Management of personal and confidential information

This Policy sets out measures and practices that CAE Memphrémagog has put in place to protect and ensure governance oversight pertaining to personal information.  

 This Policy aims mainly to inform you about : 

• The means used to collect personal information;
• The nature of the personal information collected and the purposes for which it is used;
• How CAE Memphrémagog can use personal information, and how this information can be used by any third party with whom CAE Memphrémagog may disclose personal information, if applicable;
• The various security measures put in place to protect the confidentiality of personal information; and
• The rights to which you are entitled in relation to personal information collected by CAE Memphrémagog, including the right to access your personal information or request a correction if the personal information is inaccurate. 

 By transmitting one or more items of personal information to CAE Memphrémagog through direct or indirect contact with an authorized representative or through your use of the website, you expressly consent to having CAE Memphrémagog collect, use, disclose and retain this personal information in accordance with the terms and conditions set out in this Policy.  

Information is collected in several ways : 

• Automatically when you log in to the website;  
• Automatically through the use of cookies or pixels on the website;  
• By email; 
• By telephone; 
• Via personal information shared through postal mail;
• Via personal information shared in person;  
• Via paper forms completed at meetings;
• Via forms completed on the CAE Memphrémagog website; 
  
  

Or by any other means required to securely collect data. 

The following personal information may be collected : 

• Family name and given name; 
• Postal address or email address; 
• Personal telephone number; 
• Credit card number; 
• Social insurance number; 
• Name of banking institution; 
• Personal balance sheet; 
• Credit record; 
• Resume;
• Insurance policy; 
• Date of birth; 

Or any other personal information required to review an application for assistance or financing. 

Personal information is collected for the following purposes : 

• To communicate with prospective clients and tailor communications with them;
• To advertise to clients or prospective clients;
• To respond to requests from clients or visitors to the website;  
• To assess client needs and interests;
• To ensure that visitors can log in to the website; 
• To ensure the proper function of the website; 
• To improve the website’s performance and effectiveness in retaining visitors; 
• To identify the legislative regime applicable to personal information on website visitors; 
• To advertise to clients, visitors or prospective clients;
• To ensure compliance with a law, court order or legal proceeding;
• To ensure the legal protection of the Organization; 
• To evaluate and improve protection and security measures;  
• To prevent and detect fraud; and
• To respond to complaints and to requests for access, corrections, or withdrawal of consent; 

Or for any other purposes required for proper file management. 

In compliance with our procedures applicable to the retention and destruction of personal information, we retain your personal information only for the period required to fulfil the purposes listed in the previous section of this Policy or for the period required to meet our statutory obligations, whichever comes later.  

The personal information collected is destroyed as soon as the purposes for which it was collected have been fulfilled, unless, of course, a law or regulation requires CAE Memphrémagog to retain it or a law or regulation calls for a specific retention period. 

CAE Memphrémagog discloses personal information to : 

• Its employees if they require access to it in the performance of their duties;
• Any other person or entity, when disclosure is prescribed or permitted under the applicable legislation without the consent of the person concerned, or with the consent of the person concerned; 
• Business partners, when the company, organization or contractor gives their approval by signing the required documents; 
• External consultants with whom CAE Memphrémagog has entered into a contractual agreement under whose terms the external consultant cannot use the personal information for purposes other than the provision of the said service and must destroy the personal information disclosed by no later than the end of the contractual agreement. 

 CAE Memphrémagog does not sell personal information to third parties and does not allow third parties to access personal information unless granting access to that information is required to meet one of the purposes cited above and the access or disclosure without the consent of the persons concerned is authorized or prescribed under a law or regulation. 

If you continue to use the CAE Memphrémagog website, transmit personal information to an authorized representative of CAE Memphrémagog, or disclose personal information by completing a form provided by CAE Memphrémagog, you will be deemed to consent to the disclosure of personal information for the purposes cited above and below. 

CAE Memphrémagog takes adequate physical, technological, contractual and administrative measures to protect your personal information and reduce the risks of unauthorized access, use, disclosure, and destruction.    

Without limiting the generality of the foregoing, the website features certain security mechanisms aimed at protecting your personal information: 

• Personal information collected on the website is encrypted at rest;
• All personal information transferred between the different components of the website is encrypted; and
• Suppliers of computing services for CAE Memphrémagog are contractually bound to comply with various security obligations, which entail, in particular, a periodic validation of security practices and processes as well as continuous monitoring and updating of the website’s software components. 

