1. Background
Flexia Conseil specializes in human resources management and processes personal information in the course of its activities.
As a consulting firm, we regularly collect, use and disclose personal information in the course of providing our talent acquisition and consulting services. The purpose of this policy is to ensure the protection of such information and to govern the manner in which it is collected, used, disclosed, retained and destroyed.
By providing us with personal information (through our Web site, by e-mail, in person or by telephone), you agree to its processing in accordance with this policy.
We may only use your personal information for the purposes for which it was collected or for a use consistent with those purposes.
2. Application
This policy applies to Flexia Conseil, its officers, employees, consultants and any person who otherwise provides services on behalf of Flexia Conseil.
It applies to all types of personal information managed by Flexia Conseil, concerning its customers, candidates, employees, partners or any other persons concerned.
3. Definitions
Personal information: Personal information is any information concerning a natural person that allows that person to be identified(1).
Sensitive information: Personal information is considered sensitive when it gives rise to a reasonable expectation of privacy, due to its nature or the context in which it is used. Information considered sensitive is medical, biometric or otherwise intimate in nature. Information revealing a person’s alleged racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation, are also considered sensitive(2).
Confidentiality Incident: A confidentiality incident is defined as the unauthorized access, use or disclosure of Personal Information and/or the loss of Personal Information or any other breach of the protection of Personal Information. (3)
Injury: Injury is defined as damage to a person’s rights or interests, especially bodily, material or moral harm caused to a person by a third party.
Assessing the risk of harm caused by a confidentiality incident: When assessing the risk of harm caused by a confidentiality incident, we must consider the sensitivity of the information concerned, the apprehended consequences of its use and the likelihood that it will be used for harmful purposes.
4. ApplicationTypes of personal information collected
Flexia Conseil collects and processes various types of personal information in the course of its activities, including :
- Identity and contact information (first name, last name, social insurance number, date of birth, address, postal code, e-mail address, telephone number, language)
- Biographical information (job title, name of employer, photos, video or audio content)
- Marketing information and communication preferences, comments and survey responses
- Billing and financial information, such as billing address, bank account information or payment data
- Recruitment information (curriculum vitae, educational and employment history, copies of identification)
- Information about the use of our website (website visits, interactions with our advertising and social media content, information collected through cookies and other tracking technologies)
- Information provided to us by or on behalf of our customers, or generated by us in the course of providing our services, which may, where relevant, include special categories of personal information (such as racial or ethnic origin or health, disciplinary information (employee files)).
(1) Section 2, Act respecting the protection of personal information in the private sector
(2) Comité d’accès à l’information du Québec : What is sensitive personal information? | Commission d’accès à l’information du Québec (gouv.qc.ca) (2023)
(3) Section 3.6, Act respecting the protection of personal information in the private sector
(4) Office québécois de la langue française : préjudice | GDT (gouv.qc.ca) (2002)
5. Collection of personal information
Flexia Conseil collects personal information directly from the person concerned and with his or her consent, unless an exception is provided for by law. In all cases, the company collects information only if it has a valid reason to do so. The collection of personal information is limited to that which is necessary for the purposes for which it is collected.
Flexia Conseil collects the various personal information listed above through the following means:
- By means of Web forms integrated into our Web site
- By e-mail (directly or via an attached document)
- By phone
- In person
- Via public platforms, including our website
In accordance with the law, Flexia Conseil will inform the persons concerned of any information collected, the purposes for which it is collected and the means used for the purposes of collection.
6. Use and disclosure of personal information
Flexia Conseil uses personal information only for the purposes for which it was collected. If personal information is to be used for other purposes, new consent must be obtained from the person concerned, except in cases provided for by law.
Measures are in place to limit access to personal information. Access is restricted to persons who are authorized to have access and for whom consultation of the personal information is necessary for the performance of their duties. Should other persons require access, new consent must be obtained from the person concerned, except in cases provided for by law.
Flexia Conseil uses Google Analytics to create audiences and track user behavior on the website. Google Analytics and other third parties collect data such as page views, date, time, time on page, frequency of visits, links clicked, etc. Data such as IP address, device type, geography and language are also recorded. Data such as IP address, device type, geography and language are also recorded. Anonymous data is used by Flexia Conseil for marketing purposes such as audience building and retargeting. The data helps Flexia Conseil to understand where the user is coming from so that it can optimize its marketing campaigns accordingly.
7. Retention and Destruction of Personal Information
Flexia Conseil retains personal information only as long as necessary for the fulfillment of the purposes for which it was collected, unless a minimum retention period is required by law.
At the end of the retention period, or when the personal information is no longer required, it is destroyed or anonymized (no link can be established between the personal information and the individual).
8. Rights regarding personal information and withdrawal of consent
Any individual may submit a written request for access, rectification or withdrawal of consent with respect to his or her personal information. The request must be submitted to Flexia Conseil’s Privacy Officer (see contact information below).
The Privacy Officer will process the request within 30 days of receipt of the written request.
9. Complaints handling process
Any person wishing to make a complaint concerning the application of this policy or the protection of his or her personal information by Flexia Conseil must submit a letter in writing to the person responsible for the protection of personal information (see contact information below) specifying his or her name, contact information and the subject of the complaint so that it can be evaluated. Flexia Conseil will treat all complaints as confidential and will provide a written response to the complainant.
You can also file a complaint with the Commission d’accès à l’information du Québec.
10. Contact us
Privacy Officer :
Marie-Michèle Leclerc
3175 de la Pinière Blvd. (#103), Terrebonne, Quebec j6X 4P7