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This policy sets out the measures and practices that the SADC des Îles-de- la-Madeleine (hereinafter « the SADC ») has put in place to provide a framework for its governance of personal information and to protect personal information. The SADC collects personal information from its clients, visitors to its website or people who apply for employment with them. (hereinafter « you », or   « your »). The SADC collects your information through (i) direct or indirect contact with an authorized representative of the SADC or (ii) its website <https://www.sadcdesiles.com>, and this, for purposes described in section 1 below.

 

In the policy, the expression « personal Information » means any information collected by the SADC which allows, on its own or in conjunction with other information to directly or indirectly identify any person concerned by the personal information.

 

The main purpose of this policy is to inform you :

  • The means used by the SADC to collect personal information ;

  • The nature of the personal information collected by the SADC and the purposes pursued by this personal information ;

  • How the SADC may use personal information as well as third parties to whom the SADC may communicate this personal information, if applicable ;

  • The various security measures put in place by the SADC to protect the confidential nature of personal information ; and

  • The rights you have with regard to personal information collected by the SADC, in particular to access your personal information or request the rectification of inaccurate personal information, if applicable.

 

By transmitting personal information to the SADC through (i) direct or indirect contact with an authorized representative of the SADC or (ii) your use of the website, you expressly consent that the SADC collects, uses, communicates and stores this personal information in accordance with the terms and conditions provided for in this policy.

 

This policy as well as any modified version of it are subject to the legislation applicable in the province of Quebec in Canada.

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1. UDER WHAT CIRCUMSTANCES DOES THE SADC COLLECT PERSONAL INFORMATION, BY WHAT MEANS AND FOR WHAT PURPOSES?

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The SADC collects personal information in two circumstances: (i) upon voluntary transmission of personal information to an authorized SADC representative and (ii) during your use of the website.

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Voluntary transmission of personal information to an authorized SADC representative

 

What are the means of collection ?

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The voluntary transmission of personal information to an authorized SADC representative can be done by various means including :

  1. By voluntarily responding to questions from SADC representatives who may communicate directly with you, by telephone, in person, by mail or by email ;

  2. By providing personal information to SADC representatives by telephone, in person, by mail or by email ;

  3. By providing information to SADC representatives electronically, by telephone or in person during job interviews ; or

  4. By voluntarily completing our job application form (hereinafter the « Form ») if you wish to apply for a job at the SADC, if applicable.

 

What personal information does the SADC collect through its authorized representatives ? 

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​ In the abovementioned circumstances, the SADC may collect the following personal information :

  • Name, first name, preferred language and some of your contact details (telephone number, email address, etc.) ;

  • As part of a job application, information relating to your level of education or training (year of graduation, information relating to primary, secondary, college or university studies, etc.) ;

  • As part of a job application, criminal records ;

  • As part of a job application, the position sought (the fact that the position sought is regular, part-time or student work);

  • As part of a job application, your previous jobs and your work experience ;

  • Financial information when necessary to complete a transaction that the person concerned by the personal information desires ; or

  • As part of a job application, the personal information provided on your curriculum vitae which we would need to collect to evaluate an application ;

  • As part of a financing request, your bank details ;

  • As part of a financing request, your personal assessment (annual income, employer, number of years in employment, etc.).

 

In all cases, before collecting personal information about you, the authorized SADC representative will specify the personal information requested before collecting it.

 

What are the purposes of personal information collected by SADC representatives ?

 

The SADC collects personal information through the use of its representatives for the accomplishment of numerous purposes :

  • Communicate with job candidate or potential clients and ensure that communication aimed at them is personalized ;

  • Carry out advertising to clients, visitors or potential job candidates ;

  • Evaluate job applications ;

  • Respond to your requests ;

  • Assess your needs and interests ;

  • Ensure compliance with a law, court order or a legal proceeding ;

  • Ensure the legal protection of the SADC in the event of litigation ;

  • Evaluate and improve protection and security measures ;

  • Prevent or detect fraud or illegal acts ; and

  • Respond to complaints and requests for access, rectification or withdrawal of consent.

