This document describes the policy for the protection of personal information as applied by ACTI-MENU, its employees and representatives.
Introduction
In its normal course of business, ACTI-MENU collects personal information about its
employees, its clients and their employees, participants in its various campaigns and its
subcontractors. All personal information collected respects the general laws and
regulations that apply to confidentiality and/or is subject to ACTI-MENU’s policy for the
protection of personal information.
ACTI-MENU is committed to ensuring the accuracy, confidentiality, security and private
nature of the personal information it collects by stringently applying its policy and
ensuring that it is respected by all of its employees and representatives.
Responsibility
The directors of business units and departments are responsible for ensuring that the
policy is respected and taking the appropriate measures to facilitate its application on a
day-to-day basis. In cases where the policy is not respected, they will take appropriate
measures to correct the situation.
Determining how information collected will be used
At the time it collects personal information, ACTI-MENU will specify in a document or
an agreement how the information will be used and will provide written notification to
the people from whom the information is being collected.
The collection of information is limited to the purposes for which it was authorized.
Otherwise, ACTI-MENU will obtain additional consent as required.
Consent
ACTI-MENU will inform and obtain consent from all persons concerned before it
collects, uses or transmits personal information, unless it is inappropriate to do so
under applicable laws.
Limits on information collected
ACTI-MENU will take measures to ensure that only information needed for the purpose
identified will be collected. The personal information will not be transmitted or used for
any other purpose other than that for which consent was obtained.
Subject to applicable laws, ACTI-MENU may keep personal information on file for as
long as necessary for pre-established purposes, even if the person is no longer an
employee, client or participant.
Accuracy
ACTI-MENU’s employees are required to inform the directors of business units or
departments of any changes to information in their file. Clients, participants and
subcontractors are also requested to provide any changes to information previously
submitted to ACTI-MENU.
ACTI-MENU will update personal information as soon as it is received from employees,
clients, participants and subcontractors, when it is relevant to do so.
Security
Personal information is protected by security measures that are commensurate with the
degree of sensitivity of the information.
Security measures protect personal information against loss or theft and against
unauthorized consultation, transmission, copying, use or modification.
The nature of the security measures will vary depending on the degree of sensitivity of
the personal information, the quantity, distribution and format of the information, as well
as how it is conserved. Various methods may be used, such as rendering the
information anonymous, restricting access, applying password protection or any other
means judged to be appropriate under the circumstances.
Transparency
This policy is distributed to all managers, administrators, employees and contributors
and to any person who requests it.
Access to personal information
ACTI-MENU will inform anyone who inquires as to the existence of personal information
how the information is used and the fact that it has been provided to third parties, and
will allow them to consult it. It will be possible to confirm the accuracy and
comprehensiveness of the information and to make corrections if required. Complaints
will be handled according to the appropriate procedures and within a reasonable
timeframe. This policy will be upgraded periodically.
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