NATIONAL RELOCATION SERVICES (RELONAT) INC.
POLICY ON RESPECT FOR PRIVACY
RELONAT Inc. (hereinafter called "RELONAT") has always attached great importance, within the scope of its activities, to the privacy of individuals, including its clients, co-contractors, employees and visitors to its website. Absolute confidentiality of personal information is a cornerstone of our business. Regardless of how the range of goods and services we offer might grow and the way that technology might develop, protecting personal information will always continue to be one of our objectives.
This policy describes RELONAT's principles in relation to the protection of personal information.
This information is gathered and conveyed, first and foremost, with regard to the goods and services provided by RELONAT. In all cases, RELONAT faithfully protects the privacy of individuals and the integrity of their personal information.
3. Determination of the purposes of collecting personal information
5. Limitations of RELONAT inc.'s collection of personal information
6. Limitations of using and conveying personal information by RELONAT
7. Retention of personal information by RELONAT
8. Accuracy of personal information held by RELONAT
9. Protection of personal information
11. Access to personal information
12. Complaints and requests for access to personal information
Personal information is any information that concerns a natural person (as opposed to an artificial person) and that makes it possible to identify him, other than by his name, his position, his address and telephone number at work and his e-mail address. A home address, date of birth or social insurance number as well as medical and financial information are examples of such personal information.
RELONAT is responsible for the personal information it manages, including personal information conveyed to third parties for processing and administrative purposes.
2.1 RELONAT has adopted practices that allow it to efficiently control compliance with this policy in the company, including the appointment of a person in charge of privacy protection.
2.2 Although it is this person in charge of privacy protection and senior management at RELONAT who assume ultimate responsibility for compliance with this policy, day-to-day compliance with the policy is delegated to individuals within RELONAT.
2.3 As for personal information sent to third parties for processing, RELONAT will enter into an agreement or will use other means of ensuring protection of personal information when such information is transferred to a third party, for instance, by examining such third parties' practices relating to personal information.
2.4 In order to give effect to this policy, RELONAT has adopted measures in relation to:
a) establishing procedures for the protection of personal information
b) establishing procedures for receiving and handling complaints and requests for information
c) distributing this policy and procedures on protecting personal information
d) training employees and conveying information to them with regard to RELONAT's policy and procedures.
RELONAT determines and discloses to the person concerned the purposes for which it gathers personal information before collecting it or at the time of collecting it, unless these purposes are obvious.
3.1 RELONAT makes sure that the purposes of collecting personal information and the possible use of such information are clear to the individual.
RELONAT shall abstain from gathering, using or conveying a person's personal information without his knowledge and without having obtained his prior consent, except in certain limited cases authorized by legislation:
4.1 RELONAT shall request consent to use or convey personal information at the time of collecting the information. In some cases, consent to use or convey the information will be requested after collecting but before using it, particularly if RELONAT wants to use it for a purpose about which the individual has not yet been informed.
4.2 RELONAT agrees to obtain valid consent to collect, use and convey personal information. To reach this objective, the purposes for which the information will be used are explained, if not obvious, so that the individual can reasonably understand how the information will be used or conveyed.
4.3 As a condition of supplying a product or service, RELONAT does not unreasonably demand an individual's consent with regard to collecting, using or conveying information over and above what is necessary under the circumstances.
4.4 The way in which RELONAT requests consent may vary, depending on the circumstances and the type of information collected. When it determines the type of consent required, RELONAT examines the nature of the information, the potential use of it, applicable legislation and the type of interaction within the scope of which the information is conveyed.
4.5 Consent to convey or use information must be evident, voluntary, well-informed and be given for specific purposes. The consent may be conveyed by a duly appointed representative or by a guardian or curator.
4.6 An individual who is subject to legal or contractual restrictions may withdraw his consent at any time by giving RELONAT sufficient notice. Due to the withdrawal of the consent, there is a possibility that RELONAT might no longer be able to provide or continue to provide certain services or benefits to the person in question, in which case the individual will receive notification of the impact of withdrawing his consent.
The collection of personal information by RELONAT is limited to what is necessary for the purposes that it has mentioned. RELONAT always obtains personal information through fair and legal methods.