 

Collection of personal information during your use of the website

 

What are the means of collection ?

 

When you visit our website, personal information is collected about you by various means, including :

  • Automatically by your connection to the website (your computer or cell phone and the website server automatically exchange personal information upon connection) ;

  • Automatically by installing temporary connection cookies on your computer or cell phone and by using pixels ;

  • Automatically through the use of our logging processes ;

  • By your email communications (if you communicate personal information to us by email) ; and

  • By the information you enter in our forms available on our website.

 

What personal information does the SADC collect ?

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The SADC can collect the following information :

 

A) Information collected automatically

 

 When you visit our website, personal information is automatically collected :

  • Your age group ;

  • Your gender ;

  • Your points of interests ;

  • Your language ;

  • The domain name of your Internet service provider ;

  • The brand, category, and model of your device ;

  • Your IP address ;

  • Your browser (Explorer, Firefox, etc.) ;

  • The operating system (Windows, Mac OS, etc.) you are using ;

  • The date and time of your visit to the website ;

  • The pages you consult ; and

  • The address of the site that refers you, if you access the website from another site.

 

B) Other information collected

 

If you send us an email, a request or you communicate directly with us via chat, you may communicate other personal information to us, the content of which will vary depending on the nature of the exchanges.

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​Please note that personal information recorded in your exchanges and your communication history with the SADC will be collected.

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Finally, any request for access, rectification or withdrawal of consent according to the terms set out in section 7 of this policy will require you to prove your identity by providing us with a valid photo ID and your name. All other personal information contained in this piece of identification may be masked.

 

For what purposes does the SADC collect personal information ?

 

 The SADC collects your personal information for the following purposes :

  • Evaluate the effectiveness of SADC’s approach to acquiring visitors, clientele or candidates ;

  • Improve the performance of the website and its effectiveness in retaining visitors ;  

  • Identify the legislative regime to which visitors’ personal information is subject ;

  • Communicate with job candidates and potential clients and ensure that communication towards them is personalized ;

  • Carry out advertising to potential clients, visitors or job candidates ;

  • Evaluate the needs and interests of the clientele ;

  • Evaluate the quality of job applicants ;

  • Ensure compliance with a law, court order or legal process ;

  • Ensure the legal protection of the SADC in the event of a dispute caused by your action or inaction or in the event of a dispute opposing you to the SADC ;

  • Evaluate and improve protection and security measures ;

  • Prevent or detect fraud ; and

  • Satisfy complaints, requests for access, rectification or withdrawal of consent.  

 

Links to other sites

 

The website sometimes provides links to other websites belonging to other organizations. When you visit these sites, you will not be subject to this privacy policy, but to the external site’s privacy policy, if it has one.

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2. TO WHOM MAY THE SADC COMMUNICATE YOUR PERSONAL INFORMATION ?

 

In general, the SADC uses your personal information only for internal purposes.

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However, the SADC may communicate, transmit or allow access to your personal information to :

  1. To SADC employees, if they need to have access to this information as part of their duties ;

  2. To any other person or entity, when prescribed or permitted by applicable law ;

  3. To any other person or entity to whom you consent to the communication of information ; or

  4. To external service providers with whom SADC has entered into a contractual agreement under which the external service provider cannot use personal information for purposes other than the provision of said service and must destroy the personal information communicated upon termination of the contractual agreement.

 

The SADC may communicate your personal information to people or entities belonging to the categories listed above who are located outside the borders of the province of Quebec.

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3. LIMITS ON COMMUNICATION AND USE OF PERSONAL INFORMATION

 

The personal information collected is destroyed upon completion of the purposes for which it was collected unless, of course, a law or regulation requires the SADC to keep it or a law or regulation imposes a specific time limit of retention. 

