VERIFICATION LIST
Preamble
Effective date: September 20, 2023.
Legal framework: Law on Access to Documents of Private Organizations and the Protection of Personal Information (RLRQ, p.39.1)
At Norbec, respecting the privacy of our customers and employees is extremely important.
As a private organization, Norbec collects and uses personal information and is subject to the Law on the Protection of Act respecting the protection of personal information in the private sector and other laws of the province of Quebec and federal laws of Canada and the regulations that stem from them. It is responsible for ensuring the protection of the personal information it holds and demonstrating compliance with the legal obligations. To support Norbec in the exercise of its responsibilities and legal obligations regarding the protection of personal information, the management has designated a privacy officer to ensure compliance with the Law and promote privacy-respecting practices. This policy establishes the general normative framework for the governance of Norbec’s personal information, in compliance with its legal obligations, including those arising from the Access Law.
Users outside Quebec If you use Norbec’s websites or avail of Norbec’s services and do not reside in Quebec, please note that by providing your personal information, you are deemed to consent to: the collection, use, and disclosure of your personal information in Quebec; and the collection, use, and disclosure of your personal information in accordance with the laws of the province of Quebec (which may differ from the privacy laws of your jurisdiction of residence) and this policy.
Contact Us
If you have provided personal identification information on Norbec’s website or through other means and wish for this information to be deleted, modified, or corrected from our databases, and/or if you wish to provide feedback or lodge a complaint regarding non-compliance with this policy, please contact us at the address below. We will do our best to respond to your request in a timely manner.
Mr. Brad Tomalty
Privacy Officer at Norbec
infoprotection@norbec.com
OBJECTIVES OF THE PERSONAL INFORMATION PROTECTION POLICY
This policy aims to:
Establish the commitments that guide Norbec’s practices in managing personal information.
Demonstrate compliance with legal obligations regarding the protection of personal information.
LEGAL FRAMEWORK
Legal framework: Law on Access to Documents of Private Organizations and the Protection of Personal Information (RLRQ, p.39.1)
SCOPE
This policy applies to all members of Norbec when they collect, use, disclose, retain, or destroy personal information in the course of their duties, or when they otherwise have access to personal information held by Norbec, including those held by a third party. It applies regardless of the medium, from collection to destruction of information.
It also applies to any individual to whom Norbec entrusts personal information as part of a mandate or service contract.
The policy does not apply to information held by a member for personal purposes, even if stored on a Norbec technological platform.
DEFINITIONS
Personal information: Any information held by Norbec concerning an individual that allows, directly or indirectly, for their identification. For example, information about your identity and contact details, your first and last name, your date of birth, your residential address, your phone number, your email address, your payment details.
Third party: Any individual or entity that collects, uses, retains, discloses, or destroys personal information on behalf of Norbec or otherwise manages personal information held by Norbec. This also includes any individual or entity from whom Norbec obtains personal information or to whom it communicates such information, without being otherwise connected to Norbec.
COMMITMENTS
Norbec’s practices regarding the protection of personal information are based on the following commitments:
Responsibility: Norbec is responsible for the personal information it holds, including those whose collection, use, retention, or destruction is carried out by a third party. It implements policies and practices demonstrating this responsibility.
Limitation of information collection: Norbec determines the purposes for which it collects information before collecting it. In compliance with the Privacy Policy and Terms of Use, Norbec only collects the personal information reasonably required to offer and manage its services and activities, to communicate offers and information of interest to you, to conduct data analysis and research, for the purpose of improving or developing products and services, as well as to enhance your overall customer experience and for other purposes permitted or required by law. This personal information is collected in various ways, for example, directly from you, from third parties, when you visit the Norbec Website, and is retained only for the duration necessary to achieve the determined purposes.
Consent: Through the Privacy Policy and Terms of Use, Norbec adequately informs any individual about the collection of information concerning them, the use that will be made of it, and the third parties with whom this information will be shared for this purpose. By using the services and visiting the Norbec Website, you consent to the collection, use, and disclosure of your personal information as described in this policy. Norbec is committed to obtaining the individual’s consent before using or disclosing their information for other purposes, unless legally authorized.
You can withdraw your consent at any time, except in limited cases, including when we are bound by legal or regulatory requirements or when you have contractual obligations with Norbec. To withdraw your consent, you can contact Norbec at infoprotection@norbec.com.
Accuracy: Norbec ensures that the personal information it holds is up-to-date, accurate, and complete as long as it is used. However, it is your responsibility to provide accurate, truthful, and complete information. If you notice errors in your personal information or need to update it, please notify us at infoprotection@norbec.com.
Security measures: Information security is important to Norbec. It is determined through a range of appropriate security measures aimed at protecting the personal information that Norbec collects, uses, discloses, retains, or destroys, taking into account their sensitivity, the purpose of their use, their quantity, their distribution, and their medium. Norbec aims to prevent unauthorized access to the personal information in its possession, as well as their loss, misuse, disclosure, or modification. Norbec ensures that access to your personal information is always restricted to authorized employees.
Storage location: Unless the legal or contractual preservation of your personal information in Canada is required, it may be transferred abroad. For example, some of our service providers may have access to your personal information, process it, or store it outside your province, territory, or Canada as part of their services to Norbec. In such cases, personal information is governed by the laws of the territory where it is used or stored, including all laws authorizing or requiring the disclosure of information to government authorities, courts, and law enforcement agencies of that territory.
Transparency: Norbec makes its policies and procedures regarding the management of personal information accessible on its webpage. This policy is subject to possible modifications. Any modification will take effect when the new modified version of the policy is published on this webpage. Notice will be posted on the Norbec Website to inform you of a significant modification to the policy, as required by law.
Right of access and rectification: Subject to the restrictions provided by the Access Law, Norbec undertakes to inform any individual who requests it of the existence of personal information concerning them, its use, and possible sharing with third parties. Norbec undertakes to allow any individual to consult or obtain a copy of their personal information and to have it corrected if necessary.
Complaint: If necessary, concerned individuals can request access to their personal information and voice their concerns or file complaints regarding their protection by Norbec by filling out this form or by sending it by email to infoprotection@norbec.com. . Any complaint will be subject to an investigation to verify the allegations of non-compliance with the provisions of this notice or Norbec’s privacy principles. Norbec typically responds within 45 days of receiving a complaint and will take all necessary measures to remedy the situation. If the matter cannot be resolved, Norbec agrees to cooperate in accordance with the dispute resolution system outlined below. If an individual feels that their complaint has not been dealt with satisfactorily, they may file a formal complaint, free of charge, with the regulatory bodies mentioned below.
In Canada, the Office of the Privacy Commissioner of Canada:Top of Form
30 Victoria Street, Gatineau, Quebec, K1A 1H3
Email: general@oic-ci.gc.ca
Phone: 1-800-282-1376
EFFECTIVE DATE AND REVIEW
Effective date
This policy takes effect as soon as it is adopted by management.
Policy revision
The policy will be revised as required from the date of adoption.
