Privacy policy
Candidates and employees
Last updated: July 13, 2023
What is the scope of this policy?
What do the following terms mean?
Why do we collect your personal information?
How do we obtain your consent?
What personal information is being collected?
Why do we disclose your personal information with third parties?
What is expected of you as an employee?
How long is your personal information kept?
Where is your personal information stored?
What are your rights over your personal information?
How is your personal information protected?
LPDQ considers your privacy to be of great importance and is committed to protecting your personal information.
This policy describes how we collect, use, communicate and protect your personal information and how you can exercise your rights, for example to access or rectify them.
What is the scope of this policy?
This policy applies to the personal information of employees and candidates held by LPDQ, whether by the company itself or by a third party.
What do the following terms mean?
"Applicable privacy laws" refers to the laws, regulations, recommendations or opinions applicable to privacy issues, including the Law on the protection of personal information in the private sector, as well as any other law, regulation, recommendation or opinion that replaces, complements, modifies, extends, brings into force or codifies the applicable privacy laws.
"Employee" refers to any individual employed by LPDQ, including any intern, student or agent, full-time or part-time, permanently or temporarily.
"Candidate" refers to any individual who applies for a job with LPDQ or provides LPDQ with personal information for this purpose.
"Personal information" refers to any information that pertains to an individual and that, directly or indirectly, identifies them, like a name, an employee number, a social insurance number (SIN), an online tracking identifier such as an IP address or one or more particular characteristics relating to the physical, physiological, mental, economic, cultural or social identity of this individual.
Why do we collect your personal information?
We will only collect, use and disclose personal information necessary to carry out our activities and to manage your employment or your application.
This includes the following uses:
To facilitate the hiring process
Including :
Verifying references
Conducting background checks
Conducting pre-employment assessments reasonably essential to perform the job
Preparing, conducting and analyzing interviews of candidates applying for a position with LPDQ
Contacting you again in the future with other job opportunities that may be of interest to you (with your consent)
To communicate with you
Including :
Facilitating communication with employees and candidates
Facilitating communication with an employee's emergency contacts (e.g. family members) in the event of a medical emergency or any other situation that may arise and require such communication
To manage employment benefits
Including :
Determining and managing remuneration
Communicating with third parties, including payroll or benefits service providers, insurers, accountants, lawyers and various government services, as required by law
Administering employee benefit plans
To perform data analysis
Including :
Collecting demographic data on employees and candidates in order to ensure the success of various diversity, equity and inclusion (DEI) programs and strategies
Evaluating employee productivity and performance for the purpose of annual evaluations and salary adjustments
To protect our infrastructure
Including :
Monitoring the presence of employees, candidates and other visitors on our premises for security purposes with various surveillance systems
Recording entry, exit, and working time data with card access systems
Managing access privileges of employee user accounts on computer systems
To protect your health and safety
Including :
Monitoring and promoting employee health and safety, for example:
Administering disability benefits
Making decisions pertaining to accessibility or the duty-to-accommodate, job retention or the ability to return to work safely, or the assessment of risks in the workplace
Sharing select health information with medical consultants, disability consultants, government parties or financial institutions
How do we obtain your consent?
We collect, use and disclose your personal information with your consent or as permitted or as required by law. How we obtain consent will depend on context.
- Consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.
- If you choose to share personal information with us after reading this policy, it is implied that you consent to the use and disclosure of your personal information as outlined in this policy.
- Where possible and appropriate, we offer individuals a clear choice regarding any collection, use or disclosure of personal information.
- In general, we ask for consent when your personal information is being collected.
- When seeking to use personal information for a new purpose that was not anticipated at the time we originally sought your consent or for a purpose that is not provided for by law, we will ask for consent again.
- When providing us with the personal information of another individual (e.g. emergency contact), you are responsible for obtaining their consent.
- We may collect your personal information from third parties (e.g. information obtained from references, criminal records).
- At any time, you can withdraw consent pertaining to the use or disclosure of your personal information by contacting us using the options listed in the "How to contact us?" section.
- Before following up on a request, you may be required to provide proof of identity.
- In some instances, withdrawing consent may result in our inability to process your application or to maintain an employment relationship.
What personal information is being collected?
Identification information
Name
Mailing and email address
Phone number
Date of birth
Social Insurance number (SIN)
Contact person – phone number and relationship with the employee
Employment administration
Qualifications and skills
Performance evaluation
Disciplinary file
Any personal information in a legal document relating to your employment
Any personal information in a medical document that you provide us with
Driver's license (if driving is necessary for employment or as a piece of identification for a background check)
Integration
Resume and references
Background check results
Banking information (for salary payment)
Residency status, citizenship status or work permit
Name and date of birth of spouse and/or dependants (if applicable)
Photography
Monitoring
Device geolocation when used to work remotely (IP address, access key)
Browsing history, search history, or website or application interaction data when using computer equipment provided by the employer
Why do we disclose your personal information with third parties?