There is a possibility that RELONAT may collect and use a third party's information on someone, when the law so authorizes it, and with the individual's consent in all other cases.
In this case, RELONAT shall enter the source of this information on the file.
6. Limitations of using and conveying personal information by RELONAT
RELONAT uses and conveys no personal information for purposes other than the ones for which it has been gathered, except with the individual's consent and depending on what legislation so requires or allows.
RELONAT shall retain personal information as long as it reasonably needs it for the specified purposes.
RELONAT makes reasonable efforts to ensure that individuals' personal information is as accurate and complete as required by the purposes for which it is used.
8.1 RELONAT makes reasonable efforts to collect information from individuals in order to update the information in its possession whenever necessary, for the purposes for which the information has been collected. As soon as a person informs it of the inaccuracy of the information concerning him, RELONAT updates the information as soon as possible.
8.2 A rectification request may be considered only if it is made in writing, in accordance with the procedure for requesting access to personal information provided for hereinafter.
RELONAT agrees to take and enforce security measures to ensure the confidential nature of the information.
9.1 RELONAT implements security measures that protect personal information against loss or theft as well as against unauthorized access, communication, reproduction, use or modification, regardless of the form in which it is kept.
9.2 The nature of the security measures that RELONAT implements varies according to the degree of confidentiality of the information that was collected, the quantity, distribution and form of the information as well as the methods of retaining the information.
9.3 RELONAT enforces the following protection methods:
a) physical methods, such as locking filing cabinets and restricting access to offices
b) administrative measures, such as security clearance and selective access
c) technical devices, such as the use of a password and limited access to the server, depending on the user
9.4 RELONAT makes sure that its employees are aware of the importance of ensuring the confidentiality of personal information and that they comply with this policy.
9.5 If personal information is conveyed to third parties for the purpose of processing it or for another administrative purpose, RELONAT makes reasonable efforts to ensure that the third party has recourse to personal information protection measures comparable to those that it uses itself.
RELONAT makes information available to users on its policies and practices of managing personal information. RELONAT demonstrates transparency with regard to the policy that it observes to ensure the protection of personal information.
10.1 The information is accessible in a form that is generally comprehensible.
10.2 RELONAT may make information available on its policies and practices in a number of ways, depending on the nature of the goods or service offered and the nature of the personal information, in French and in English.
RELONAT has adopted a procedure that the individual must follow to access his personal information.
11.1 Subject to relevant laws, upon receiving a written request by an individual in this regard, RELONAT informs the individual whether it has any personal information about him.
11.2 The individual may be obliged to send sufficient information to allow RELONAT to inform him of the existence, use and communication of personal information. The information sent is solely used for this purpose.
11.3 Upon receipt of a written request in this regard, RELONAT sends a summary of the use that has been made or that is being made of the information, notifies the individual of the identity of the third parties to whom it may have conveyed personal information concerning him and the purposes for conveying this information to the third party.
11.4 RELONAT may request reasonable charges to cover the costs of conveying the information, as long as it informs the individual in advance of the approximate amount of these charges, while allowing him to withdraw his request if he so desires. The individual may consult his file, free of charge, at RELONAT's head office.
11.5 If the individual proves that the personal information in RELONAT's possession is inaccurate or incomplete, the company will change the information in accordance with the request. If need be, the information changed will be sent to the third party having access to the information in question.
11.6 RELONAT may refuse an individual access to his information, in accordance with relevant legislation, in which case it shall explain its refusal, unless the law prohibits it from doing so.
Anyone on whom RELONAT has personal information may file a complaint regarding RELONAT's non-compliance with this policy.
12.1 Complaints and requests for access may be submitted in writing to the person in charge of privacy protection at National Relocation Services (RELONAT) Inc., 1500 Cunard, Laval, Quebec H7S 2B7, by phone at (514) 382-0790 or by e-mail at firstname.lastname@example.org.
12.2 RELONAT has set up a procedure with regard to receiving and handling complaints concerning this policy and its practices of handling personal information.
12.3 If an individual is not satisfied with RELONAT's reply to a complaint or policies and practices with regard to handling personal information, he may file a complaint with the Commission d’accès à l’information on the Commissioner's website (www.cai.gouv.qc.ca).