PERSONAL INFORMATION PRIVATE POLICY

As a service company, we comply with the privacy laws applicable in Canada.

Under these laws:

  • The individual has a right to access personal information held by an organization and to challenge its accuracy, if need be.
  • Personal information can only be used for the purposes for which it was collected. If an organization is going to use it for another purpose, consent must be obtained again.
  • Individuals have the assurance that their information will be protected by specific safeguards, including measures such as locked cabinets, computer passwords or encryption.

This good privacy practice is one of the components of sound business management.

WHAT IS PERSONAL INFORMATION?

Personal information means any information pertaining to an identifiable individual. It can be any type of information, including:

  • Age, name, sex, residential address, health status, personal characteristics, marital status, name of spouse, personal and financial circumstances, ethnic origin, level of education, identification numbers (SIN, driver’s license, RAMQ), income, banking information, employment records, credit records, medical information;
  • Employee record, credit or loan record, information on a person’s intentions (e.g., intention to acquire goods or services, or change jobs), financial products purchased.

Personal information can be collected in a variety of forms, including written (correspondence and memoranda), as well as electronic communications and records, or recordings.

ACCOUNTABILITY UNDER THE ACT

We are accountable for the personal information that we manage. We make sure to act with due diligence in collecting, using and disclosing personal information in order to maintain the confidence and loyalty of our clients.

Ten principles serve as the basis for collecting, using and disclosing personal information:

  1. Accountability
  2. Identifying purposes
  3. Consent
  4. Limiting collection
  5. Limiting use, disclosure and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual access
  10. Challenging compliance

PERSONAL INFORMATION PRIVATE POLICY

As a service company, we comply with the privacy laws applicable in Canada.

Under these laws:

  • The individual has a right to access personal information held by an organization and to challenge its accuracy, if need be.
  • Personal information can only be used for the purposes for which it was collected. If an organization is going to use it for another purpose, consent must be obtained again.
  • Individuals have the assurance that their information will be protected by specific safeguards, including measures such as locked cabinets, computer passwords or encryption.

This good privacy practice is one of the components of sound business management.

WHAT IS PERSONAL INFORMATION?

Personal information means any information pertaining to an identifiable individual. It can be any type of information, including:

  • Age, name, sex, residential address, health status, personal characteristics, marital status, name of spouse, personal and financial circumstances, ethnic origin, level of education, identification numbers (SIN, driver’s license, RAMQ), income, banking information, employment records, credit records, medical information;
  • Employee record, credit or loan record, information on a person’s intentions (e.g., intention to acquire goods or services, or change jobs), financial products purchased.

Personal information can be collected in a variety of forms, including written (correspondence and memoranda), as well as electronic communications and records, or recordings.

ACCOUNTABILITY UNDER THE ACT

We are accountable for the personal information that we manage. We make sure to act with due diligence in collecting, using and disclosing personal information in order to maintain the confidence and loyalty of our clients.

Ten principles serve as the basis for collecting, using and disclosing personal information:

  1. Accountability
  2. Identifying purposes
  3. Consent
  4. Limiting collection
  5. Limiting use, disclosure and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual access
  10. Challenging compliance

PERSONAL INFORMATION PRIVATE POLICY

As a service company, we comply with the privacy laws applicable in Canada.

Under these laws:

  • The individual has a right to access personal information held by an organization and to challenge its accuracy, if need be.
  • Personal information can only be used for the purposes for which it was collected. If an organization is going to use it for another purpose, consent must be obtained again.
  • Individuals have the assurance that their information will be protected by specific safeguards, including measures such as locked cabinets, computer passwords or encryption.

This good privacy practice is one of the components of sound business management.

WHAT IS PERSONAL INFORMATION?

