Personal Information Protection Policy
(internal)
The purpose of this policy is to provide a framework for the protection of personal information with respect to all Beaudoin Canada employees and interns, business partners, and current and former clients. Personal information is any information that relates to a natural person directly or indirectly and that allows that person to be identified.
1. Responsibility
Beaudoin Canada
Beaudoin Canada assumes full responsibility for the protection of personal information over which it has control. The information collected, used, communicated, kept or destroyed is governed by this policy in order to protect the privacy of all individuals.
In order to ensure optimal protection of personal information, Beaudoin Canada has designated a Privacy Management Committee. The people in charge must :
- Oversee and review internal personal information handling practices and procedures and compliance with applicable laws.
- Suggest measures to ensure the ongoing protection of personal information that are consistent with Privacy Impact Assessments.
- Implement the necessary measures within the company to ensure the protection of information.
- Ensure staff compliance and training in good practices to protect personal information.
- Coordinate, investigate and respond to privacy requests and complaints.
- Communicate with the person(s) concerned and the Commission d’accès à l’information (CAI) in the event of a data leak or any other incident.
- Keep a register of incidents relating to personal data.
Employee(s)
As an employee, you also have certain responsibilities regarding personal information about yourself, other colleagues, and the company:
- Comply with the access rules you have been given.
- Respect the privacy rules and procedures you have been given.
- Respect the directives given to you concerning the protection of information.
- Act with vigilance and report to the person in charge if you witness or detect a breach of confidentiality in accordance with established procedures.
- Avoid researching and attempting to access personal information that does not concern you.
The protection of personal information is everyone’s business. No reprisals will be taken against an individual who files a privacy complaint or participates in a CIA investigation.
2. Collecting personal information
The personal information collected allows Beaudoin Canada to perform its duties and conduct its activities in accordance with applicable laws and standards. Beaudoin Canada collects personal information only when it is necessary and for specific, pre-defined purposes.
Personal information collected may include, but is not limited to:
- Full name
- E-mail address
- Browsing behavior
- Telephone number
- Residential address
- Social insurance number
- Banking information
You may be asked to provide personal information about other individuals in order to assist you in an emergency. It is your responsibility to obtain their consent before providing us with their contact information.
3. Consent and accuracy of personal information
Beaudoin Canada ensures that personal information is collected for justified, clear and specific reasons and with the free and informed consent of the individual. When a new employee is hired, certain information is requested on a form that must be completed. Manifest consent is reiterated at the end of this form. Moreover, it is the individual’s responsibility to ensure that the information contained in his or her file is accurate and up to date.
4. 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. Beaudoin Canada must provide certain information in order to meet legal and regulatory audit requirements and processes. Uses may vary, but may include, but are not limited to:
- The recruitment process
- Employment records and payroll administration
- Performance management
- Compliance with applicable employment laws
- Occupational health and safety investigations and claims
- Driving record
Information may be transmitted to third parties to the extent necessary for the purposes of the activities mentioned. Beaudoin Canada cannot be held responsible for the behaviour and use undertaken by third parties.
Personal information will not be used or disclosed for purposes other than those for which it was collected, unless required by law.
5. Protection of your personal information
Beaudoin Canada takes all reasonable precautions and has implemented significant physical and technical measures to prevent unauthorized or illegal use of or access to personal information. The measures in place include the following:
- Use information only when necessary.
- Ensuring the confidentiality and protection of personal information of which a person may have become aware during his or her duties, unless authorized to make disclosure by the person concerned.
- Protect files with selective access limited to authorized persons.
- Securing office access with locked doors and access codes.
- Secure shredding of paper files.
- Double authentication in all platform connections (where available and accessible).
- Immediate withdrawal of access following dismissal.
All individuals are required to contribute to the protection of personal information. You must ensure that computer equipment is securely located and that you do not share your access codes with anyone. It is your responsibility never to divulge your identification codes and passwords. If you suspect that sensitive information has been compromised, you must immediately notify our Privacy Officer.