By default, all the confidentiality parameters applied to your use of the website offer the highest level of confidentiality, with no action required on your part.   

In addition to these measures, CAE Memphrémagog also provides: 

• An internal access management policy for its employees; 
• Under this policy, only employees who require access to personal information in the performance of their duties may access the said information; 
• An internal information protection policy to which employees are subject in order to ensure the integrity, availability and confidentiality of personal information; 
• A registry of confidentiality incidents, minor or major, that result in your personal information being compromised , in order to identify the measures required to prevent such incidents from reoccurring;
• A personal information retention schedule to ensure that the personal information is destroyed when it is no longer required for the aforementioned purposes and when its retention is no longer required under law; 
• A response plan for confidentiality incidents, which makes it possible to respond in an effective and timely manner in the event that your personal information is compromised;   
• An access log specific to your personal information; and
• Annual training activities offered to our staff members.  

In spite of these measures, it remains impossible for CAE Memphrémagog to guarantee the security of the personal information it receives.  

If you suspect that your personal information retained by CAE Memphrémagog has been compromised, please contact our Privacy Officer at the following email address: info@caememphrémagog.ca 

CAE Memphrémagog keeps an updated registry of confidentiality incidents, in compliance with the applicable legislation. If your personal information is compromised, entailing a risk of serious harm, CAE Memphrémagog will take the necessary measures to notify you thereof, in compliance with the applicable legislation.  

It will also apply measures to limit the harm that may result from your personal information being compromised and the chances of such an incident reoccurring.

You or a person authorized under the Act respecting the protection of personal information in the private sector may submit a request for access to your personal information by directly contacting our Privacy Officer. To do so, complete the access request form and send it to the following address: info@caememphrémagog.ca   

The Privacy Officer will grant this access, except if: 

• The Law prohibits CAE Memphrémagog from providing access; 
• CAE Memphrémagog has a serious and legitimate interest in denying access; or
• Providing the access poses a risk of serious harm to a third party.   

In principle, exercising the right to access is free of charge. However, reasonable fees may be required from the applicant in order to offset the costs of transcribing, reproducing or transmitting the personal information. In such cases, the applicant will be notified of the fee amount in question before their application is processed.  

We ask that you notify us of any changes that may affect the authenticity or accuracy of your personal information.  

You or a person authorized under the Act respecting the protection of personal information in the private sector may also submit a request to correct your personal information.  

Such a request will allow you to correct the personal information in our possession if: 

• The personal information is inaccurate;
• The personal information is outdated; 
• The personal information is ambiguous;
• The personal information is incomplete; or
• The personal information has been wrongfully collected. 

Alternatively, you may submit a written request for correction, asking the Privacy Officer to destroy the outdated personal information or the personal information wrongfully collected or retained.  

To do so, fill out the correction form and send it to the following email address: info@caememphrémagog.ca 

Any request for destruction or correction must be made in writing to our Privacy Officer by completing the correction form and sending it to the following address: info@caememphremagog.ca

Subject to your contractual commitments to CAE Memphrémagog and the applicable legislation, the Act respecting the protection of personal information in the private sector (if it applies to you) lets you withdraw your consent to certain uses or disclosures of personal information.  

Please note that the exercise of this right can affect services that you receive from CAE Memphrémagog. If you submit such a request, CAE Memphrémagog will identify and explain the consequences of the withdrawal of consent in relation to its services.   

Any request for access or correction must be made in writing by filling out the consent withdrawal form and sending it to the following email address: info@caememphrémagog.ca    

The request must be sufficiently detailed to allow the Privacy Officer to evaluate and find the personal information cited in the request. Above all, the applicant must ensure that the Privacy Officer can reach them for purposes of providing assistance in clarifying the request, facilitating the identification of the personal information sought under the request, and most importantly, letting the applicant know whether the request has been approved or denied, if applicable.    

The Privacy Officer has a duty to process these requests within 30 days. If the request is not processed within this period, it will be deemed to have been denied.  

You may file a complaint concerning our methods, practices and policies pertaining to the protection or governance of personal information by directly contacting our Privacy Officer. To do so, fill out the complaint form and send it to the following email address: info@caememphrémagog.ca    

The Privacy Officer will respond to the complaint within 30 days of its receipt.  

If the complaint is accepted, you will receive a brief summary of the changes made to our methods, practices and policies pertaining to the protection or governance of personal information.