Personal information means any information pertaining to an identifiable individual. It can be any type of information, including:

  • Age, name, sex, residential address, health status, personal characteristics, marital status, name of spouse, personal and financial circumstances, ethnic origin, level of education, identification numbers (SIN, driver’s license, RAMQ), income, banking information, employment records, credit records, medical information;
  • Employee record, credit or loan record, information on a person’s intentions (e.g., intention to acquire goods or services, or change jobs), financial products purchased.

Personal information can be collected in a variety of forms, including written (correspondence and memoranda), as well as electronic communications and records, or recordings.

ACCOUNTABILITY UNDER THE ACT

We are accountable for the personal information that we manage. We make sure to act with due diligence in collecting, using and disclosing personal information in order to maintain the confidence and loyalty of our clients.

Ten principles serve as the basis for collecting, using and disclosing personal information:

  1. Accountability
  2. Identifying purposes
  3. Consent
  4. Limiting collection
  5. Limiting use, disclosure and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual access
  10. Challenging compliance

Principle 1: Accountability

The Firm, its representatives and its employees are accountable for the protection and security of the personal information in their possession.

Principle 2: Identifying purposes

We will identify the purposes for which personal information is collected, either before or at the time of collection.

We collect personal information in a number of different ways, including via application forms, representatives, or claim forms, during personal interviews, or by any other means. Before or at the time of collection, we will identify the purpose of collection. This may be communicated in writing or verbally, depending upon the manner in which the information is collected.

Persons collecting personal information are expected to be able to explain to individuals the purposes for which the information is being collected.

We will not use information beyond that required to fulfill the purposes specified at the time of collection.

Principle 3: Consent

We must obtain the consent of the individual concerned for the collection, use and disclosure of personal information, subject to certain exceptions stipulated in the Act.

We will obtain consent for the use or disclosure of personal information at the time of collection. Sometimes, consent is obtained after the information has been collected but prior to use (for example, when we wish to use information for a purpose not previously identified). Consent may also be obtained in writing, verbally, electronically, or through a representative or an employee.

We may seek consent in a variety of ways, depending on the circumstances and the type of information collected. We will generally seek express consent when the personal information is likely to be considered sensitive (such as medical or financial records).

Sometimes consent may be obtained from an authorized representative, such as a legal guardian or a power of attorney.

Implied consent may be inferred in circumstances where the information is less sensitive and consent to collection, use or disclosure can be reasonably inferred.

In certain limited circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking the consent of the individual might defeat the purpose of collecting the information. Similarly, seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or otherwise incapacitated.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. However, we will inform the individual of the implications of such withdrawal, which may include termination of benefits or inability to process a claim.

Principle 4: Limiting collection

We will not collect personal information indiscriminately. The nature of the information collected will be limited to that which is necessary for the purposes identified.

Information will be collected in accordance with the company’s obligation to identify the purposes of collection and to obtain the individual’s consent to the collection, use and disclosure of personal information.

Principle 5: Limiting use, disclosure and retention

We will not use or disclose personal information for purposes other than those for which it was collected, except in cases stipulated in the Act or with the consent of the individual. Personal information will be retained only for as long as is necessary to fulfill its purposes.

Personal information that has been used to make a decision about an individual is retained long enough to allow the individual access to the information after the decision has been made.

Principle 6: Accuracy

Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is being used.

The extent to which personal information is updated will depend on what the personal information is being used for, taking into consideration the best interests of the individual. Information will be sufficiently accurate, complete and up-to-date so as to minimize the risk that inappropriate information may be used to make a decision about the individual.

We will not routinely update personal information, unless such a process is necessary to fulfil the purposes for which the information was collected, e.g., the management and services indicated in the file.

Principle 7: Safeguards

Personal information will be protected by safeguards appropriate to the sensitivity of the information.

We have implemented appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Moreover, external data backups are fully encrypted.

The methods of protection include physical, organizational and technological measures designed to limit access to authorized persons, ensure the integrity of the information, and protect it from unauthorized use or disclosure.

