Privacy policy
Governance policies and practices with respect to personal information
FONTAINEBLEAU IMMOBILIER INC. is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (the Act).
Personal information
Personal information is information about a natural person that allows, directly or indirectly, that person to be identified. Writing, images, videos and sound recordings can all contain personal information. In the course of its professional activities, the AGENCY may collect personal information such as a person's name, home address, date of birth, identification information and, if applicable, social insurance number, income information, marital status, etc. The AGENCY is not responsible for the accuracy or completeness of this information.
Consent
L'AGENCE collects, uses and communicates personal information with the consent of the person concerned. To be valid, consent must be manifest, free, informed and given for specific purposes. A person who consents to provide personal information is presumed to consent to its use and communication for the purposes for which it was collected.
Any person may withdraw his or her consent to the collection, use and disclosure of his or her personal information by the AGENCY at any time. In this case, if the collection is necessary for the conclusion or performance of the contract by the AGENCY, the AGENCY may not be able to fulfill a request for service.
Responsibility
L'AGENCE is responsible for protecting the personal information it holds in the course of its real estate brokerage activities. To this end, the AGENCY has adopted the Privacy Policy, as well as policies and practices governing the governance of personal information, the purpose of which is to provide a framework for the collection, use, communication, retention and destruction of personal information.
Collection of personal information
L'AGENCE collects only the personal information required to carry out its real estate brokerage activities. For example, information may be collected for the purposes of carrying out a real estate transaction, maintaining files, monitoring professional practice by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ) or any other purpose determined by the AGENCY and made known to the person whose consent is being sought.
The AGENCY invites its employees to explain the reasons for the collection of personal information to the person concerned in clear and simple terms, and to ensure that the person understands.
For the purposes of collecting personal information, the AGENCY encourages its brokers and staff members to use the standardized forms developed by the OACIQ.
L'AGENCE may also collect personal information verbally during correspondence with persons involved in a transaction or through various documents submitted as part of a real estate transaction (identification, financial documents, powers of attorney, etc.).
Use and communication of personal information
Personal information is used and disclosed for the purposes for which it was collected and with the consent of the person concerned. In certain cases provided for by law, personal information may be used for other purposes.
may be used for other purposes, for example, to detect and prevent fraud or to provide a service to the person concerned.
AGENCY may be required to disclose personal information to third parties, for example, suppliers, contractors, subcontractors, agents, insurers (such as the Fonds d'assurance responsabilité professionnelle du courtage immobilier du Québec [FARCIQ]), professionals, other regulators, or outside Québec.
The AGENCY may, without the consent of the person concerned, communicate personal information to a third party if such communication is necessary for the execution of a mandate or a service or business contract. In this case, the AGENCY will draw up a written mandate or contract in which it will indicate the measures that its agent must take to ensure the protection of the personal information entrusted to it, to ensure that it is used only in the performance of the mandate or contract, and that it is destroyed once the mandate or contract has ended. The co-contractor must also undertake to cooperate with the AGENCY in the event of a breach of confidentiality of personal information.
Before disclosing personal information outside Québec, the AGENCY takes into account the sensitivity of the information, the purpose for which it will be used and the safeguards that will be in place outside Québec. The AGENCY will only disclose personal information outside Québec if its analysis demonstrates that it will benefit from adequate protection in the place where it is to be disclosed.
Retention and destruction of personal information
Once the purposes for which the personal information was collected or used have been fulfilled, the AGENCY must destroy it, subject to the retention period stipulated in the Act. In this regard, AGENCY's professional obligations require it to retain its files for at least six (6) years following their final closing.
Security measures
When collecting, using, storing and destroying personal information, the AGENCY applies the necessary security measures to protect the confidentiality of personal information. More specifically, the following measures apply
- Documents containing personal information are kept under lock and key;
- Only administrative staff and the broker(s) involved in the transaction have access to them;
- Files will be destroyed after the statutory retention period.
Confidentiality incident
A confidentiality incident is any access, use or disclosure of personal information that is not authorized by the Act, or the loss of personal information or any other breach in the protection of personal information.
L'AGENCE has established a confidentiality incident management protocol that identifies the persons who assist the Privacy Officer and sets out the concrete actions to be taken in the event of an incident. This protocol sets out the responsibilities expected at each stage of incident management, including the measures to be taken to ensure data security.
Roles and responsibilities
THE AGENCY:
Ensures confidentiality of information through good information management practices. In particular, it provides guidelines, training and instructions to staff members regarding the collection, use, storage, modification, consultation, communication and permitted destruction of personal information.
Deploys appropriate safeguards to reduce the risk of privacy incidents, such as computer security
for example, computer security, updating personal information policies, staff training, etc.
Has standardized methods for filing documents containing personal information.
Has standardized methods for storing documents containing personal information, including digitization procedures.
Manages physical and computer access to personal information, based in particular on its sensitivity.
Securely destroys personal information. In particular, it issues directives or instructions to staff members concerning the secure destruction method, destruction deadlines, etc.
Privacy Officer
In accordance with the Act, the AGENCY has appointed a Privacy Officer.
He or she is responsible for ensuring that these policies are respected and that they comply with applicable regulations. The name and contact details of this person are listed in the "Right of access, withdrawal and rectification" section.
The Privacy Officer is responsible for managing privacy incidents and, in this context, takes action as provided for by law.
The Privacy Officer handles requests for access and rectification of personal information. He or she also handles complaints about the AGENCY's handling of personal information.
The Privacy Officer is consulted as part of a privacy impact assessment for any project involving the acquisition, development or redesign of an information system or the electronic delivery of services involving the collection, use, disclosure, retention or destruction of personal information. It may suggest measures to ensure the protection of personal information in the context of such a project.
Staff members
AGENCY employees may access personal information only insofar as this is necessary for the performance of their duties or mandate.
The AGENCY staff member :
Ensures the integrity and confidentiality of personal information held by the AGENCY.
Complies with all AGENCY policies and directives on access, collection, use, disclosure and destruction of personal information, and on information security, and complies with the instructions presented to him or her.
Respects the security measures in place at his or her workstation and on all equipment containing personal information.
Uses only equipment and software authorized by the AGENCY.
Ensures the secure destruction of personal information in accordance with instructions received. Immediately report to his/her supervisor any act of which he/she is aware that may constitute an actual or suspected breach of security rules relating to personal information.
Right of access, withdrawal and rectification
An individual (or his/her authorized representative) may request access to his/her personal information held by AGENCY. An individual may withdraw his or her consent to the collection, use and disclosure of his or her personal information at any time. This withdrawal is recorded in writing.
An individual may request correction of personal information in a file concerning him or her that he or she believes to be inaccurate, incomplete or equivocal.
The AGENCY may refuse a request for access or rectification in the cases provided for in the Act.
Complaints
An aggrieved individual may file a complaint regarding the AGENCY's handling of his or her personal information. This complaint will be handled diligently by the Privacy Officer within a maximum of 10 working days, and a written response will be sent to you.
To request access to or rectification of your personal information, or to submit a complaint regarding the processing of personal information, please contact by e-mail Jean-François Bleau, Agency Director and Privacy Officer, Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.
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