POLICY FOR THE PROTECTION OF PERSONAL INFORMATION
Latest Reviewed - July 2022
Createch undertakes to conduct its business in compliance with all applicable data protection laws and regulations, and in accordance with the standards of ethical behavior.
Createch is committed to protecting your privacy and your personal information. To ensure transparency, Createch adopted a “Policy for the Protection of Personal Information” regarding the personal information it collects, in compliance with the applicable regulations.
“HR” or “Human Resources”: Any department or member of a department involved in staff management, hiring, payroll, or relationships with organizations representing staff within Createch.
“Personal Information” or “Personal Data”: Any information relating to an individual, so long as the individual can be identified either (i) directly with all the information held by Createch, or (ii) indirectly with all the available information regarding that individual, and depending on the technical means.
“Person Concerned”: Individual to whom the Personal Information relates.
2. Who Is Responsible for the Protection of Personal Information?
If for any reason you believe our response was unsatisfactory, you can file a complaint with the Commission d’accès à l’information du Québec, the privacy commissioner of your province, or the Office of the Privacy Commissioner of Canada.
3. What Data Is Being Collected?
- Identification data, such as last name, first name, telephone number, email address;
- Applicant data, such as last name, first name, email address, telephone number, work experience, and any information you provide us with your application or résumé, or during interviews (skills, level of education, languages spoken, salary expectations, home address, leisure activities, etc., if you wish to apply for a position with the Createch Group);
- Business data, such as last name, first name, duties, company affiliation, whether you are a supplier or service provider for Createch.
In the context of human resource management, Personal Information we may collect include the following:
- Data on social insurance and immigration status;
- Data on business transport and travel, such as an employee’s means of transportation for reimbursement of transport costs (transit fares, vehicle operating costs, etc.);
- Data on training and career, such as résumé, degrees, training experience, work experience, cover letter, information provided by the applicant, summary of interviews, interview dates, work permit, foreign languages spoken;
- Data on professional life, such as employment contract, date of hire, employee ID number, job title;
- Financial data, such as withholding tax, salary level, posting of salary and other compensation elements, RRSP, banking account details;
- Data on video surveillance, and access control (Createch implements video surveillance, and access control systems in its premises, which result in the collection of data such as video recordings, access information, and the moment at which the data was collected);
- Any additional data that we need to collect to manage the employment relationship.
4. For What Purpose Is Your Data Being Collected?
Respond to any question, contact request, appointment request;
Develop our offerings based on services in which you may be interested, encourage you to attend our events and sign up to our blog, bearing in mind that you can, at any moment and at no expense, oppose to commercial prospecting by clicking the unsubscribe link included in each email or by contacting us via the reference information found in Section 2;
Keep our customer files up to date to constantly meet your expectations.
- Management of the employment relationship (administration of compensation, payroll, and other standard employment duties)
- Administration of HR processes, including performance and absence management, disciplinary matters, and complaints
- Security management
- Provision of computer equipment
- Compliance with the applicable regulations (obligations relating to maternity leave, work schedules, compensation, salary and benefits payable in accordance with the employment contract, annual wage increase and any other salary adjustment, etc.)
- Compilation of statistics, and conduct of surveys and research in order to generate internal and statutory reports
- Fulfilment of our responsibilities in accordance with the legislation on equality, immigration, and public safety
5. For How Long Will Your Data Be Kept?
- If cookies are being used, we determine their lifetime by following the limit established by the competent authority, i.e., thirteen (13) months.
- When we retain some of your Personal Information to comply with a legal or regulatory obligation, and for us to exercise our rights, we retain your data where necessary for the period indicated in the reference legal text (for instance, the limitation period or legal retention period).
- In the context of an application, your résumé and the information you will have entered during the hiring process will be retained during two (2) years after your last contact with Createch, unless you oppose it. Only your explicit agreement enables a longer retention period.
- The data you have entered in the contact form will be retained as long as necessary to respond to your request.
- Your employee profile and HR file will be retained by the Createch Group until the end of your employment contract, some of your Personal Information being archived for a longer period than what the law prescribes, or for the exercise or advocacy of legal rights (for instance, a limitation period during which someone could resort to court action).
6. What Are Your Rights as Person Concerned, and How to Exercise Them?
- Right of access
The right to obtain confirmation from our end about whether Personal Information about you is being processed. Where appropriate, you can access your Personal Information and obtain other information such as the end of the collection period, and the categories of Personal Data concerned.
Right to rectificationThe right to obtain rectification of inaccurate Personal Information about you.
Right to erasure (or right to oblivion)The right to obtain erasure of your Personal Information, insofar as one of the reasons justifying the exercise of this right applies.
Right to data portabilityThe right to receive your Personal Information in a structured format, commonly used and machine readable, and the right to send that information to a third party with no objection from our end.
Right to opposition
The right to be able, for example, to prohibit us from using your Personal Information for direct marketing purposes.
7. Who Can Access Your Personal Information?
Authorized individuals within Createch and, in some circumstances, our subcontractors can access your Personal Information. We make every effort to make sure the number of these individuals remains as low as possible, and we preserve the confidentiality and security of your Personal Information. Other third-party recipients, such as our trusted providers, can also receive your Personal Information.
To that extent, we only give them the information they need to provide their services, and ask them not to use your Personal Information for other purposes. We make every effort to ensure that the trusted providers with whom we conduct business preserve the confidentiality and security of your Personal Information. We also make sure that when a business relationship with a provider comes to an end, that provider deletes your Personal Data without delay.
We carefully select our trusted providers by ensuring they offer sufficient guarantees, particularly in terms of expertise, reliability, and resources, to implement the technical and organizational measures that can meet the requirements of the applicable legislation, most notably in regard to processing security. In this respect, we make sure that our trusted providers process Personal Information exclusively according to our documented instructions. We also ensure that their staff members are committed to respecting your privacy, or abide by an appropriate legal obligation in regard to confidentiality.
Internally, your Personal Information can only be accessed by the HR department, or any other department on a strict need-to-know basis. The access is strictly controlled by our data protection officer to ensure the Group’s compliance with the applicable laws.
8. Which Security Measures Have We Implemented in Regards to Your Personal Information?
Createch implemented appropriate technical and organizational measures in respect to the type of data and risk to preserve the security and confidentiality of your Personal Information, and in particular to prevent unauthorized third parties to access them.
These measures can notably include practices such as limited access by staff members of departments authorized by virtue of their duties, contractual performance guarantees in the event of recourse to external providers, privacy impact assessments, regular reviews of our privacy practices and policies, and/or physical and/or logical security measures (secured access, authentication procedures, backup copies, antivirus software, firewalls, etc.).
Cookies are small text files stored on your computer or device when you browse the internet. Cookies can be used to collect, store and share information about your online activity, and the websites and web services you use.
Our websites use the Google Analytics metric tool to collect traffic and statistical data. This data is anonymized to comply with the current regulations for the protection of Personal Information.
You can set up cookies directly from your browser, and either choose the systematic refusal of cookies, or their authorization on a case-by-case basis.
10. Links to Third-Party Sites - Social Networks
The Createch website may contain links to social networking platforms managed by individuals or organizations on which Createch has no control.
We invite you to review the applicable policy in regard to the protection of Personal Information on each third-party website you access through our website in order to assess how your Personal Information will be used.