Safeguards also include steps to ensure that all third parties with whom we contract and who may be required to handle personal information have implemented comparable security measures.

Principle 8: Openness

Under review.

Principle 9: Individual access

We will reply within thirty (30) days of receipt of a written request for access from a client.

Upon request, we will inform the individual whether or not we hold personal information about the individual. We will permit the individual to access the information and provide an account of the use made of the information, including any disclosure to third parties (if applicable).

An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

We will reply within thirty (30) days of receipt of a challenge.

Principle 10: Challenging compliance

An individual may address a challenge concerning compliance with the principles set out above to the following person:

Isabelle Paradis
Courtage Conseil Birar Inc.
7900 boul. Taschereau, Suite 201-E
Brossard, QC J4X 2C2

We will inform individuals who make inquiries or lodge complaints of the applicable complaint handling protocol.

Principle 1: Accountability

The Firm, its representatives and its employees are accountable for the protection and security of the personal information in their possession.

Principle 2: Identifying purposes

We will identify the purposes for which personal information is collected, either before or at the time of collection.

We collect personal information in a number of different ways, including via application forms, representatives, or claim forms, during personal interviews, or by any other means. Before or at the time of collection, we will identify the purpose of collection. This may be communicated in writing or verbally, depending upon the manner in which the information is collected.

Persons collecting personal information are expected to be able to explain to individuals the purposes for which the information is being collected.

We will not use information beyond that required to fulfill the purposes specified at the time of collection.

Principle 3 : Consent

We must obtain the consent of the individual concerned for the collection, use and disclosure of personal information, subject to certain exceptions stipulated in the Act.

We will obtain consent for the use or disclosure of personal information at the time of collection. Sometimes, consent is obtained after the information has been collected but prior to use (for example, when we wish to use information for a purpose not previously identified). Consent may also be obtained in writing, verbally, electronically, or through a representative or an employee.

We may seek consent in a variety of ways, depending on the circumstances and the type of information collected. We will generally seek express consent when the personal information is likely to be considered sensitive (such as medical or financial records).

Sometimes consent may be obtained from an authorized representative, such as a legal guardian or a power of attorney.

Implied consent may be inferred in circumstances where the information is less sensitive and consent to collection, use or disclosure can be reasonably inferred.

In certain limited circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking the consent of the individual might defeat the purpose of collecting the information. Similarly, seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or otherwise incapacitated.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. However, we will inform the individual of the implications of such withdrawal, which may include termination of benefits or inability to process a claim.

Principle 4: Limiting collection

We will not collect personal information indiscriminately. The nature of the information collected will be limited to that which is necessary for the purposes identified.

Information will be collected in accordance with the company’s obligation to identify the purposes of collection and to obtain the individual’s consent to the collection, use and disclosure of personal information.

Principle 5: Limiting use, disclosure and retention

We will not use or disclose personal information for purposes other than those for which it was collected, except in cases stipulated in the Act or with the consent of the individual. Personal information will be retained only for as long as is necessary to fulfill its purposes.

Personal information that has been used to make a decision about an individual is retained long enough to allow the individual access to the information after the decision has been made.

Principle 6: Accuracy

Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is being used.

The extent to which personal information is updated will depend on what the personal information is being used for, taking into consideration the best interests of the individual. Information will be sufficiently accurate, complete and up-to-date so as to minimize the risk that inappropriate information may be used to make a decision about the individual.

We will not routinely update personal information, unless such a process is necessary to fulfil the purposes for which the information was collected, e.g., the management and services indicated in the file.

Principle 7: Safeguards

Personal information will be protected by safeguards appropriate to the sensitivity of the information.

We have implemented appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Moreover, external data backups are fully encrypted.

The methods of protection include physical, organizational and technological measures designed to limit access to authorized persons, ensure the integrity of the information, and protect it from unauthorized use or disclosure.

Safeguards also include steps to ensure that all third parties with whom we contract and who may be required to handle personal information have implemented comparable security measures.

