Privacy Policy
Last updated: October 2023
This Privacy Policy lays forth Bulle et Baluchon's practices regarding the collection, use, disclosure and retention of your personal information. Please note that throughout the Policy we frequently use the word "we" when referring to Bulle et Baluchon.
Our Policy applies regardless of the means by which personal information is collected, whether in person, by telephone, by email, or through our website.
Our Policy applies regardless of the means by which personal information is collected, whether in person, by telephone, by email, or through our website.
1 How to contact our Privacy Officer?
You can reach our Privacy Officer:
By e-mail:
Attention:
Jacinthe Samson, Privacy Officer.
By phone:
819-822-6046
Attention:
Jacinthe Samson, Privacy Officer.
By mail:
1255 Daniel Street, Suite 131, Sherbrooke, Quebec, J1H 5X3
Attention:
Jacinthe Samson, Privacy Officer.
2 How do we collect your personal information and for what purposes do we use it?
2.1 As part of our mission and the services we offer:
We process, use, disclose and retain the personal information of children whose safety and development we believe to be compromised, and for whom a report to the Department of Youth Protection is deemed necessary. The personal information collected includes but is not limited to: surname, first name, home address, date of birth.
We process, use and retain the personal information of adults who request assistance and for whom follow-up is required. Follow-up is consented to by the person concerned. The personal information collected includes but is not limited to: surname, first name, email address, telephone number.
2.2 Human Resources Management (employees, job applicants and administrators):
We process, use, disclose and retain the personal information of employees and job applicants for the purposes of, among others, maintaining employee records, evaluating and analyzing pre-employment applications, and for payroll. We process, use, disclose and retain administrators' personal information for internal communications and government accountability purposes. The personal information collected includes but is not limited to: Surname, first name, current and previous home addresses, email address, date of birth, telephone number, social insurance number, driver's license, emergency contact, resume, employment history, criminal history, financial information related to bank accounts, void cheque.
2.3 Communication to members:
We process, use, disclose and retain the personal information of members of the organization in order to communicate with them, in particular for the Info-Bulle newsletter and invitations to activities offered by the organization. The personal information collected includes but is not limited to: Surname, first name, home address, email address and telephone number.
We process, use, disclose and retain the personal information of children whose safety and development we believe to be compromised, and for whom a report to the Department of Youth Protection is deemed necessary. The personal information collected includes but is not limited to: surname, first name, home address, date of birth.
We process, use and retain the personal information of adults who request assistance and for whom follow-up is required. Follow-up is consented to by the person concerned. The personal information collected includes but is not limited to: surname, first name, email address, telephone number.
2.2 Human Resources Management (employees, job applicants and administrators):
We process, use, disclose and retain the personal information of employees and job applicants for the purposes of, among others, maintaining employee records, evaluating and analyzing pre-employment applications, and for payroll. We process, use, disclose and retain administrators' personal information for internal communications and government accountability purposes. The personal information collected includes but is not limited to: Surname, first name, current and previous home addresses, email address, date of birth, telephone number, social insurance number, driver's license, emergency contact, resume, employment history, criminal history, financial information related to bank accounts, void cheque.
2.3 Communication to members:
We process, use, disclose and retain the personal information of members of the organization in order to communicate with them, in particular for the Info-Bulle newsletter and invitations to activities offered by the organization. The personal information collected includes but is not limited to: Surname, first name, home address, email address and telephone number.
3 How do we collect your personal information?
3.1 We collect personal information directly from the concerned person related to:
3.3 Minors under the age of 14
If necessary, we obtain the consent of the holder of parental authority in order to process the personal information of children under the age of 14. If we discover that we have collected personal information from a person under the age of 14 without the consent of the holder of parental authority or other authorization, we will ensure that we do not process, use, disclose, or retain this information unless we believe that the child's safety or development is at risk.
3.1.1 Our mission and the services we provide: when the individual voluntarily provides us with their personal information, when the individual fills out our forms, when they communicate with us by email, telephone, or in-person.
3.1.2 Human resources management (employees, job applicants and administrators): when you voluntarily provide your personal information through your communications with us, by email, telephone or in person, when you submit your application for a job with us, when you fill out pre-employment and post-employment forms, when you submit your information for payroll and/or when you begin your term with us as an employee.
3.1.3 Member communication: when the individual fills out our forms by communicating with us by email, phone or in person.
3.2 We collect personal information from third parties about an individual related to:3.2.1 Human resources management: from digital platforms such as, but not limited to, LinkedIn, Indeed, JobBoom and JobIllico, from former employers, and from HR service providers or platforms.
