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Governance policies and practices with respect to personal information

 

NORVAL CONSTRUCTION INC. is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (the Act).

 

Personal information

Personal information is information about a natural person that directly or indirectly allows that person to be identified. Writing, images, videos and sound recordings may contain personal information. In the course of its professional activities, NORVAL CONSTRUCTION may collect personal information such as a person's name, home address, date of birth, identification information and, if applicable, social insurance number, income information, marital status, etc. NORVAL CONSTRUCTION will not disclose this information to third parties without your consent.

 

Consent

NORVAL CONSTRUCTION collects, uses and discloses personal information with the consent of the individual concerned. To be valid, consent must be manifest, free, informed and given for specific purposes. A person who consents to provide personal information is presumed to consent to its use and disclosure for the purposes for which it was collected.

Individuals may withdraw their consent to the collection, use and disclosure of their personal information by NORVAL CONSTRUCTION at any time. In this case, if the collection is necessary for NORVAL CONSTRUCTION to enter into or perform a contract, NORVAL CONSTRUCTION may not be able to fulfill a request for service.

 

Liability

NRVAL CONSTRUCTIONO is responsible for the protection of the personal information it holds in the course of its activities. To this end, NORVAL CONSTRUCTION has adopted the Privacy Policy as well as policies and practices governing the governance of personal information, the purpose of which is to govern the collection, use, disclosure, retention and destruction of personal information.

 

Collection of personal information

NORVAL CONSTRUCTION only collects personal information that is necessary for the performance of its activities. For example, this may include information collected for the purposes of fulfilling an employment contract.

NORVAL CONSTRUCTION encourages its employees to explain the purposes for collecting personal information in simple and clear terms and to ensure that the individual understands the purposes for which personal information is collected.

For the purposes of collecting personal information, NORVAL CONSTRUCTION encourages its employees to use the forms prepared by the company.

NORVAL CONSTRUCTION may also collect personal information verbally through correspondence with individuals involved in a transaction or through various documents submitted as part of a real estate transaction (identification, financial documents, powers of attorney, etc.).

 

Use and disclosure of personal information

Personal information is used and disclosed for the purposes for which it was collected and with the consent of the person concerned. In certain cases provided for by law, personal information may be used for other purposes, for example to detect and prevent fraud or to provide a service to the person concerned.

NORVAL CONSTRUCTION may be required to disclose personal information to third parties, for example, suppliers, contractors, subcontractors, agents, insurers, professionals, other regulators, or outside Quebec.

NORVAL CONSTRUCTION may, without the consent of the individual concerned, disclose personal information to a third party if such disclosure is necessary for the performance of a mandate or a contract for services or undertakings. In such cases, NORVAL CONSTRUCTION will establish a written mandate or contract in which it will indicate the measures that its agent must take to ensure the protection of the personal information entrusted to it, to ensure that it is used only in the performance of the mandate or contract and that it is destroyed once the mandate or contract has ended. The co-contractor must also undertake to cooperate with the AGENCY in the event of a breach of confidentiality of personal information.

Before disclosing personal information outside Quebec, NORVAL CONSTRUCTION considers the sensitivity of the information, the purpose for which it is to be used and the safeguards that will be in place outside Quebec. NORVAL CONSTRUCTION will only disclose personal information outside Quebec if its analysis demonstrates that the information will be adequately protected in the location where it is to be disclosed.

 

Retention and destruction of personal information

Once the purposes for which the personal information was collected or used have been fulfilled, NORVAL CONSTRUCTION must destroy it, subject to the retention period provided for by law. In this regard, NORVAL CONSTRUCTION's professional obligations require it to keep its files for at least six (6) years following their final closing.

 

Safety measures

When collecting, using, storing and destroying personal information, NORVAL CONSTRUCTION applies the security measures necessary to protect the confidentiality of personal information. More specifically, the following measures apply :

  • Documents containing personal information are kept under lock and key;
  • Only administrative staff involved in the transaction have access;
  • Files will be destroyed after the statutory retention period.

 

Privacy incident

A confidentiality incident is any access, use or disclosure of personal information that is not authorized by the Act, or the loss of personal information or any other breach of the protection of personal information.

NORVAL CONSTRUCTION has established a protocol for managing a confidentiality incident, which identifies the persons who assist the Privacy Officer and sets out the concrete actions to be taken in the event of an incident. This protocol sets out the responsibilities expected at each stage of incident management, including the measures to be taken to ensure data security.

 

Roles and responsibilities

  1. NORVAL:

  • Ensures confidentiality of information through good information management practices. In particular, it provides guidelines, training and instructions to staff members regarding the collection, use, storage, modification, consultation, communication and permitted destruction of personal information.
  • Deploys appropriate safeguards to reduce the risk of confidentiality incidents, by For example, computer security, updating personal information policies, staff training, etc.
  • Has standardized methods for filing documents containing personal information.
  • Has standardized methods for storing documents containing personal information, including digitization procedures.
  • Manages physical and computer access to personal information, according to its sensitivity.
  • Securely destroys personal information. In particular, it gives directives or instructions to staff members concerning the secure destruction method, destruction deadlines, etc.

 

  2. Privacy Officer

In accordance with the Act, NORVAL CONSTRUCTION has appointed a Privacy Officer.

In particular, he/she ensures that these policies are respected and that they comply with applicable regulations. The name and contact details of this person are given in the "Right of access, withdrawal and rectification" section.

The Privacy Officer is responsible for managing incidents of confidentiality and, in this context, takes the actions provided for in the Act.

The Privacy Officer handles requests for access to and correction of personal information. He or she also handles complaints about NORVAL CONSTRUCTION's handling of personal information.

The Privacy Officer is consulted as part of a privacy impact assessment for any project involving the acquisition, development or redesign of an information system or the electronic delivery of services involving the collection, use, disclosure, retention or destruction of personal information. It may suggest measures to ensure the protection of personal information in the context of such a project.

 

  3. Staff members

A NORVAL CONSTRUCTION employee may access personal information only to the extent necessary to perform his or her duties or mandate.

 

NORVAL staff member:

  • Ensures the integrity and confidentiality of personal information held by NORVAL CONSTRUCTION
  • Complies with all NORVAL CONSTRUCTION policies and guidelines on access, collection, use, disclosure, destruction of personal information and information security and complies with all instructions provided to him/her.
  • Respects the security measures in place at the workstation and on any equipment containing personal information.
  • Use only equipment and software authorized by NORVAL CONSTRUCTION.
  • Ensures the secure destruction of personal information in accordance with instructions. Immediately report to his/her superior any act of which he/she is aware that may constitute an actual or suspected breach of security rules relating to personal information.             

 

Right of access, withdrawal and rectification

An individual (or his or her authorized representative) may request access to his or her personal information held by NORVAL CONSTRUCTION. An individual may withdraw his or her consent to the collection, use and disclosure of his or her personal information at any time. This withdrawal will be recorded in writing.

An individual may request the correction of personal information in a file concerning him or her that he or she believes to be inaccurate, incomplete or equivocal.

NORVAL CONSTRUCTION may refuse a request for access or rectification in the cases provided for by law.

 

Complaints

A person who considers himself/herself aggrieved may formulate a complaint concerning the processing of his/her personal information by NORVAL CONSTRUCTION. This complaint will be treated with diligence within a maximum of 10 working days by the Privacy Officer and a written response will be sent to you.

 

To request access to or rectification of your personal information, or to submit a complaint regarding the processing of personal information, please contact by e-mail Jean-François Bleau, Privacy Officer, This email address is being protected from spambots. You need JavaScript enabled to view it.

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