Principle 8: Openness

Under review

Principle 9: Individual access

We will reply within thirty (30) days of receipt of a written request for access from a client.

Upon request, we will inform the individual whether or not we hold personal information about the individual. We will permit the individual to access the information and provide an account of the use made of the information, including any disclosure to third parties (if applicable).

An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

We will reply within thirty (30) days of receipt of a challenge.

Principle 10: Challenging compliance

An individual may address a challenge concerning compliance with the principles set out above to the following person:

Isabelle Paradis
Courtage Conseil Birar Inc.
7900 boul. Taschereau, Suite 201-E
Brossard, QC J4X 2C2

We will inform individuals who make inquiries or lodge complaints of the applicable complaint handling protocol.

Principle 1: Accountability

The Firm, its representatives and its employees are accountable for the protection and security of the personal information in their possession.

Principle 2: Identifying purposes

We will identify the purposes for which personal information is collected, either before or at the time of collection.

We collect personal information in a number of different ways, including via application forms, representatives, or claim forms, during personal interviews, or by any other means. Before or at the time of collection, we will identify the purpose of collection. This may be communicated in writing or verbally, depending upon the manner in which the information is collected.

Persons collecting personal information are expected to be able to explain to individuals the purposes for which the information is being collected.

We will not use information beyond that required to fulfill the purposes specified at the time of collection.

Principle 3 : Consent

We must obtain the consent of the individual concerned for the collection, use and disclosure of personal information, subject to certain exceptions stipulated in the Act.

We will obtain consent for the use or disclosure of personal information at the time of collection. Sometimes, consent is obtained after the information has been collected but prior to use (for example, when we wish to use information for a purpose not previously identified). Consent may also be obtained in writing, verbally, electronically, or through a representative or an employee.

We may seek consent in a variety of ways, depending on the circumstances and the type of information collected. We will generally seek express consent when the personal information is likely to be considered sensitive (such as medical or financial records).

Sometimes consent may be obtained from an authorized representative, such as a legal guardian or a power of attorney.

Implied consent may be inferred in circumstances where the information is less sensitive and consent to collection, use or disclosure can be reasonably inferred.

In certain limited circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking the consent of the individual might defeat the purpose of collecting the information. Similarly, seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or otherwise incapacitated.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. However, we will inform the individual of the implications of such withdrawal, which may include termination of benefits or inability to process a claim.

Principle 4: Limiting collection

We will not collect personal information indiscriminately. The nature of the information collected will be limited to that which is necessary for the purposes identified.

Information will be collected in accordance with the company’s obligation to identify the purposes of collection and to obtain the individual’s consent to the collection, use and disclosure of personal information.

Principle 5: Limiting use, disclosure and retention

We will not use or disclose personal information for purposes other than those for which it was collected, except in cases stipulated in the Act or with the consent of the individual. Personal information will be retained only for as long as is necessary to fulfill its purposes.

Personal information that has been used to make a decision about an individual is retained long enough to allow the individual access to the information after the decision has been made.

Principle 6: Accuracy

Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is being used.

The extent to which personal information is updated will depend on what the personal information is being used for, taking into consideration the best interests of the individual. Information will be sufficiently accurate, complete and up-to-date so as to minimize the risk that inappropriate information may be used to make a decision about the individual.

We will not routinely update personal information, unless such a process is necessary to fulfil the purposes for which the information was collected, e.g., the management and services indicated in the file.

Principle 7: Safeguards

Personal information will be protected by safeguards appropriate to the sensitivity of the information.

We have implemented appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Moreover, external data backups are fully encrypted.

The methods of protection include physical, organizational and technological measures designed to limit access to authorized persons, ensure the integrity of the information, and protect it from unauthorized use or disclosure.

Safeguards also include steps to ensure that all third parties with whom we contract and who may be required to handle personal information have implemented comparable security measures.

Principle 8: Openness

Under review.

