Personal Information Protection Policy and Privacy Policy
Personal Information Protection Policy and Privacy Policy
1. Context
Complexe funéraire Lachance inc. is a company incorporated in Quebec that processes personal information as part of its activities, particularly when providing funeral services and managing its customer communications.
This policy aims to ensure the protection of personal information and to govern how Complexe funéraire Lachance inc. collects, uses, discloses, retains, and destroys it, or otherwise
manages it. It also aims to inform any interested party about how Complexe funéraire Lachance inc. processes their personal information, including when collected through technological means. 2. Application and Definitions
This policy applies to Complexe funéraire Lachance inc., which includes its officers, employees, consultants, volunteers, as well as any person providing services on behalf of Complexe funéraire Lachance inc. It also applies to the Complexe funéraire Lachance inc. website and all websites controlled and maintained by Complexe funéraire Lachance inc.
It covers all types of personal information managed by Complexe funéraire Lachance inc., whether it be the information of its clients (potential or current), consultants, employees, partners, or any other person (for example, visitors to its websites).
2.1 Personal Information
A personal information is information that relates to a natural person and allows, directly or indirectly, to identify them. For example: name, address, email address, phone number, gender, banking information, health information, ethnic origin, language, etc.
2.2 Sensitive Personal Information
A sensitive personal information is information for which there is a high degree of reasonable expectation of privacy, for example: health information, banking information, biometric information, sexual orientation, ethnic origin, political opinions, religious or philosophical beliefs, etc.
2.3 Professional Contact Information
Generally, a person’s professional or business contact information does not constitute personal information, for example: name, title, address, email address, or work phone number.
Within the meaning of Quebec’s Act respecting the protection of personal information in the private sector, and as of September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to a person’s information relating to the exercise of a function within an enterprise, such as their name, title, function, as well as the address, email address, and phone number of their workplace.
These same paragraphs also do not apply to personal information that is public by law, effective upon the entry into force of this policy.
3. Collection, Use, and Disclosure
As part of its activities, Complexe funéraire Lachance inc. may collect different types of information, for various purposes. The types of information that Complexe funéraire Lachance inc. may collect, their use (or intended purpose), and the means by which they are gathered are indicated in Appendix A of this policy.
Complexe funéraire Lachance inc. will also inform the individuals concerned, at the time of personal information collection, of the types of information gathered, the purposes for which they are collected, and the means of collection, in addition to other information required by law.
3.1 Consent
- Generally, Complexe funéraire Lachance inc. collects personal information directly from the individual concerned and with their consent, unless an exception is provided by law. Consent may be implicit, for example, when the individual provides their information after being informed, through this policy, of the purposes for which it will be used and disclosed (see Appendix A for more details).
- Normally, Complexe funéraire Lachance inc. must also obtain the consent of the individual concerned before collecting their personal information from third parties, before disclosing it to third parties, or for any secondary use. However, Complexe funéraire Lachance inc. may act without consent in certain cases provided by law and under the conditions stipulated therein.
3.2 Collection
- Complexe funéraire Lachance inc. collects information only if it has a valid reason to do so. The collection is limited to the information necessary to achieve the intended purpose.
- The services and programs of Complexe funéraire Lachance inc. are not aimed at minors. Generally, Complexe funéraire Lachance inc. does not intentionally obtain personal information concerning minors without the consent of a parent or guardian.
- Collection from third parties. Complexe funéraire Lachance inc. may collect personal information from third parties. Unless an exception is provided by law, the consent of the individual concerned will be obtained before collecting information about them from a third party. The individual may request the source of the information collected from Complexe funéraire Lachance inc.
In certain situations, Complexe funéraire Lachance inc. may also collect personal information from third parties, without the consent of the individual concerned, if it has a serious and legitimate interest in doing so and: a) if the collection is in the individual’s interest and it is not possible to do so from them in a timely manner; or b) if this collection is necessary to ensure the accuracy of the information.
