Introduction
Boscoville cares about respecting your privacy and protecting your personal information.
As part of the use of our services, Boscoville may collect and you may communicate personal information. The collection, use, communication and keeping of your personal information are subject to the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1).
Boscoville reserves the right to modify this Policy at any time. Any modification will be published on the various online platforms of Boscoville. Your use of services following the posting of changes to the Policy constitutes acceptance of these changes.
The purpose of the present Policy is to explain the following to users of Boscoville services:
- How their personal data is collected and processed;
- What are their rights with regard to this data;
- Who is responsible for the processing of personal data collected and processed;
- To whom this data is transmitted;
- The use of cookies by Boscoville on its websites.
Personal Information
Any factual or subjective information about an identifiable individual is considered personal. Your personal information may include, but is not limited to, your first and last name, address, telephone numbers, gender, email address, marital status, lifestyle or health information.
However, an individual’s name and business contact information, i.e., their title, address, telephone number and email address, are not personal information.
Personal information must be protected regardless of the medium in which it is held or the form it takes: written, graphic, audio, visual, computerized or other.
Our Commitment
We have established and implemented internal policies and procedures to adequately protect personal information in our possession and we review them on a regular basis.
We make our staff aware of the importance of protecting personal information by requiring them to undergo training on the subject and by issuing occasional directives outlining their role and obligations in this regard.
Purposes of Information Collection
When using our services, we collect your personal and confidential information only to enable us to provide you with the requested services in an appropriate and personalized manner. In all cases, the disclosure of your personal and confidential information will be subject to obligations to maintain confidentiality and comply with applicable laws.
The following types of personal information may be collected, stored and used:
- Information required for administrative purposes with our employees or contract workers.
- Information required for our Human Resources services.
- To allow us to carry out different services within our programs.
- For our communication needs and the promotion of our events and services.
- Information to prepare government slips.
- Information generation when you use our website, including when, how often and under what circumstances you use it.
- Information contained in any communications you send to us by email or on one of our websites, including their content and metadata.
- Any other personal information that you communicate to us.
Consent
Subject to the exceptions and requirements of applicable laws, we will not share your personal information with any other third parties without your consent.
By using our services, you consent to the collection, use and communication of your personal and confidential information in accordance with this Policy.
Your consent will be requested:
- By a person representing our senior management, for contractual purposes;
- By a person representing our human resources department;
- By the main service provider when Boscoville acts as a subcontractor.
You may withdraw your consent at any time, subject to certain legal or contractual restrictions.
In certain special circumstances, we may collect, use or disclose personal information without your knowledge or consent. Such circumstances arise when, for legal, medical or security reasons, it is impossible or unlikely to obtain your consent or when the information is necessary for the purpose of investigating a possible breach of contract, prevent or detect fraud or to enforce the law.
Before you provide us with personal information about another person, you must obtain that person’s consent to the disclosure and processing of that personal information in accordance with this Policy.
Personal Information Concerning a Minor
Personal information concerning a minor under 14 years of age will not be collected from them without the consent of the holder of parental authority or guardian.
Limits on Collection, Use and Disclosure
Collection
We limit the collection, use and disclosure of your personal information to only the purposes we have indicated to you. Your personal information can only be accessed by certain authorized persons, and only within the scope of their duties.
If you submit personal information on one of our websites for publication, we will publish it and may use the information in accordance with the authorizations you grant us.
Use
We may use the collected personal information for the following purposes:
- For internal administrative purposes;
- To provide the requested services;
- To respond to your requests for information;
- To improve our service offering;
- To provide any other complementary services associated with the requested services;
- To meet legal requirements;
- To monitor the quality of customer service and prevent errors and cases of fraud.
Disclosure
We may disclose your personal information to our employees, professional advisors, suppliers or subcontractors to the extent reasonably necessary to provide the requested services and for the purposes set out in this Policy.
Generally, we do not disclose your personal information. From time to time, we may communicate your personal information to certain suppliers or agents in order to provide the services you have requested from us. In all cases, we comply with the restrictions and requirements provided by law when we disclose your personal information, and the whole is subject to a written agreement and a security assessment demonstrating that your personal information benefits from adequate protection similar to that in place at Boscoville.
Your personal information will not be disclosed to third parties other than in accordance with this Privacy and Data Protection Policy, except as required or permitted by law, or as ordered by a court of competent jurisdiction.
We may share the collected information with our service providers to provide the applicable services, including for the purposes mentioned below.
We do not sell your personal information to third parties.
Impact Assessment
An impact assessment on the use of personal information is conducted before any personal information is used by Boscoville. When transfers are made outside Québec, the impact of such a transfer will also be assessed.
International Data Transfers
The information we collect for social networks may be stored, processed and transferred in all regions in which Boscoville or its subcontractors offer their services, to enable us to use the information in accordance with this Policy.
The information we collect may be transferred to the following countries: the United States of America and certain countries of the European Union.
Personal information that you publish on our website or submit for publication may be available, via the Internet, throughout the world. We cannot prevent the use, good or bad, of this information by third parties.
You expressly agree to the transfer of personal information described in this section.
Non-Personal Information
We automatically collect certain non-personal information using third-party analytics programs to help us understand how our visitors use our web services, but none of this information identifies you personally. Your IP address as well as other relevant information may be used to track any fraudulent or criminal activity, or any activities that constitute a breach of our terms of use.
Location
When your location is necessary to use our services, your location is collected through the location services of your device or through the location services of your browser, but only if you authorized this feature beforehand.
Cookies
Boscoville and affiliated web services use cookies. Cookies are small data files stored in the memory of your computer or mobile device when you visit a website or application. They are used to enhance your user experience by recording certain data about your computer or mobile device. By using Boscoville’s web services, you consent to this use.