We may disclose your personal information to third parties or service providers. We will endeavor to protect the personal information shared as a result of contractual agreements and, where applicable, written commitments, asking third parties to adopt appropriate practices, procedures and confidentiality and security measures that are at a minimum equivalent to ours.
We may use service providers to perform services on our behalf. We only provide these service providers with the personal information necessary to perform the services entrusted to them.
Categories of services provided by third parties with access to your personal information:
- Website hosting
- Background checks and psychometric tests
- Financial or accounting audit purposes
- Security cameras and building access management
- Insurance and mutual plan management
- Payroll and time management
- IT support
If you would like more information about our service providers, visit the “How to reach us?” section for more information on how to contact us.
We may disclose personal information when required to do so by law, regulation, court order, subpoena, valid request or search warrant, or in response to a government investigation or other legitimate request.
This information may also be disclosed to our accountants, auditors, agents and lawyers to enforce or protect our rights. Certain personal information may also be disclosed if we reasonably believe that it is necessary to do so to protect our rights, safety or property, or others, to the extent provided for or authorized by law (e.g. to prevent fraud).
What is expected of you as an employee?
We will ensure that personal information we collect, use or disclose is as accurate, up-to-date and complete as possible.
We assume that any information you provide to us is accurate and up-to-date. If any of your personal information changes during your employment with us, you are required to inform us of these changes so that your employment file may be updated.
How long is your personal information kept?
We will keep your personal information in accordance with our commercial and legal obligations and only for as long as necessary to achieve the purposes outlined in this policy, unless the law requires a longer retention period.
Upon hiring, we generally keep personal information on file for the duration of your employment plus three (3) years, unless we are required by law to keep it longer.
We generally keep the personal information of unsuccessful candidates for three (3) years starting from the date upon which the decision was made, unless we are required by law to keep it longer. Similarly, if you authorize us to contact you again for future job opportunities, we will keep your personal information for three years after the decision was made.
If personal information is used to make a decision that directly affects you, we will retain the information for a reasonable period of time after using it and for at least one year after making such a decision.
Where is your personal information stored?
The personal information of employees and candidates is currently stored in Quebec (Canada). If necessary, the information may be held and used in Quebec (Canada). As a result, we may disclose personal information in countries other than your country/province/state of residence, where privacy laws may be different.
If your personal information is used outside of your country/province of residence, it is subject to the laws of that country/province/state and may be disclosed to the governments, courts, law enforcement agencies or regulatory agencies of that other country, or disclosed in accordance with the laws of that country. However, our practices regarding your personal information will always be governed by this policy and by applicable privacy laws.
What are your rights over your personal information?
You may be asked to provide proof of identity before we can respond to your request. This identification information will only be used for that purpose.
You have several rights as it pertains to your personal information, including:
Right to access and rectify data
You can request to access and to obtain a copy of personal information we collected about you.
If any personal information concerning you is inaccurate, incomplete or equivocal, or if its collection, communication or storage is not authorized by law, you may request that it be rectified.
You can also ask us for information about the source of your personal information (if it was not obtained from you), as well as the names of the persons who have access to your information and details about their retention period.
Right to withdraw consent
You can withdraw consent pertaining to the use or disclosure of the personal information collected.
If necessary, you can also request that your personal information no longer be shared.
To exercise your rights, please send a written request to our Privacy Officer using the contact details listed in the “How to reach us?” section.
After your request is submitted, you will receive a written response within 30 days starting from the date of receipt of your request.
How is your personal information protected?
Appropriate procedures and security measures are put in place to ensure the protection of your personal information, whether it is stored on our servers or with one of our service providers. We work with a specialized service provider to ensure this protection.
Only authorized and qualified personnel who need to consult your personal information in the exercise of their duties have access to it.
However, no security measure is absolute or fully guaranteed. If you have reason to believe that interactions with us are no longer secure (for example, if you believe that the security of the information you have provided to us has been compromised), please contact our Privacy Officer immediately.
Who evaluates policy compliance?
Our Privacy Officer independently assesses policy violation allegations by reviewing practices and procedures and determines if follow-up corrective measures are necessary, including disciplinary measures up to and including termination of employment.
How to reach us?
You can send any request, question, complaint or comment concerning this policy to our Privacy Officer at:
Will this policy be updated?
This policy has been in effect as of the date the policy was updated as noted at the top of the page.
If significant changes are made to this policy, for example, to comply with new legal requirements, a notice will be published on our website, indicating the date of the last update.