Complexe funéraire Lachance inc. may also collect personal information indirectly, particularly through technology providers or partners:
- Clover – Clover has its own terms and privacy policy.
- Global Payments – Global Payments has its own terms and privacy policy.
- Stripe – Stripe has its own privacy policy.
This collection through third parties may be necessary to use certain services or programs, or to do business with Complexe funéraire Lachance inc. When required, Complexe funéraire Lachance inc. will obtain the individual’s consent at the appropriate time.
3.3 Retention and Use
- Complexe funéraire Lachance inc. ensures that the information it holds is up-to-date and accurate at the time of its use to make a decision concerning the individual in question.
- Complexe funéraire Lachance inc. uses personal information only for the reasons indicated in this policy or at the time of collection. Any use for a new purpose requires new consent, which must be explicit when sensitive personal information is involved. In certain cases provided by law, Complexe funéraire Lachance inc. may, however, use the information for secondary purposes without consent (for example: clear benefit to the individual, fraud prevention or detection, improvement of security measures).
- Limited Access. Complexe funéraire Lachance inc. implements measures to limit access to personal information to only those authorized employees or individuals for whom such information is necessary in the performance of their duties.
3.4 Disclosure
- Generally, Complexe funéraire Lachance inc. obtains the individual’s consent before disclosing their personal information to a third party, except for exceptions provided by law or this policy. When consent is required for sensitive personal information, it must be explicit.
- Personal information may, however, be disclosed without consent in certain cases, particularly to a public body in the exercise of its functions or to service providers when this is necessary for the performance of their mandate (for example, subcontractors, cloud providers, event organizers). In these cases, written agreements stipulate the responsibilities of these providers regarding confidentiality and security.
- Personal information may also be disclosed in the context of a commercial transaction, subject to the conditions provided by law.
- Disclosure outside Quebec. It is possible that certain personal information may be disclosed outside Quebec, for example when Complexe funéraire Lachance inc. uses cloud service providers whose servers are located outside Quebec.
3.5 Additional Information on Technologies Used
Use of Cookies
Websites controlled by Complexe funéraire Lachance inc. use cookies to:
- remember visitors’ settings and preferences (e.g., language choice, current session);
- generate usage statistics and improve the sites.
The cookies used include session cookies (temporary) and persistent cookies (retained until their expiration). Some optional cookies may be disabled by default and activated by the visitor.
It is possible to disable cookies in your browser settings. For more information, you can consult your browser’s help resources or Google’s documentation on cookies.
Use of Google Analytics
Websites under the control of Complexe funéraire Lachance inc. use Google Analytics to analyze site usage and improve its content. Google Analytics uses cookies to generate statistical reports on visitor behavior.
Information from Google Analytics is never shared by Complexe funéraire Lachance inc. with third parties. It is possible to install a browser add-on to disable Google Analytics .
Other Technological Means Used
Complexe funéraire Lachance inc. also collects personal information through web forms (for example: contact form, newsletter subscription forms, etc.), online questionnaires, applications, or other tools like Microsoft Forms.
When technological products or services are used, Complexe funéraire Lachance inc. ensures, when required, that privacy settings offer the highest level of protection by default.
4. Retention and Destruction of Personal Information
Unless a minimum retention period is required by law or applicable regulations, Complexe funéraire Lachance inc. will retain personal information only for the duration necessary to fulfill the purposes for which it was collected.
Information used to make a decision concerning an individual must be retained for at least one year following the decision, or up to seven years after the end of the fiscal year when the decision has tax implications (for example, circumstances of employment termination).
At the end of the retention period or when the information is no longer necessary, Complexe funéraire Lachance inc. will ensure:
- to destroy it securely; or
- to anonymize it (irreversibly) for serious and legitimate purposes.
This section may be supplemented by any internal policy or procedure of Complexe funéraire Lachance inc. regarding the retention and destruction of personal information. For more information, it is possible to contact the personal information protection officer indicated in section 9.