Cookies We Use on Our Websites
We use cookies for the following purposes:
a) Authentification : We may use cookies to identify you when you visit and browse our website and our platform. The cookies used for these purposes are used to manage connections and sessions.
b) Personalization : We may use cookies to store information on your preferences and to enable us to personalize the services according to your needs. These cookies are used to document the language you use on the Boscoville websites.
Cookies Used by Our Service Providers
Our service providers use cookies that may be stored on your computer or device when you browse our website.
Cookie Management
You can set your browser or device to refuse cookies or to delete them after they have been stored. Please refer to the “Help” section of your browser or device for instructions. Please note that deleting or refusing cookies may affect your user experience.
Accuracy
We make every effort to ensure that your personal information is accurate and complete for the purposes for which it was collected, used or disclosed.
Retention of Personal Information
We retain your personal information only as long as is necessary for the purposes for which it was collected. We must destroy or anonymize such information in accordance with the law and our retention schedule.
Your personal and confidential information is kept, directly or through subcontractors, only for the duration necessary for the purposes of the services requested and the applicable legal and regulatory requirements. We require our subcontractors to subscribe to confidentiality agreements and apply policies equivalent to this one. In all cases, access to your personal and confidential information is restricted to persons for whom access is required to perform their duties.
Liability
We are responsible for the personal information in our possession or custody, including information entrusted to third parties for the purpose of providing you with the requested services. We require these third parties to retain this information according to strict standards of confidentiality and security.
We adhere to the principles set out in the Act. We have implemented policies and guidelines that ensure your privacy is protected. Our Privacy and Information Technology Security Officer oversees this Privacy and Data Protection Policy and the company’s various guidelines.
Our staff is informed and adequately trained on our privacy policies and practices.
Security Measures
We have implemented several security measures with respect to the personal information and confidential data we hold in order to protect them against loss, theft and to prevent unauthorized access, transmission, use or modification of such personal information, in particular with the following measures.
Privacy Impact Assessment
Boscoville performs a privacy impact assessment on any project involving the acquisition, development or redesign of an information system or the electronic delivery of services that involves the collection, use, disclosure, retention or destruction of personal information. This assessment documents the serious and legitimate interest in the use of personal information.
Secure Computing Environments
The infrastructure and equipment are hosted in a secure environment in a data centre located in Québec, Canada.
Access to Boscoville web services is via a transmission channel secured by an SSL certificate (HTTPS).
Access Management
Only employees whose duties require it have access to personal or confidential information. Access to data is logged and monitored.
Training and Awareness
Our employees and partners are trained and aware of the importance of protecting your personal information.
Confidentiality Agreement
The signing of a confidentiality agreement by our employees: failure to comply with this agreement may result in sanctions up to and including dismissal.
Security audits are carried out by firms specializing in information security.
Destruction
We retain your personal information only as long as is necessary for the purposes for which it was collected. We must destroy or anonymize such information in accordance with the law and our retention schedule. When we destroy or anonymize personal information, we take the necessary measures to ensure its confidentiality and that no unauthorized person has access to it during the destruction or anonymization process.
Management of Incidents Involving Personal Information
If Boscoville has reasons to believe that a confidentiality incident involving personal information has occurred and that there is a risk that serious harm will be caused by the incident, Boscoville will promptly notify the Commission d’accès à l’information and any person whose personal information is affected by the incident. Boscoville may also notify any person or organization that may be able to mitigate this risk, by communicating only the personal information required for this purpose without the consent of the person concerned. In all cases, a log will document the incident for reference purposes.
User Rights
Request for Access, Withdrawal or Correction
Subject to any regulatory or contractual restrictions, you may consult, correct or destroy the personal information we hold about you.
We will send you such information within a maximum of 30 days from the date of receipt of the written request and in a structured, commonly used technological format. However, a fee may be charged for processing your request.
Under certain circumstances, we may refuse to provide you with the information you have requested. Exceptions to your right of access include the fact that information cannot be disclosed for legal or security reasons.
These limitations are described in the Act respecting the protection of personal information in the private sector.
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 in accordance with the Act.
Data Portability
Users have the right to request the portability of their personal data held by Boscoville to another site.
Limitation and Opposition to Data Processing
Users have the right to request the limitation of or to oppose the processing of their data by Boscoville and Boscoville cannot refuse this request unless it can be shown that there are legitimate and compelling reasons for doing so, which may override the interests and rights and freedoms of the users.
Decision Based Exclusively on an Automated Process
Users have the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning them, or significantly affects them in a similar way.
Requests, Complaints and Questions
We are committed to responding to your questions and concerns regarding the protection of your personal information. If you are not satisfied with the response, you may contact the Privacy Officer at the address below.
Contact
Any request or complaint concerning the protection of personal information should be sent to the Privacy Officer at the address below:
Boscoville Privacy Officer
10950 Perras Boulevard
Montréal, Québec H1C 1B3
Email: direction@boscoville.ca
If Boscoville’s Privacy Officer decides not to respond to a user’s request, and this person wishes to contest this decision, or if the user believes that one of their rights has been infringed, they have the right to contact the Commission d’accès à l’information of Québec (Commission d’accès à l’information | (gouv.qc.ca).
Revision and Approval
This Policy comes into effect upon adoption by the Board of Directors and may be revised at any time by the Privacy Officer.
Changes may be proposed by various Boscoville stakeholders, which must be submitted in writing to the Privacy Officer.
This Policy should be reviewed at least every two years to ensure its relevance to Boscoville’s mission, the activities of its users and any substantial changes in legislation or regulatory requirements.
Effective Date
This Policy is effective as of September 1, 2023. It cancels and replaces all previous guidelines on this matter.