POLICIES AND PRACTICES REGARDING THE GOVERNANCE AND PROTECTION OF PERSONAL INFORMATION
The purpose of this policy (hereinafter referred to as the “Policy”) is to describe the practices of Sources Coulombe Inc. in terms of the management and governance of personal information. Sources Coulombe is committed to protecting all personal information collected and used in the course of its activities. All persons working or acting on behalf of Sources Coulombe must respect the confidentiality of personal information in accordance with the Act respecting the protection of personal information in the private sector.
Sources Coulombe Inc. does not collect personal information about you unless you voluntarily provide it. The consent of an individual is always required for the collection, use or disclosure of personal information, except when required or permitted by law or this Policy. In such a case, the collection, use or communication of this information is done by legal and reasonable means.
By providing personal information to Sources Coulombe Inc. or its service providers or agents, you authorize Sources Coulombe Inc. to use, collect and communicate this personal information in accordance with this Policy and as authorized or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to some of the identified purposes at any time by contacting Sources Coulombe Inc.’s Privacy Officer as indicated below. If you refuse or withdraw your consent, we may not be able to provide or continue to provide you with some of the services or information that may be useful to you.
Your express consent will be required if Sources Coulombe Inc. wishes to collect, use or disclose your personal information for a purpose other than those set out in this Policy.
COLLECTION OF PERSONAL INFORMATION
Personal information is data or a combination of data that makes it possible to identify an individual. However, information generally considered to be of a professional nature, such as an individual’s name, business title, business address, business telephone number and business e-mail address, is not considered personal information.
Sources Coulombe Inc. collects or creates personal information intended to be used for administrative purposes directly from the person concerned, except when:
- the person authorizes Sources Coulombe Inc. to collect personal information from another source;
- personal information is collected for a purpose for which it may be disclosed to Sources Coulombe Inc;
- collecting personal information directly from the individual could result in the collection of inaccurate information; or
- collecting personal information directly from the individual could defeat the purpose or compromise the use for which the personal information is collected.
We limit the collection, use and disclosure of your personal information to the purposes we have identified to you. Your personal information can only be accessed by certain authorized persons, and only in the context of the tasks assigned to them.
You do not need to provide any personal information to access our website. However, we may collect information that does not identify you, such as the type of Internet browser or operating system you use and the domain name of the website from which you linked to our site.
In addition, when you visit our website, we may store some information on your computer in the form of cookies or similar files. Cookies allow us to tailor a website or promotion to your interests and preferences. Most Internet browsers allow you to erase cookies from your hard drive, block them or receive a warning before they are stored on your computer. To find out more about these functions, consult your browser’s instructions or help function.
Sources Coulombe Inc. does not automatically collect your personal information. However, it may associate information obtained automatically (e.g., the Internet browser you use) with personal information already provided.
USE OF PERSONAL INFORMATION
Purposes pursued by Sources Coulombe Inc.
Sources Coulombe Inc. uses and communicates personal information for the following purposes:
(a) communicate with customers regarding any questions or comments about our products;
(b) allow customers to participate in contests and promotions;
(c) develop, improve and market our products;
(d) assess our customers’ needs and preferences;
(e) communicate with customers about promotions, offers and contests we are offering;
(f) process any application for employment submitted by a potential candidate;
(g) carry out studies and data analysis in order to improve our products and services or to create new ones;
(h) comply with applicable laws and regulatory requirements;
(i) communicate company policy changes, including this Policy, to customers.
Disclosure of personal information
We may share personal information with our affiliates, service providers acting on our behalf and business partners. Sources Coulombe Inc. reserves the right to transmit personal information to service providers who act on our behalf to process or store data, including personal information. These suppliers agree to comply with this Policy. Personal information may be disclosed as part of a mandatory disclosure required by law. We may also disclose personal information to protect your interests in the event of fraud or attempted fraud. An individual’s personal information may also be disclosed for other purposes, with that individual’s consent.
RETENTION AND PROTECTION OF PERSONAL INFORMATION
Retention of personal information
Sources Coulombe Inc. keeps the personal information it holds for a reasonable period of time. This period is determined on the basis of the time required to fulfill the purposes for which the information is to be used, or to comply with legal provisions or commercial practices, whichever is longer. We establish retention criteria based on the type of information collected. We retain personal information that has been used to make a decision about an individual long enough for that individual to have access to it once the decision has been made. In the event of a request for consultation or a challenge, we retain the information collected long enough for the individual to exercise all possible recourses under the law. Once the personal information has been used to fulfill the identified purposes, or when the individual requests that the information be destroyed, Sources Coulombe Inc. anonymizes or destroys the information in a manner that prevents any unauthorized disclosure or access to the information.
Permanent destruction of personal information
When personal information is no longer useful to our organization, we have a duty to destroy or anonymize it. Personal information is no longer useful when the purpose for which it was collected or used is no longer relevant.
In cases where the destruction of personal information or a medium containing such information is necessary, our organization will follow the following final destruction techniques:
- The original document and its copies will be destroyed using a shredder;
- In the case of extremely sensitive personal information, we may resort to incineration of shredded documents.
