Last update: Novembre 2nd, 2023
Maibec Inc. attaches great importance to privacy and is committed to protecting the confidentiality of personal information entrusted to us (employees, customers, members, etc.). This information may be stored by the company or by a third party.
The purpose of this document is to inform you of Maibec Inc.’s personal information practices and to explain our policies and procedures regarding the collection, use and disclosure of personal information. This policy applies to all personal information collected by Maibec Inc. regardless of the channel through which it is collected. The collection, use, disclosure and retention of your personal information are subject to the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1).
1. Personal information
Personal information includes any information that relates to a natural person and makes it possible, directly or indirectly, to identify that person.
The support of senior management is essential to the success of the privacy program and the adoption of a privacy-friendly culture. Maibec Inc. senior management promotes the privacy program and ensures that the company’s activities comply with defined policies and procedures.
At Maibec Inc. the day-to-day management of the privacy program is formally delegated to the Privacy Officer. The Privacy Officer is responsible for implementing Maibec Inc.’s commitment to earning and maintaining the trust of customers and other stakeholders in our handling of personal information. The Privacy Officer is responsible for structuring, designing and managing the program, including all procedures, training, monitoring/auditing, documentation, evaluation and follow-up.
Maibec Inc. to the
attention of the Privacy Officer
202-1984, 5e rue
Canada, G6W 5M6
3. Determining the purposes of collection
In all situations, Maibec Inc. ensures that it has a legitimate reason for collecting personal information. The purposes for which we collect your personal information are as follows:
- Maintain an employee file.
- To be able to pay our employees for the work they do.
- Provide employee benefits (insurance, pension plans, etc.).
- Identify the needs and preferences of end users.
- Comply with laws, regulations and contractual provisions
- Investigate and resolve customer and end-user incidents, complaints and disputes.
- Process our employees’ expense accounts.
- Validate criminal records of job applicants
- Establish and maintain a responsible commercial relationship with the customer and ensure ongoing service.
- Design, improve, promote or supply products and services to the customer.
- To manage and develop our business and activities, including diagnosing technical problems or improving functionality, and to maintain and improve the security of customer data.
- Provide products and services on behalf of the customer (in accordance with contractual obligations), including for billing purposes.
- Receive applications for job postings at Maibec
For these purposes, we may collect the following personal information:
With our employees (internal)
- Name, address, gender and telephone number
- Date of birth
- Social Insurance Number (SIN)
- Quebec’s health insurance plan number (in case of emergency)
- Banking information
- Civil status
- Information on spouse and dependants
- Emergency contact information
To the public (external)
- Name, address and telephone number
- Curriculum vitae (job application)
- Identity documents (job application)
We may also collect certain personal information automatically when you access our website (your IP address, device type, operating systems, browsing behaviour, information collected through cookies and, if your device’s location features are enabled, you may send us location data).
Except where permitted or required by law, Maibec Inc. will only collect your personal information for the purposes for which we have first obtained your consent. Consent will be obtained before or at the time the personal information is collected. Depending on the nature and sensitivity of the information collected and the purposes for which it is to be used, your consent may be express or implied. As a general rule, Maibec Inc. will seek express consent at the time of collection. Consent may be obtained verbally, electronically or in writing. In some situations, implied consent may be reasonably inferred from an individual’s action or inaction, for example, providing a name and address to receive a publication or a name and telephone number to obtain an answer to a question. If we want to use personal information for a new purpose, we will describe the intended use and ask for consent again.
You may at any time decide to withdraw your consent to the collection, disclosure and retention of your personal information. You may also request to have your information de-indexed, which may result in Maibec Inc. ceasing to disseminate such information or de-indexing a hyperlink to such information. Please note that if you choose to withdraw your consent or have your information de-indexed, Maibec Inc. will inform you of the consequences of this choice.
For withdrawal of consent or de-indexing, a written request to this effect must be submitted to the Privacy Officer. Maibec Inc. undertakes to respect a reasonable period of time (30 days) to cease using the information.
5. Limitation of Collection
Maibec Inc. is committed to limiting the collection of personal information to that which is necessary to establish, manage and maintain our relationship with you and for the purposes outlined above. Maibec Inc. collects personal information that you voluntarily provide in the course of your employment. This includes, but is not limited to employment contracts and forms, benefits documents, etc.
6. Restrictions on Use, Communication and Storage
Maibec Inc. undertakes to use personal information only for the purposes for which it was collected. Unless an exception is provided for by law, Maibec Inc. will obtain new consent from the person concerned to use the information for a purpose other than that for which the original consent was obtained.
