Privacy policy
Privacy Policy
Prosphère Inc. is responsible for the personal information of its customers and staff under its management. It is its responsibility to take all necessary measures to ensure the security of personal and confidential information in its possession.
This Privacy Statement reflects our processes in place and describes our personal information protection practices to meet the requirements of applicable laws and professional responsibilities. This Privacy Statement also applies to Prosphère Inc. affiliates and partners.
Personal information
The term “personal information” means information that relates to an identifiable individual, as more specifically defined by applicable privacy laws.
Prosphère Inc. is committed to implementing best practices in the protection of personal information. We continually reassess our practices to maintain high management standards.
While providing services to clients and conducting due diligence on our services (or discussing services we may offer), we will collect or obtain personal information from clients and their companies. We may also collect personal information about you when you use this site or through your digital interactions with us.
We may collect or obtain such personal information further to obtaining consent.
Valid and informed authorization from the client
Authorization is considered valid only if it is reasonable to expect that individuals understand the nature, purposes and consequences of the collection, use or disclosure of their personal information to which they consent.
From the outset of the relationship with existing and potential customers, we obtain written consent for the collection, use and disclosure of their personal information.
We collect personal information primarily from the individual concerned. We may also collect it from other people, depending on the circumstances and the products or services desired.
An individual who holds or wishes to obtain a product or service may also provide us with personal information about other individuals who may benefit from this product or service. For example, this individual could add an insured person. However, if this information is provided to Prosphère, the individual must, before providing us with this information, have obtained the appropriate consent or the required authorizations to allow us to collect, use and disclose this personal information.
Limiting the collection of personal information
We limit the amount of personal information we collect to what is necessary and appropriate for the fulfillment of the purposes for which it is collected.
When collecting personal information, we make every reasonable effort to ensure that information about existing and prospective customers in customer files is accurate and updated or corrected as necessary. From time to time, customers and staff may be asked to update their personal information.
We also take steps to ensure that the information collected is used for the purposes specified and not for other purposes, and that it is not disclosed to a third party without the consent of the existing or potential customer, unless otherwise required by law.
How we collect your personal information
We may collect personal information in a variety of ways, including:
- by phone
- For any request made by telephone, it is necessary to identify the person before providing any personal information.
- in person
- via our paper and online forms
What personal information do we collect?
We only collect personal information necessary to fulfill the purposes mentioned in this statement.
Here are some examples of personal information we may collect.
Personal information: Name, first name, gender, date of birth, social security number, telephone number, marital status, occupation, driver’s license number, relationships, and medical records.
Financial information: Remuneration, employer, financial statement, personal insurance portfolio, savings structure, legal aspects
Protection of personal information
Appropriate safeguards are taken with respect to the storage and destruction of personal information. All persons associated with Prosphère, or its employment, are required to comply with procedures to this effect.
Prosphère uses a combination of technological, physical and organizational safeguards to protect personal information against theft and misuse, as well as against unauthorized access, disclosure, reproduction, use or modification.
Encryption software, antivirus software and firewalls are installed and kept up to date on all technology tools used in a business context to ensure data security. This includes encrypting sensitive data when stored or transmitted, including when transmitted to backup servers.
The protection measures of these technological tools are periodically reviewed and upgraded when necessary.
Access to personal information and files is granted to Prosphère personnel only when required to perform certain tasks. Prosphère personnel are advised of the importance of protecting the security and confidentiality of personal information. Confidentiality and non-disclosure agreements are signed upon hiring.
Destruction of personal information
Personal information is retained only for as long as it is necessary for the identified purposes, or as required or permitted by law. We are solely responsible for the safekeeping of these documents and for protecting their confidentiality.
Personal information that is no longer required for the purposes identified at the time of collection is securely destroyed or erased.
Document retention
Customer and staff records are retained for at least the minimum period stipulated by law.
Access to personal information
Under privacy laws, customers have the right to access their personal information contained in files held by Prosphère. A request for access to your personal information or a request for information regarding the collection, use and disclosure of your personal information by Prosphère must be submitted in writing to the Privacy Officer at the following address:
Privacy Officer
50 Perreault Street East
Rouyn-Noranda (Quebec) J9X 3C2
Email : nathalie.gagnon@prosphere.ca
Third Party Service Providers
Prosphère must obtain the customer’s authorization before transferring personal information to a supplier and retain control over the information when transferring personal information to a supplier for processing.
Transfers of information to vendors for processing purposes, including cloud services, are made for a variety of reasons, including data storage and processing or handling of customer personal information.
Personal information shall not, without consent, be used or disclosed to a third party for purposes other than those for which it was collected, unless such use or disclosure is required or permitted by law.
Training program
All Prosphère staff members receive training in the protection of personal information. This training is mandatory and must be completed before access to personal information is granted.
Training is an ongoing process and refresher training is provided regarding changes in laws, technology, service providers, new access to or uses of personal information.
Roles and responsibilities of staff members
Where applicable, each Prosphère staff member ensures that personal information is collected, stored, used and destroyed according to best practices. When a probable, apprehended or proven confidentiality incident is brought to the attention of a member of the organization, the latter will contact the person responsible for the protection of personal information. Prosphère ensures that personal information is accessible to a member of its organization’s staff only if it is necessary for the performance of his or her duties.
Incidents and incident log
Prosphère must keep a record of confidentiality incidents in accordance with the Private Sector Act and its regulations. When Prosphère has reason to believe that a confidentiality incident has occurred involving one or more pieces of personal information that it holds, it must then take reasonable measures to reduce the risk of harm being caused and prevent new incidents of the same nature from occurring. Where applicable, if the incident presents a risk of serious harm, it must then notify the Commission d’accès à l’information du Québec and the person concerned in accordance with the Private Sector Act and its regulations. The assessment of the risk of harm is done in consultation with the person responsible for the protection of personal information and considers the sensitivity of the information concerned, the anticipated consequences of its use and the likelihood that it will be used for harmful purposes.
Complaint handling process
The person responsible for the protection of personal information receives complaints relating to the protection of personal information. When such a complaint is filed, the person responsible for the protection of personal information acknowledges receipt of the complaint to the person concerned, takes note of its content, investigates the circumstances and responds in writing in a diligent manner. If necessary, he or she may make recommendations to Prosphère to improve the protection of personal information.
Changes to the Compliance Policy
Privacy laws are evolving; therefore, this policy may be amended by Prosphère, in its sole discretion, without notice and without liability to you or any other person. Prosphère’s collection, use and disclosure of your personal information is governed by the current version of this policy.
Privacy Officer
We have appointed two (2) co-privacy officers who oversee the protection of privacy and personal information on behalf of Prosphère Inc. and its subsidiaries. We have also informed our staff of the existence of our Privacy Statement, as well as the role that each must play in ensuring the protection of the personal information of our customers and staff. If you have any questions regarding our privacy practices, do not hesitate to contact the privacy officers:
Nathalie Gagnon
50 Perreault Street East
Rouyn-Noranda (Quebec)
J9X 3C2
nathalie.gagnon@prosphere.ca
Jonathan Bolduc
50 Perreault Street East
Rouyn-Noranda (Quebec)
J9X 3C2
jonathan.bolduc @prosphere.ca