The purpose of the Act to modernize legislative provisions as regards the protection of personal information (LQ 2021, c 25) (Act) and the regulations adopted under it is to provide an appropriate framework for the access to documents and the protection of personal Information held by private organizations. In the pursuit of its mission, 1823 Consultatnts must collect, use, store, communicate and destroy personal Information related to its employees.
This personal information is confidential, with the exception of information deemed public under the Act. 1823 Consultants is therefore responsible for protecting the confidentiality of this information and complying with its legal obligations in this regard, including obtaining the consent of the individuals concerned before disclosing the information to third parties. The Policy on the Management and Protection of Personal Information (Policy) aims to implement concrete measures to meet these requirements.
All persons working with, for or on behalf of 1823 Consultants (the “Company”) are required to respect the confidentiality of personal information and the right to privacy of every individual, in accordance with the Privacy Act, when collecting, using, disclosing, retaining or destroying of personal information in the course of their duties. We respect the privacy rights of individuals whose personal information is in our possession, in accordance with these requirements.
We collect only the personal information we need from the individuals concerned or from a third party authorized to communicate it. We cannot use your personal information for purposes other than those to which you have consented, nor disclose it to a third party without your consent (see Article 6). We may, however, collect, use or disclose your personal information without your consent when required by law. We limit the collection, use and disclosure of your personal information to the purposes we have identified to you. Your personal information may only be accessed by certain authorized persons, and only for the duties assigned to them.
We are responsible for ensuring that our service providers comply with applicable privacy laws and for ensuring that they provide a level of protection comparable to our own. You have the right to know, upon request, to whom your personal information has been communicated. Only in exceptional circumstances and in accordance with the law will we refuse to disclose this information. We keep precise track of the individuals to whom your personal information has been disclosed and the circumstances that led to such disclosure.
We only collect personal information that is directly related to our business operations. Wherever possible, this information is provided directly by the person who comes into contact with us. The amount and type of information collected will be limited to that which is necessary for the purposes identified. We collect only what we need.
For example, we may collect information such as your name and contact details if you fill out our contact form or when you complete an application form.
We may also collect personal information from other sources as needed, including cookies, employers or from company files and records.
Restrictions on access:
1823 Consultants limits access to personal information to only those authorized to receive it within the company, when such information is necessary to fulfill their duties.
1823 Consultants limits the use of personal information: unless an exception is provided for by law, the company must obtain the consent of the person concerned to use his or her information once the purpose of the assignment has been fulfilled.
Consent for use of personal information:
Companies are required to protect the confidential nature of the information they hold by preventing it from being disclosed to another company or public organisation. However, there are two exceptions:
– if you give your consent, 1823 Consultants may disclose the information to which that consent relates;
– if, through law enforcement and as required by law, we are compelled to provide information.
This principle must be interpreted in the light of the purposes intended by the company. Personal information is necessary if the purpose for which it is collected is legitimate, important, urgent and real, and if the infringement of the right to privacy resulting from the collection, communication or retention of each item of information is proportionate to that purpose (i.e. is the collection of the information rationally connected to the objectives in question, is the infringement of the right to privacy minimized, and is the disclosure of the required information clearly more useful to the company than harmful to the individual concerned).
Disclosure is the period during which personal information is communicated, for example in an electronic service delivery system, by e-mail, to customer service, via Web sites or to a third party.
At this stage, the company must comply with the following obligations:
– Obtain consent from the individuals concerned to disclose their information to a third party (e.g., a service provider), unless an exception is provided for by law;
– Comply with legal obligations when disclosing personal information without consent;
– Respect the specific obligations applicable to the communication of personal information outside Quebec.
Storage:
Retention is the period of time during which a company keeps personal information in any form, regardless of whether or not the information is actively used.
At this stage, 1823 Consultants ensures compliance with the following obligations:
1- Ensure the quality of personal information by keeping it up to date and accurate when used to make a decision about an individual;
2- Take appropriate security measures to ensure personal information remains secure.
Destruction:
The life cycle of personal information ends when it is destroyed.
At this stage, 1823 Consultants is committed to securely destroying personal information as soon as the purpose for which it was collected has been fulfilled, subject to the time limit stipulated by law or by a retention schedule established by government regulation (e.g. for tax purposes).
We have implemented and continue to develop rigorous security measures to ensure that your personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
These security measures include organizational measures such as the use of security clearances and restricting access to what is necessary; physical measures and technological measures such as the use of passwords and encryption (for example, frequent password changes and the use of firewalls).
You have the right to know whether we hold personal information about you and to access that personal information. You also have the right to ask questions about how this information has been collected and used and to whom it has been disclosed.
We will provide you with such information within a reasonable period of time from the date we receive your written 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, the information cannot be disclosed for legal, security or copyright reasons, the information was obtained as part of an investigation into a possible breach of contract or fraud, the information is prohibitively expensive to obtain, or the information is the subject of litigation or is confidential.
You may verify the accuracy and completeness of your personal information and, if necessary, request that it be amended. Any request for amendment will be processed within a reasonable timeframe.
Requests to access or amend personal information may be sent to the address below:
1823 Consultants
797, boulevard Lebourgneuf, Suite 100
Québec (Québec)
G2J 0B5
Courriel : info@1823.ca