- Reusable digital media (SD, XD flash memory card; USB key; computer hard drive):
- The methods used will be formatting, rewriting or digital shredding;
- Digital shredding involves the use of software that securely deletes the personal information and then writes random information at the location of the file containing the personal information to be destroyed.
- Non-reusable digital media (some CDs, DVDs, flash memory cards, USB sticks and hard drives)
- Physical destruction of the media such as crushing, shredding, drilling, incineration, etc.).
- Shredding with a traditional shredder for CDs and DVDs;
- Degaussing is possible for hard disks;
- Devices containing hard disks (fax machines, scanners, printers, photocopiers, etc.)
- Overwriting of personal information on the device’s hard disk;
Security and information sharing
Sources Coulombe Inc. takes reasonable precautions to protect the personal information it collects. In particular, this information may be passed on to authorized agents, service providers or other affiliated companies. These persons and entities undertake to comply with this Policy. These persons and entities are thus required to ensure the confidentiality of this information and to use it only for the purposes established in agreement with Sources Coulombe Inc.
Sources Coulombe Inc. has adopted several measures to ensure the security of personal information. Equipment or infrastructures that may contain personal information, such as computer servers, are located in secure locations with secure access. Also, the number of people with access to personal information is limited. Only employees who need to consult personal information in order to carry out their work are authorized to do so.
In the event of a confidentiality incident, such as a data leak, measures are in place to deal with the situation. Our Privacy Officer is then responsible for adding this incident to Sources Coulombe Inc.’s confidentiality incident log.
In the event of a confidentiality incident presenting a risk of serious harm, we are obliged to notify the Commission d’accès à l’information du Québec. If a serious privacy incident occurs, we will take reasonable steps to mitigate any risk of data leakage or other consequences of the incident.
REQUEST FOR ACCESS TO INFORMATION AND MODIFICATIONS
Subject to the exceptions set out in the Privacy Act, any individual may access, review or receive a copy of his or her personal information held by the organization by submitting a written request to that effect to the organization’s Privacy Officer.
We will provide you with such information within a reasonable period of time from the date we receive your written request. A reasonable fee may also be charged to process your request.
Under certain circumstances, we may refuse to provide you with the requested information. Exceptions to your right of access include the fact that the information requested concerns other individuals; that the information cannot be disclosed for legal, security or copyright reasons; that the information was obtained as part of a fraud investigation; that the information can only be obtained at prohibitive cost or that the information is the subject of litigation or is privileged.
If we hold medical information about you, we may refuse to communicate it directly to you and ask that it be sent to a health professional designated by you.
You may verify the accuracy and completeness of your personal information and, if necessary, request that it be amended. All modification requests will be processed within a reasonable time.
Any request for access to or modification of personal information may be sent to our Privacy Officer, who is responsible for the application of this Policy and can be reached at the address below:
Sources Coulombe Inc.
A/S Privacy Officer
2240, rue Cyrille-Duquet, Québec
QC G1N 2G3
PROTECTION OF PERSONAL INFORMATION COMPLAINT PROCESS
In order to make a complaint regarding the protection of personal information, any person must address such a complaint in writing to our Privacy Officer. You will find the contact details of our Privacy Officer in the present Policy.
In order to make such a complaint, the person must provide his or her name, contact information, telephone number and the subject of the complaint, in text form. The complaint in question must be detailed to ensure optimal handling. If a complaint is not sufficiently detailed, our Privacy Officer may contact the individual to obtain further information.
Complaints are handled confidentially by the people assigned to this task within our organization. We undertake to deal with sufficiently detailed complaints within a reasonable time.
When a complaint is received by our Privacy Officer, he or she is required to evaluate the complaint and provide a written response to the complainant. In assessing the complaint, our organization will determine whether the processing or use of the personal information to which the complaint relates was carried out in a manner consistent with this Policy, our organization’s related internal guidelines and applicable legislation.
Members of our organization who handle complaints are required to keep a separate file for each complaint. A complaint file contains the following information: the written complaint, the analysis carried out during the complaint assessment and the written response sent to the complainant.
TRAINING AND AWARENESS-RAISING
Sources Coulombe Inc. ensures that the various members of our organization are trained and made aware of the best practices in effect in terms of personal information protection. Our staff agrees to adhere to the Policy and internal guidelines in terms of protection of personal information by means of a consent form that they must sign. The name and contact information of the Privacy Officer are known to our staff and are posted in the offices of Sources Coulombe Inc. Various training activities and information sessions on the protection of personal information are offered to members of our organization on a regular basis.
If for any reason, you believe that the company has not adhered to these principles, please notify us by contacting our Privacy Officer. We will then take steps to identify and correct the problem within a reasonable timeframe. Mention “Privacy protection” as the subject.
MODIFICATION OF THE POLICY
Sources Coulombe Inc. reserves the right to modify this Policy at any time by updating its content on its websites. Modification of this Policy shall constitute notice of modification of this Policy. Persons holding personal information processed, retained or collected by Sources Coulombe Inc. are bound by this Policy and any amendments thereto.
Policy update date: November 9, 2023