Principle 9: Individual access

We will reply within thirty (30) days of receipt of a written request for access from a client.

Upon request, we will inform the individual whether or not we hold personal information about the individual. We will permit the individual to access the information and provide an account of the use made of the information, including any disclosure to third parties (if applicable).

An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

We will reply within thirty (30) days of receipt of a challenge.

Principle 10: Challenging compliance

An individual may address a challenge concerning compliance with the principles set out above to the following person:

Isabelle Paradis
Courtage Conseil Birar Inc.
7900 boul. Taschereau, Suite 201-E
Brossard, QC J4X 2C2

We will inform individuals who make inquiries or lodge complaints of the applicable complaint handling protocol.

OUR PROCEDURES

We are committed to ensuring the protection of personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Our protection measures apply regardless of media type: paper, electronic or other.

We use appropriate security measures to protect the information:

  • Use of an alarm system;
  • Restricted access to our offices;
  • Locked filing cabinets and offices. For example, our representatives and employees place all confidential documents in their filing cabinets when they leave the office for the day.

Access to our computer system is secured on two levels:

  • Access to the computer network requires a user name and password;
  • Access to the Kronos software also requires a user name and password;
  • Only our representatives and employees have access to the computer network.

We also apply administrative measures such as:

  • Limiting access to personal information to authorized individuals;
  • Informing and training our employees and representatives on this policy;
  • Posting the privacy policy on our website (if applicable);
  • Informing employees of the importance of safeguarding personal information;
  • Mandatory signature on our Confidentiality agreement.

Destruction of confidential documents:

  • All representatives and employees are responsible for disposing of their confidential documents in the Shred-it bins provided for this purpose. The bins are locked.
  • We have a very strict procedure governing the destruction of confidential documents.

OUR PROCEDURES

We are committed to ensuring the protection of personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Our protection measures apply regardless of media type: paper, electronic or other.

We use appropriate security measures to protect the information:

  • Use of an alarm system;
  • Restricted access to our offices;
  • Locked filing cabinets and offices. For example, our representatives and employees place all confidential documents in their filing cabinets when they leave the office for the day.

Access to our computer system is secured on two levels:

  • Access to the computer network requires a user name and password;
  • Access to the Kronos software also requires a user name and password;
  • Only our representatives and employees have access to the computer network.

We also apply administrative measures such as:

  • Limiting access to personal information to authorized individuals;
  • Informing and training our employees and representatives on this policy;
  • Posting the privacy policy on our website (if applicable);
  • Informing employees of the importance of safeguarding personal information;
  • Mandatory signature on our Confidentiality agreement.

Destruction of confidential documents:

  • All representatives and employees are responsible for disposing of their confidential documents in the Shred-it bins provided for this purpose. The bins are locked.
  • We have a very strict procedure governing the destruction of confidential documents.

OUR PROCEDURES

We are committed to ensuring the protection of personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Our protection measures apply regardless of media type: paper, electronic or other.

We use appropriate security measures to protect the information:

  • Use of an alarm system;
  • Restricted access to our offices;
  • Locked filing cabinets and offices. For example, our representatives and employees place all confidential documents in their filing cabinets when they leave the office for the day.

Access to our computer system is secured on two levels:

  • Access to the computer network requires a user name and password;
  • Access to the Kronos software also requires a user name and password;
  • Only our representatives and employees have access to the computer network.

We also apply administrative measures such as:

  • Limiting access to personal information to authorized individuals;
  • Informing and training our employees and representatives on this policy;
  • Posting the privacy policy on our website (if applicable);
  • Informing employees of the importance of safeguarding personal information;
  • Mandatory signature on our Confidentiality agreement.

Destruction of confidential documents:

  • All representatives and employees are responsible for disposing of their confidential documents in the Shred-it bins provided for this purpose. The bins are locked.
  • We have a very strict procedure governing the destruction of confidential documents.