1.    POLICY OBJECTIVES

Guilbault values privacy and is committed to protecting the confidentiality of personal information.

The purpose of this document is to outline Guilbault’s personal information practices and explain its policies and procedures regarding the collection, use and disclosure of personal information. This policy applies to all personal information collected by Guilbault, regardless of the channel by which it is collected. Guilbault’s collection, use, disclosure and retention of personal information is subject to Quebec’s Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1).

2.    PERSONAL INFORMATION

A personal information includes any information that concerns a natural person and allows, directly or indirectly, to identify it.  

3.    RESPONSIBILITY

Senior management support is critical to the success of the privacy program and the adoption of a culture of privacy. Guilbault’s senior management promotes the privacy program and ensures that the company’s activities comply with defined policies and procedures.

At Guilbault, the day-to-day management of the privacy program is formally delegated to the Privacy Officer. The Privacy Officer is responsible for implementing Guilbault’s commitment to earning and maintaining the trust of customers and other stakeholders in how it handles personal information. The Privacy Officer is responsible for structuring, designing and managing the program, including all procedures, training, control/verification, documentation, evaluation and monitoring.  

4.    PURPOSES OF COLLECTION

In any situation, Guilbault ensures that it has a legitimate reason for collecting personal information. The main reasons we collect your personal information are:

  • Support recruitment processes and human resources management;
  • Provide products and services on behalf of the customer (in accordance with contractual obligations), including for billing purposes;
  • Establish and maintain business relationships with clients;
  • Support the organization and logistics of certain services, such as delivery services.

For example, for these purposes, we may collect:

  • Identification data: first and last names;
  • Contact information: addresses, telephone numbers, email.

Please note that we only collect data that helps us achieve the purposes set out in this Privacy Policy. We will not collect additional data without your prior consent.

5.    CONSENT

Except as permitted or required by law, Guilbault will only collect your personal information for the purposes for which we first obtained your consent.

You may withdraw your consent to the collection, disclosure and retention of your personal information at any time. You can also make a request to de-index your information, which could lead Guilbault to stop its distribution or to de-index a hyperlink giving access to this information. Please note that if you choose to withdraw your consent or de-index your information, Guilbault may not be able to provide certain products or services to you afterwards.

For withdrawal of consent or de-indexing, a written request must be submitted to the Privacy Officer. Guilbault undertakes to cease the use of the information within a period of 30 days.

6.    LIMITING COLLECTION

Guilbault undertakes to limit the collection of personal information only to what is necessary to establish, manage and maintain its relationships with data subjects and for the purposes detailed above. Guilbault collects the personal information you voluntarily provide when you use our services. These include, but are not limited to: completing a form, making phone calls for payment for services, applying for job offers, and other.

7.    LIMITING USE, COMMUNICATION AND RETENTION 

Guilbault undertakes to use personal information only for the purposes for which it was collected. Unless otherwise provided by law, Guilbault will obtain new consent from the individual to use the information for a purpose other than that for which the original consent was obtained.

Guilbault will not disclose personal information to third parties without the consent of the individuals concerned or if applicable laws provide that it is possible to do so without their consent.

In general, the personal information we collect is used and stored in Quebec. However, some of our service providers may store them outside of the province for the purposes of the services they provide to us. Where applicable, Guilbault shall ensure through a written agreement that the information is subject to controls to protect its confidential nature and that it is used and retained only for the purposes described in this policy.

Guilbault has a policy on personal information lifecycle management. In this regard, Guilbault undertakes to retain your personal information only for as long as necessary to enable us to achieve the purposes for which it was collected, comply with legal requirements and protect our legitimate business interests. After this period, Guilbault will ensure the safe destruction or anonymization of personal information in order to maintain the its confidentiality and to meet its obligations under applicable laws.

8.    ACCURACY

Guilbault undertakes to take all reasonable measures to ensure the accuracy of the personal information in its possession. If you notice any errors in your information or wish to update it, please let us know by contacting the Privacy Officer. Guilbault undertakes to make the necessary changes within a period of 30 days.

9.    SECURITY MEASURES

Guilbault uses all reasonable security measures to protect the personal information in its possession. We are committed to implementing safeguards against loss or theft, unauthorized access, use or disclosure, modification or destruction, through appropriate technical, administrative and organizational security measures. The level of protection afforded to personal information may depend on:

  • Sensitivity of personal information;
  • Quantity, distribution and format of data;
  • Method and retention period.

Privacy Incident Management

Guilbault has developed a privacy incident response plan, which is continuously reviewed and improved. This plan ensures that any privacy incident is properly managed and resolved in a coordinated manner. Incidents are logged for reference.

10.   TRANSPARENCY

Guilbault is committed to ensuring that everyone has easy access to specific information about its policies and practices regarding the management of personal information. Guilbault’s collection, use and disclosure of your personal information is governed by the current version of this Privacy Policy.

We may occasionally update our policy. As such, we invite you to consult it regularly, in order to be aware of the latest changes.

11.    ACCESS TO PERSONAL INFORMATION

You may request access to your personal information at any time. To do so, please contact the Privacy Officer. Guilbault undertakes to respond within 30 days of receipt of the request.

In case of refusal on our part, we will inform you of the reasons for this refusal, subject to the restrictions provided by law, as well as the remedies available to you. 

12.   POSSIBILITY OF FILING A COMPLAINT FOR NON-COMPLIANCE WITH THE PRINCIPLES

Questions or complaints about how Guilbault handles personal information may be forwarded to the Privacy Officer. Guilbault has procedures in place to respond to requests or complaints regarding its handling of personal information and undertakes to investigate such complaints or those concerning compliance with this policy confidentiality.

13.    PRIVACY OFFICER CONTACT

For any questions or comments regarding this Privacy Policy or the protection of personal information, to exercise any applicable rights, to file a complaint or to obtain information about Guilbault’s policies and practices with respect to any service provider, the Privacy Officer may be contacted by e-mail at privacy@groupeguilbault.com or by post: 

Francis Thivierge
8000 Armand-Viau Street
Suite 300
Quebec (Quebec)
G2C 2E2