6. How long we keep your personal information
Minimum retention periods are set according to the category of personal information. However, if the information collected is no longer useful to Beaudoin Canada and its retention is neither necessary nor mandatory under the various legislative frameworks, it will be destroyed, erased, or converted so as to remain anonymous.
| Document type | Applicable law | Minimal delays |
|---|---|---|
| Recruitment folder | 3 years Unless the candidate requests its destruction. |
|
| Dismissed employees file | Civil Code of Quebec, LQ 1991, c64, art 2925 | 3 years Limitation period for civil actions |
| Medical file | Act respecting occupational health and safety, LRQ c S-2.1, art 127 (5) | None Recommendation: 20 years after end of employment or 40 years after start of employment, whichever is longer. |
| Claims files under the Act respecting industrial accidents and occupational diseases | An Act respecting industrial accidents and occupational diseases, LRQ c A-3.001. | None Recommendation: keep these documents permanently, as claims may arise long after employment has ended. |
| Information used to complete a pay equity program or to evaluate the maintenance of pay equity in the enterprise | Pay Equity Act, R.S.Q., c. E-12.001 (Sections 14.1 and 76.8) | 5 years from posting of results. |
| Training (training programs and agreements, training invoices and contracts) |
Regulation respecting eligible training expenses, RRQ 1981, c D-8.3, r 3, art 4. | 6 years After the last year for which information is available |
| Corporate pension plan | Supplemental Pension Plans Act, LRQ c R-15.1. | Permanent If the employee is eligible for a retirement pension |
| Occupational health and safety committee (minutes) | Regulation respecting occupational health and safety committees, D. 2025-1983, (1983) GOQ II, 4209, art 31. | 5 years minimum |
| Payroll and related documents | Regulations governing the maintenance of a registration system or register, RRQ 1981, c N-1.1, r 6, art 2. | 3 years |
| Register for tax purposes and supporting documents (account books, etc.) | Department of Revenue Act, LRQ c M-31, art 35.1; Income Tax Act, LRC 1985, c 1 (5e suppl.), art 230(4). | 6 years After the last year to which they relate or after the tax return has been filed (i.e. 7 years) |
| Records of employment and other documents relating to contributions/deductions and claims | Employment Insurance Act, LC 1996, c 23, art 87(3) et art 87(4). | 6 years After the end of the year in respect of which the records were kept or until a decision is rendered (including the expiry of the appeal) in a dispute under section 90 or 91 of the Act |
| Rentes du Québec (registers of contributor information) | Quebec Pension Plan Act, LRQ c R-9, art 66. | None Recommendation: 4 years minimum after the end of the fiscal year in which employment is terminated. This corresponds to the 4-year limitation period for any imposition by the Minister (provided for in section 66 of the Act). |
| Documents for which a request for access or rectification has been made | Act respecting the protection of personal information in the private sector, LRQ c P-39, art 36. | None However, when personal information is the subject of a request for access that is refused by the enterprise, it must be retained for the time required to allow the person concerned to exhaust the recourses provided for in the Act. |
7. Commitment to transparency
Beaudoin Canada is committed to being transparent about the processing, procedures, and purposes for which personal information is collected from customers, employees, trainees, and business partners.
8. Access to your personal information
An individual may request access to his or her personal information and the means by which it was collected. Depending on the content of the individual’s file, exceptions may apply, such as personal information about a third party, but the individual will be informed. In the event of inaccurate information in the file, the person concerned may ask for it to be corrected.
9. File a complaint
Fraudulent use of personal data is a serious offence that may be subject to disciplinary action, including dismissal, and/or legal prosecution.
An individual who believes that his or her personal information has been collected, retained, used, disclosed or destroyed in a manner that does not comply with the provisions of this policy may file a confidential complaint with the Privacy Officer. The Privacy Officer will investigate complaints, minimize damage and take any necessary corrective action.