3.3 Minors under the age of 14
If necessary, we obtain the consent of the holder of parental authority in order to process the personal information of children under the age of 14. If we discover that we have collected personal information from a person under the age of 14 without the consent of the holder of parental authority or other authorization, we will ensure that we do not process, use, disclose, or retain this information unless we believe that the child's safety or development is at risk.
4 Who will have access to your personal information within the Bulle et Baluchon organization and to whom do we share your personal information?
4.1 Internally:
Within Bulle et Baluchon, employees will have access to your personal information only when it is necessary to fulfill the purposes disclosed in this Policy or in a related consent form.
Within Bulle et Baluchon, employees will have access to your personal information only when it is necessary to fulfill the purposes disclosed in this Policy or in a related consent form.
5 What identification, profiling, or location technologies do we use?
We use technologies to identify, locate or profile you through the use of cookies on our website. For more information, please refer to our cookie policy.
6 How long do we keep your personal information?
With your consent, we will retain your personal information for as long as the purposes for which it was collected have not been fulfilled and in accordance with our internal policies and processes for this purpose. The retention period of personal information is consented to at the time of drafting the consent agreement between Bulle et Baluchon and the person concerned.
For more information about how long we retain personal information for, please contact our Privacy Officer at the contact information herein1.
For more information about how long we retain personal information for, please contact our Privacy Officer at the contact information herein1.
7 Where do we store personal information and is it transferred outside of Quebec?
Some information is held in paper format at our employees' workstations, in classified folders to which only the employees concerned have access. When using third-party services, your personal information may be transferred or hosted outside of Quebec by service providers. For example, when we use Outlook, Indeed, or any other platform necessary for Bulle et Baluchon to function.
When we consider that the disclosure of your personal information outside of Quebec is necessary to support our operations, we assess whether your personal information is adequately protected in the event of disclosure. We will only disclose your personal information if we believe it is adequately protected. This communication will also be governed by an appropriate contractual agreement.
When we consider that the disclosure of your personal information outside of Quebec is necessary to support our operations, we assess whether your personal information is adequately protected in the event of disclosure. We will only disclose your personal information if we believe it is adequately protected. This communication will also be governed by an appropriate contractual agreement.
8 Safeguards and inherent risks
We have adequate security measures in place to protect your personal information. In particular, we have put in place appropriate physical, technical, and administrative safeguards to ensure the protection of personal information.
Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or guarantee the security and confidentiality of any personal information you transmit or provide to us. You do so at your own risk.
If you have reason to believe that personal information has been compromised, please contact our Privacy Officer at the contact information herein.
Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or guarantee the security and confidentiality of any personal information you transmit or provide to us. You do so at your own risk.
If you have reason to believe that personal information has been compromised, please contact our Privacy Officer at the contact information herein.
9 What are your rights with respect to your personal information?
You have a number of legal rights with respect to your personal information.
9.1 Access to your personal information
You can ask us if we hold any personal information about you and, if so, you can ask us to have access to that personal information.
9.2 Rectification
You may ask us to rectify any incomplete or inaccurate personal information we hold concerning you.
9.3 Withdrawal of consent
You may withdraw your consent to the disclosure or use of the personal information we hold about you. However, by doing so, you consent to no longer being able to benefit from our services.
9.1 Access to your personal information
You can ask us if we hold any personal information about you and, if so, you can ask us to have access to that personal information.
9.2 Rectification
You may ask us to rectify any incomplete or inaccurate personal information we hold concerning you.
9.3 Withdrawal of consent
You may withdraw your consent to the disclosure or use of the personal information we hold about you. However, by doing so, you consent to no longer being able to benefit from our services.
10 How can you exercise your rights?
To exercise any of your rights listed above, please contact our Privacy Officer at the contact information herein1.
11 How do you file a complaint regarding our handling of your personal information?
Bulle et Baluchon takes inquiries, complaints and comments about how we handle your personal information seriously. We encourage you to contact our Privacy Officer with complaints or comments about our privacy practices.
Your complaint will be reviewed by our Privacy Officer, who will determine whether the handling of your personal information complies with our privacy policy, as well as any applicable laws.
You can also file a complaint with Quebec's Information-Access Board (Commission d'accès à l'information du Québec) using the form available on their website. However, we encourage you to contact our Privacy Officer first.
Your complaint will be reviewed by our Privacy Officer, who will determine whether the handling of your personal information complies with our privacy policy, as well as any applicable laws.
