Protection of personal information policy

This policy aims to ensure the protection of personal information and to define the procedures for collecting, using, disclosing, retaining, destroying, and managing information by Lac Pemichangan, including management, employees, suppliers, etc. In addition, it aims to inform any concerned person about how Lac Pemichangan processes their personal information, whether relating to clients, employees, or any other persons.

Responsibility

Lac Pemichangan assumes full responsibility for protecting the personal information under its control. The information collected, used, disclosed, retained, or destroyed is governed by this policy with the objective of protecting everyone’s privacy.

To ensure optimal protection of personal information, the person responsible for information protection at Lac Pemichangan must:

Oversee and review internal practices and procedures for processing personal information, as well as compliance with applicable laws;
Suggest measures to ensure the ongoing protection of personal information that align with privacy impact assessments;
Implement the necessary measures within the Lac Pemichangan to ensure the protection of information;
Ensure staff compliance and training regarding best practices for protecting personal information.
Coordinate, investigate, and respond to requests and complaints relating to the protection of personal information;
Communicate with the person(s) concerned and the Commission d’accès à l’information (CAI) in the event of a data breach or any incident;
Maintain a register of incidents relating to personal data.

The protection of personal information is everyone’s business. No retaliation may be taken against an individual who files a complaint relating to the protection of personal information or participates in a CAI investigation process.

Collection of personal information

The personal information collected enables Lac Pemichangan to carry out its functions and conduct its activities in accordance with applicable laws and standards. Lac Pemichangan collects personal information only when necessary and to meet specific purposes defined in advance. Personal information is collected directly from the person concerned and with their consent, unless an exception is provided by law.

With respect to client information, data is provided to feed our management systems, contracts, and billing, but it is mostly professional information and necessary in the context of our services, such as name, email, and phone number to contact them, as well as the payment method for services rendered, etc.

Consent and accuracy of personal information

Lac Pemichangan ensures that the collection of personal information is carried out for justified, clear, and specific reasons and with the person’s free and informed consent. Consent is required for any collection, use, or disclosure of personal information. Before collecting personal information, we will ensure that we obtain your informed consent in writing and separately, providing clear details on the purpose of the collection and how the information will be used. Your consent is essential to ensure the protection of your personal data.

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. Lac Pemichangan must provide certain information in order to meet legal and regulatory verification processes and requirements.

Information may be transmitted to third parties to the extent necessary or required by law. Lac Pemichangan cannot be held responsible for the conduct and use undertaken by third parties.

Personal information will not be used or disclosed for purposes other than specific objectives unless required by law.

Protection of your personal information

Lac Pemichangan takes all reasonable precautions and has put in place significant physical and technical measures to prevent unauthorized or unlawful use of and access to personal information. The measures in place include, among others:

Use of information only when necessary;
Ensure the confidentiality and protection of personal information that a person may have become aware of in the performance of their duties, unless authorized to disclose it by the person concerned.
Protect records with selective and limited access to authorized persons;
Secure access to offices through locked doors and access codes;
Secure shredding of paper records;
Two-factor authentication for all logins to platforms;
Immediate removal of access following the end of a business relationship.

All individuals are required to contribute to the protection of personal information. If you suspect that sensitive information has been compromised, you must immediately notify the person responsible for the protection of personal information.

Retention period for your personal information

Lac Pemichangan undertakes to respect the minimum retention periods provided for according to the category of personal information and applicable laws. However, if the collected information is no longer useful to Lac Pemichangan and its retention is neither necessary nor mandatory under the various legislative frameworks, it will be destroyed, erased, or converted in such a way as to retain an anonymous character.

Commitment to transparency

Lac Pemichangan undertakes to be transparent regarding the processing, procedures, and purposes of use governing personal information with clients, employees, interns, and business partners.

Access to your personal information

A person may request access to the personal information concerning them and the means used to collect it. Depending on the contents of the person’s file, exceptions may apply, such as personal information relating to others; however, the person will be informed. In the event of inaccurate information in the file, the person concerned may request a correction.

For any consultation, withdrawal, and/or modification of personal information, you may write to the email address info@pemichangan.org. At any time, you may withdraw your consent to the disclosure of your personal information. A written request must be submitted to the person responsible for the protection of personal information at info@pemichangan.org. A response will be provided within 30 days following the date it is received. When it is not possible to share the requested information, a legal justification and support must be provided to support the decision to the requester.

Filing a complaint

A person who believes that their personal information has been collected, retained, used, disclosed, or destroyed in a manner not compliant with the provisions of this policy may submit a confidential complaint to the person responsible for the protection of personal information at the email address info@pemichangan.org. The individual must provide their name, their contact details, including a phone number, as well as the subject and reasons for the complaint. It is necessary to provide sufficient details for the complaint to be properly assessed. A response will be provided within 30 days following the date the complaint is received. If the complaint is not sufficiently specific, the person responsible for the protection of personal information may request any additional information deemed necessary to assess the complaint. The person responsible will conduct an investigation into the complaints received, minimize damages, and implement the necessary corrective actions.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec. However, Lac Pemichangan encourages concerned persons to first contact the person responsible for the protection of personal information and to wait for the conclusion of the processing process provided for.