 

The SADC does not sell personal information to third parties nor provide third parties with access to personal information unless granting such access is necessary to fulfill one of the above purposes and the access or communication without the consent of the persons concerned is authorized or imposed by law or regulation.

 

All privacy settings applicable to your use of the website provide, by default, the highest level of privacy, without any intervention on your part.

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4. HOW DOES THE SADC PROTECT THE PRIVACY OF YOUR PERSONAL INFORMATION ?

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The SADC takes appropriate physical, technological, contractual and administrative protection measures to protect your personal information and reduce the risks of unauthorized access, use, communication and destruction.

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Without limiting the generality of the aforementioned, the website has certain security mechanisms designed to protect your personal information, namely :

  • Personal information collected on the website is encrypted at rest ;

  • All transfers of personal information between the different components of the website are encrypted ; and

  • The SADC IT services providers are contractually required to respect various security obligations which notably involve periodic validation of security practices and processes and continuous monitoring of the software components of the website and their updating.

 

In addition to these measures, the SADC also provides, among other things :

  • A data management policy and an information protection framework to which SADC employees are subject, to ensure the integrity, availability and confidentiality of personal information ;

  • A confidentiality and protection of employee personal information policy to which SADC employees are subject, to ensure the integrity, availability and confidentiality of their personal information ;

  • A confidentiality incident register, which helps the SADC to take inventory of both minor and major incidents, that compromise your personal information in order to ensure that these incidents do not happen again and to identify the necessary measures ;

  • A calendar of retention for personal information, to ensure that personal information is destroyed when it is no longer required for the aforementioned purposes and the law no longer requires its conservation ;

  • A confidentiality incident response plan, which allows the SADC to respond effectively and quickly to breaches of your personal information ; and

  • Annual training for members of our staff.

 

Despite these various measures, it nevertheless remains impossible for the SADC to guarantee the security of the personal information entrusted to it. If you suspect that your personal information held by the SADC has been compromised, please contact the person in charge of the protection of personal information at this address: dgaudet@sadcdesiles.com

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5. WHAT MEASURES HAS THE SADC IMPLEMENTED WITH RESPECT TO CONFIDENTIALITY INCIDENTS ?

 

The SADC maintains a register of confidentiality incidents in accordance with applicable legislation. In the event of a breach of your personal information presenting a risk that serious harm may be caused to you, the SADC will take the necessary measures to notify you, in accordance with applicable legislation. The SADC will also apply measures that will limit the harm that could result from the breach and that will limit the chances that the breach will recur.  

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6. HOW LONG WILL YOUR PERSONAL INFORMATION BE STORED ?

 

In accordance with our procedures for secure retention and destruction of personal information, we retain your personal information only for the period necessary to fulfill the purposes listed in section 1 of this policy or for the period required to comply with our statutory obligations, whichever is later.

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7. REQUESTS RELATING TO PERSONAL INFORMATION

 

I) REQUEST FOR ACCESS

 

You or a person authorized by the Act on the protection of personal information in the private sector can make a request for access to your personal information by contacting the person in charge of the protection of personal information directly according to the procedure mentioned below. The SADC person in charge of the protection of personal information will grant this access unless :

  • The law prevents the SADC from granting access ;

  • The SADC has a serious and legitimate interest in refusing access ; or

  • Granting this access risks serious harm to a third party.

 

In principle, the right to access is free. However, reasonable fees may be charged to the applicant to compensate for the costs of transcription, reproduction or transmission of personal information. In such a case, the applicant will be informed of the amount of the fees in question before processing their request.

 

You may also request a copy of your personal information by submitting a written request to the person in charge of the protection of personal information in accordance with the above-mentioned procedure.

 

In the event that the SADC grants any request for a copy of computerized personal information, the SADC will ensure that such copy is provided to the SADC (or to any person or organization authorized by law to collect such personal information) in a structured and commonly used technological format. Unless the communication of this copy in such a technological format raises serious practical difficulties or the SADC or one of its service providers has inferred or created personal information.