You can also file a complaint with Quebec's Information-Access Board (Commission d'accès à l'information du Québec) using the form available on their website. However, we encourage you to contact our Privacy Officer first.
12 External sites or services
This Policy does not apply to any third-party websites, pages or applications that may be accessed through our products and services, including, but not limited to, our websites. We are not responsible for any such third-party services. If you follow such links, these third-party sites or services will likely have their own privacy policies that you will need to review before submitting your personal information.
13 How do we update this Policy?
We can, at our sole discretion, change our Policy. Changes will be posted on Bulle & Baluchon's website, along with a notice of change. The proposed amendments will come into force on the date set out in the relevant change notice.
Summary of our Internal Privacy Governance Policy
Bulle et Baluchon is committed to protecting your personal information for the span of its duration, in accordance with its privacy practices and per the requirements of applicable laws.
To this end, in addition to our privacy policy, Bulle et Baluchon has adopted an internal governance policy with respect to personal information. The purpose of this agreement is to lay forth the principles governing the protection of personal information in the context of Bulle et Baluchon's operations.
To this end, in addition to our privacy policy, Bulle et Baluchon has adopted an internal governance policy with respect to personal information. The purpose of this agreement is to lay forth the principles governing the protection of personal information in the context of Bulle et Baluchon's operations.
1 Roles and responsibilities
Since the respect of your personal information concerns everyone at Bulle et Baluchon, our person in charge of personal information protection is supported by a team that is aware of the protection of personal information as well as the rights of the persons concerned.
Every member of our staff has a role to play so that we can act in accordance with our Privacy Policy. In fact, each member of our staff is expected to:
Every member of our staff has a role to play so that we can act in accordance with our Privacy Policy. In fact, each member of our staff is expected to:
i. Address any questions or comments to the Privacy Officer about how we process or should process your personal information.
ii. Participate in training and awareness-raising activities on the importance we place on the protection of personal information.
ii. Participate in training and awareness-raising activities on the importance we place on the protection of personal information.
2 Guiding principles of governance
Bulle et Baluchon recognizes the importance of the protection, confidentiality and security of the personal information we handle in the course of our activities, as well as the importance of raising awareness among our staff and partners related to this subject.
Bulle et Baluchon has prepared guidelines on best practices and prohibited practices regarding how we may process your personal information. For example:
Bulle et Baluchon has prepared guidelines on best practices and prohibited practices regarding how we may process your personal information. For example:
i. We outline the purposes and objectives before collecting your personal information. Thereafter, your personal information is only used in accordance with those purposes and objectives.
ii. We seek to collect the bare minimum in order to achieve the identified aims.
iii. We obtain your consent at the time we collect your personal information, particularly when it is sensitive personal information.
iv. We post our Privacy Policy clearly and explicitly when we collect your personal information through technological means.
v. We ensure that our technological products or services with privacy settings, provide the highest level of privacy by default, without any action required on your part.
vi. If we use technologies that enable identification, location or profiling, we will disclose this to you and inform you of the terms of use.
vii. We conduct Privacy Impact Assessments when required by law, and when we consider that the processing of your personal information poses risks to your privacy.
viii. We do not share your personal information with third parties without your consent, except as permitted by law.
ii. We seek to collect the bare minimum in order to achieve the identified aims.
iii. We obtain your consent at the time we collect your personal information, particularly when it is sensitive personal information.
iv. We post our Privacy Policy clearly and explicitly when we collect your personal information through technological means.
v. We ensure that our technological products or services with privacy settings, provide the highest level of privacy by default, without any action required on your part.
vi. If we use technologies that enable identification, location or profiling, we will disclose this to you and inform you of the terms of use.
vii. We conduct Privacy Impact Assessments when required by law, and when we consider that the processing of your personal information poses risks to your privacy.
viii. We do not share your personal information with third parties without your consent, except as permitted by law.
3 PRIVACY INCIDENT
Bulle et Baluchon has put in place a process to respond to and deal with privacy incidents.
Under this process, Bulle et Baluchon must take reasonable steps to reduce the risk of serious harm and review its practices to prevent future privacy incidents of the same nature.
Bulle et Baluchon documents all privacy incidents in its Privacy Incident Registry and will adapt its privacy policy as needed, following a privacy incident.
Under this process, Bulle et Baluchon must take reasonable steps to reduce the risk of serious harm and review its practices to prevent future privacy incidents of the same nature.
Bulle et Baluchon documents all privacy incidents in its Privacy Incident Registry and will adapt its privacy policy as needed, following a privacy incident.