Maibec Inc. will not disclose personal information to third parties without the prior consent of the individuals to whom the information relates, or if applicable law provides that it may be disclosed without consent. In certain circumstances, we cannot avoid sharing your data with other entities, for example, if you require services that Maibec does not provide directly, but rather through business partners. In such cases, the entities with which we share some of your data are required to use or disclose your data only for the performance of the services we request from them.
When required, your data may be shared with:
- entities of the Maibec group of companies;
- the service providers we use to perform services on our behalf;
- service providers who render necessary services to Maibec
Generally speaking, the personal information we collect is used and stored in Quebec. However, some of our service providers may store it outside the province (elsewhere in Canada) for the purposes of the services they provide to us. When applicable, Maibec Inc. ensures through a written agreement or a validation of good security practices that the information benefits from controls ensuring the protection of its confidential nature and that it is used and stored only for the purposes described in this policy.
We may receive your data through our partners when you purchase our products or services from them, particularly when Maibec is responsible for service performance, product delivery or product warranties. In these situations, our partners will provide us with your name, a means of contacting you (such as a telephone number or e-mail address) and information necessary for the delivery of products or the performance of services, such as a postal address or other form of geolocation information.
Maibec operates in several countries and is headquartered in Canada. Therefore, although we aim to encourage local data processing by the entity using the data, your data may be transferred to other entities within the Maibec group, including the Canadian head office. The European Commission has approved the transfer of data to Canada as it considers Canadian privacy laws to be adequate.
As our products are sometimes sold through a network of suppliers and partners, please note that these suppliers and partners have their own privacy policies and practices. Although we are meticulous in selecting our suppliers and partners, we cannot accept any responsibility for their privacy policies and practices. Therefore, we invite you to check their privacy policies before submitting data to these entities. The same applies to links we may provide to non-Maibec websites.
Maibec Inc. has a policy regarding the life cycle management of personal information. Maibec Inc. is committed to keeping your personal information only as long as necessary to fulfill the purposes for which it was collected, to comply with legal requirements and to protect our legitimate business interests. After this period, Maibec Inc. will ensure the secure destruction or anonymization of personal information in order to maintain its confidentiality and comply with its obligations under applicable laws. Certain technological constraints may hinder or even prevent the destruction or anonymization of data. In such cases, explanations will be provided.
Maibec Inc. is committed to taking all reasonably available means to ensure the accuracy of personal information in its possession. With respect to employee files, at many levels, you have access to modify your own personal information. Otherwise, if you notice any errors in your information or if you need to update it, please notify us by contacting the Privacy Officer. Maibec Inc. will then make every effort to correct or complete any personal information that you have communicated to us as being erroneous or incomplete, and undertakes to respect a reasonable period of time (30 days) to make the necessary changes.
8. Safety Measures
Maibec Inc. uses all reasonable security measures to protect personal information in its possession. We are committed to protecting personal information against loss or theft, unauthorized access, use or disclosure, alteration or destruction, through appropriate technical, administrative and organizational security measures. The level of protection afforded to personal information depends on the following elements:
- The sensitivity of personal information.
- The quantity, distribution and format of information.
- Storage method and duration.
To the extent possible, Maibec Inc. implements, maintains and monitors the following measures to better protect the integrity, availability and confidentiality of personal information entrusted to it:
- Limiting access to personal information to only those employees who need the information to perform their duties, on a need-to-know and least-privilege basis.
- Employee training on confidentiality and protection of personal information.
- Privileges of access to information only for those who need to know.
- Review employees’ security histories according to the sensitivity of the information they will be handling.
- Implementation of technological security measures such as password policies, multi-factor authentication, firewalls and intrusion detection and prevention tools, malware protection tools, and more.
- Implementation of physical security measures such as restricting access to our offices and data centres, locking document vaults, and others.
- Imposition of contractual obligations on our service providers.
Confidentiality incident management
Maibec Inc. has a Personal Data Incident Preparedness and Response Manual, which is tested and improved on an ongoing basis. This manual ensures that any privacy-threatening incident is identified quickly, then managed and resolved in a coordinated manner. The manual clearly sets out everyone’s roles and responsibilities, as well as the criteria for reporting, escalation and decision-making. Incidents are recorded in a logbook for future reference.
10. Access to Personal Information
You may at any time make a request to Maibec Inc.’s Privacy Officer if you have any questions or if you wish to access, correct or, in some cases, delete your data and if you wish to choose how we may use your data, for example, by managing the parameters concerning the way in which we communicate with you. To do so, please send a written request to the following address (firstname.lastname@example.org). Maibec Inc. undertakes to reply within 30 days of receipt of your request. In the event of a refusal on our part, we will inform you of the reasons for our refusal, subject to legal restrictions, and of the recourse available to you.
11. Possibility of Lodging a Complaint Against Non-compliance With the Principles