to clients, employees, or any other persons.

RESPONSIBILITY

Couvertures Beaupré & Fils assumes full responsibility for the protection of the personal information under its control. Information collected, used, communicated, retained, or destroyed is governed by this policy with the objective of protecting the privacy of every individual.

To ensure optimal protection of personal information, the person responsible for the protection of personal information at Couvertures Beaupré & Fils must:

  • Supervise and review internal practices and procedures for handling personal information as well as compliance with current laws;
  • Suggest measures to ensure the ongoing protection of personal information that align with privacy impact assessments;
  • Implement the necessary measures within the company to ensure information protection;
  • Ensure staff compliance and training regarding best practices for protecting personal information.
  • Coordinate, investigate, and respond to requests and complaints related to the protection of personal information;
  • Communicate with the concerned person(s) and the Commission d’accès à l’information (CAI) in the event of a data leak or any incident;
  • Maintain a registry of incidents related to personal data.

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

COLLECTION OF PERSONAL INFORMATION

The personal information collected allows Couvertures Beaupré & Fils to perform its functions and conduct its activities in accordance with applicable laws and standards. Couvertures Beaupré & Fils collects personal information only when necessary and for specific, predefined purposes. The collection of personal information is done directly from the person concerned and with their consent, unless an exception is provided by law.

You will find in Appendix A a non-exhaustive list of the information collected and the intended use of the data. The majority of the personal information collected concerns employees to meet the company’s legal obligations. The communication of personal information of other individuals may be requested to assist employees in case of emergency, for example. It is the responsibility of employees to obtain their consent before providing us with their contact details.

Regarding client information, data is provided to populate our CRM, contracts, and billing, but it is mostly professional or business-related information such as email and phone numbers to contact them, or payment methods for services rendered. Payment information is entered, as often as possible, by the client into the CRM and is masked for the rest of the company members to ensure confidentiality. For clients who have completed a form including their credit card or business/professional bank account number, the data is only accessible by a small number of employees, such as administration and owners, to process the files.

CONSENT AND ACCURACY OF PERSONAL INFORMATION

Couvertures Beaupré & Fils ensures that the collection of personal information is done 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 we obtain your informed consent in a written and distinct manner, providing you with clear details on 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. Couvertures Beaupré & Fils must provide certain information to satisfy legal and regulatory audit processes and requirements. Use may vary, but could notably serve different purposes as illustrated in Appendix A.

Information may be transmitted to third parties to the extent necessary for the activities mentioned in Appendix A. Couvertures Beaupré & Fils cannot be held responsible for the behavior and usage undertaken by third parties.

Personal information will not be used or communicated for purposes other than specific objectives unless required by law.

PROTECTION OF YOUR PERSONAL INFORMATION

Couvertures Beaupré & Fils takes all reasonable precautions and has implemented significant physical and technical measures to prevent unauthorized or illegal use and access to personal information. Thus, the measures in place include, among others:

  • Using information only when necessary;
  • Ensuring the confidentiality and protection of personal information that a person may have become aware of in the course of their duties, unless authorized to disclose it by the person concerned.
  • Protection of files with selective and limited access to authorized persons;
  • Securing access to offices with door locks and access codes;
  • Secure shredding of paper files;
  • Two-factor authentication for all platform logins;
  • Immediate removal of access following the end 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 the person responsible for the protection of personal information.

RETENTION PERIOD OF YOUR PERSONAL INFORMATION

Couvertures Beaupré & Fils undertakes to respect the minimum retention periods provided according to the category of personal information and applicable laws. However, if the information collected is no longer useful for Couvertures Beaupré & Fils and its retention is neither necessary nor mandatory according to various legislative frameworks, it will be destroyed, erased, or converted to maintain anonymity.

COMMITMENT TO TRANSPARENCY

Couvertures Beaupré & Fils is committed to being transparent regarding the processing, procedures, and purposes of use governing personal information for clients, employees, interns, and business partners.

ACCESS TO YOUR PERSONAL INFORMATION

An individual may request access to the personal information concerning them and the means used to collect it. Depending on the content of the individual’s file, exceptions may apply, such as personal information concerning others; however, the individual will be informed of this. In the event of inaccurate information in the file, the person concerned may request a correction.

For any consultation, withdrawal, and/or modification of personal information, you may write to the email address in**@***********ls.com. At any time, you may withdraw your consent to the communication of your personal information. A written request must be submitted to the person responsible for the protection of personal information at in**@***********ls.com. A response will be provided to you within 30 days of its receipt. When it is not possible to share the requested information, a legal justification and support must be provided to the applicant to back the decision.

FILING A COMPLAINT

An individual who believes that their personal information has been collected, retained, used, disclosed, or destroyed in a manner inconsistent with the provisions of this policy may file a confidential complaint with the person responsible for the protection of personal information at the email address in**@***********ls.com. The individual must provide their name, contact details, including a telephone number, as well as the subject and grounds for the complaint. It is necessary to provide sufficient details so that the complaint can be properly evaluated. A response will be provided to you within 30 days of receipt of the complaint. If the complaint is insufficiently precise, the person responsible for the protection of personal information may request any additional information deemed necessary to evaluate the complaint. The responsible person will conduct an investigation into the complaints received, minimize damages, and implement necessary corrections.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec. However, Couvertures Beaupré & Fils encourages the individuals concerned to first contact the person responsible for the protection of personal information and await the conclusion of the established processing procedure.

APPROVAL

This policy is approved by the person responsible for the protection of personal information within Couvertures Beaupré & Fils.

Person responsible for the protection of personal information:
90 rue Denis, Lourdes-de-joliette, QC J0K 1K0
in**@***********ls.com

For any request, question, or comment regarding this policy, please contact the responsible person by email.

APPENDIX A

Concerned Persons
Information Categories
Types of Information
Purposes for which Information is Retained
Employees
Staffing
Information related to recruitment, such as a resume, information on educational and professional background, details concerning previous employers for employment verification for potential recruitment.
Internal management (evaluation of applications)
Hiring (Employees and internships)
Information related to establishing the employee file such as first and last name, contact details, SIN, compensation, banking information, employment or internship contract, emergency contacts, etc.
Internal management (payroll operations, legal obligations, CNESST, RRSP, Pay Equity, performance management, etc.)
Clients and suppliers
Accounting management system, CRM, and project management

Information related to services requested and/or rendered.

Information related to billing and financial information, such as a billing address, information related to a bank account, or payment data.

Internal management (IT services, cybersecurity, billing, project management, communication management, information collection within the framework of a program, contract, and service agreement)