 

II) REQUEST FOR RECTIFICATION

 

We ask that you notify us of any changes that may affect the authenticity or accuracy of your personal information.

 

You or a person authorized by the Act on the the protection of personal information in the private sector can also send a request for rectification of your personal information. Such a request will allow you to correct the personal information in our possession if :  

  • The personal information is inaccurate;

  • The personal information is out of date;

  • The personal information is equivocal;  

  • The personal information is incomplete; or

  • The personal information was collected in an unjustified manner.  

 

Alternatively, you can send a written rectification request asking the person in charge of the protection of personal information to destroy personal information that is out of date or collected or retained unjustifiably. Any request for destruction or correction must be made in writing to the person in charge of the protection of personal information in accordance with the procedure below.

 

III) REQUEST FOR CESSATION OF BROADCASTING, DE-INDEXING OR RE-INDEXING

 

The SADC may also, at the request of the person concerned by the information or any person authorized by law to do so, cease the dissemination of personal information, deindex or reindex, as the case may be, any hyperlink attached to the name of a person concerned by personal information, subject to the criteria established by the applicable legislation.

 

IV) REQUEST FOR WITHDRAWAL OF CONSENT

 

Subject to your contractual commitments with the SADC and applicable legislation, the Act respecting the protection of personal information in the private sector (if it applies to you) allows you to withdraw your consent to certain uses or communication of personal information. Please note that exercising this right may affect SADC services to you. As such, if you make this request to us, the SADC will identify what the consequences of withdrawing consent will be on the services.

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8. APPLICATION PROCEDURES

 

All requests for access or rectification must be sent in writing to Daniel Gaudet, the person in charge of the protection of personal information. An applicant can communicate directly with him by sending an email to this address: dgaudet@sadcdesiles.com.

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The request must be sufficiently detailed to allow the person in charge of the protection of personal information to evaluate and identify the personal information covered by the request. The person making the request must ensure that the person in charge of the protection of personal information can contact him/her in order to provide assistance, if necessary, facilitate the identification of the personal information covered by the request and communicate the acceptance or refusal of the request if applicable.

 

The person in charge of the protection of personal information has a duty to process these requests with 30 days. If the request is not processed within the deadline, it is deemed to have been refused.  

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9. COMPLAINT PROCEDURE

 

You can submit a complaint about our methods, practices and policies for protecting or governing personal information by contacting the person in charge of the protection of personal information at the following email address : dgaudet@sadcdesiles.com. The person in charge of the protection of personal information will respond to the complaint within 30 days upon receipt. If the complaint is accepted, a brief summary of the changes made to our methods, practices and policies for the protection or governance of personal information will be provided to you.  

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10. CHANGES TO THE PRIVACY POLICY

 

The SADC may unilaterally modify this personal information protection policy. Before implementing the changes, the SADC will provide a notice on the website which will identify the upcoming changes. We therefore invite you to revisit this policy from time to time and check if it has been modified. To facilitate this process, we have included the date of the last update of this policy.

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If you have provided us with your email address, you will also receive this notice or a similar notice by email. Your use of the website, your communication of your personal information to an authorized SADC agent, or entry of your personal information on a SADC form upon receipt of this version will be deemed to constitute acceptance of the changes made.

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11. OTHER

 

For any questions about any of your rights, if you wish to ask questions to the SADC or for any comments, please contact the person in charge of the protection of personal information.

C/O : Daniel Gaudet

Person in charge of the protection of personal information,

General Director of the SADC

735, chemin Principal, Cap-aux-Meules, Québec, G4T 1G8

Email Address : dgaudet@sadcdesiles.com

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Last update of this policy: December 13, 2023

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Contact details of the Person in charge of the Protection of Personal Information
If you have any questions about processing or updating your personal information or to express any concerns in this regard, please contact us at the following email address : dgaudet@sadcdesiles.com


The person responsible for the protection of personal information will contact you within thirty (30) days of receiving your email.

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