5. Responsibilities of Complexe funéraire Lachance inc.
Generally, Complexe funéraire Lachance inc. is responsible for the protection of personal information it holds.
The personal information protection officer of Complexe funéraire Lachance inc. is the president of the organization. They ensure compliance with applicable legislation, approve policies and practices regarding personal information governance, and oversee the implementation of this policy.
In the event of the absence or inability to act of this officer, the president assumes the duties of the personal information protection officer.
Staff members with access to personal information or involved in its management must ensure its protection and comply with this policy, as well as any other relevant internal policy.
6. Data Security
Complexe funéraire Lachance inc. commits to implementing reasonable security measures to ensure the protection of the personal information it manages. Security measures take into account, in particular, the purpose, quantity, distribution, medium, and sensitivity of the information.
Personal information qualified as sensitive, within the meaning of section 2 of this policy, is subject to more significant security measures.
Complexe funéraire Lachance inc. must, in particular, impose access restrictions in its information systems, so that only authorized employees who require it in the performance of their duties can access personal information.
7. Rights of Access, Rectification, and Withdrawal of Consent
To assert their rights of access, rectification, or withdrawal of consent, concerned individuals must submit a written request to the personal information protection officer of Complexe funéraire Lachance inc., at the email address indicated in section 9.
Subject to certain legal restrictions, individuals may request access to their personal information held by Complexe funéraire Lachance inc. and request its correction when it is inaccurate, incomplete, or ambiguous. They may also demand the cessation of the dissemination of personal information concerning them or the de-indexing of a hyperlink associated with their name when the dissemination violates the law or a court order.
The officer in charge must respond in writing within 30 days of receiving the request. Any refusal must be justified and indicate the remedies provided by law and the applicable deadlines.
Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the disclosure or use of their personal information.
They may also ask Complexe funéraire Lachance inc. what personal information is collected from them, which categories of individuals within the organization have access to it, and what its retention period is.
8. Complaint Handling Process
8.1 Receipt
Any person wishing to file a complaint regarding the application of this policy or, more generally, the protection of their personal information by Complexe funéraire Lachance inc., must do so in writing by contacting the Personal Information Protection Officer at the email address indicated in section 9.
The complaint must include the complainant’s name, contact information (including a phone number), as well as the subject and reasons for the complaint with sufficient detail to allow for its analysis. Additional information may be requested if necessary.
8.2 Processing
Complexe funéraire Lachance inc. commits to handling all complaints confidentially.
Within 30 days of receiving the complaint or any additional information deemed necessary, the officer evaluates the complaint and provides a written and reasoned response to the complainant, indicating whether the processing of personal information complies with the policy and applicable legislation.
If the complaint cannot be processed within this timeframe, the complainant will be informed of the reasons for the additional delay, the progress of the processing, and the reasonable time required.
Complexe funéraire Lachance inc. maintains a separate file for each complaint, including the complaint, analysis, supporting documentation, and written response.
It is also possible to file a complaint with the Commission d’accès à l’information du Québec or any other competent body for the protection of personal information. However, Complexe funéraire Lachance inc. invites all individuals to first contact its Personal Information Protection Officer.
9. Approval and Officer in Charge
This policy is approved by the Personal Information Protection Officer of Complexe funéraire Lachance inc., whose business contact details are as follows:
Personal Information Protection Officer:
Denis Lachance
President
152, rue du Curé-Rondeau,
Notre-Dame-des-Prairies (Quebec) J6E 1G8For any request, question, or comment regarding this policy, please contact the officer by email at: info@cflachance.ca, or by using the contact form.
10. Publication and Amendments
This policy is published on the website of Complexe funéraire Lachance inc., as well as on all websites controlled and maintained by Complexe funéraire Lachance inc. to which it applies, regarding the personal information collected therein. It may also be disseminated by any other means deemed appropriate to reach the individuals concerned.
Complexe funéraire Lachance inc. reserves the right to amend this policy at any time. Any amendment will be updated on the website and, if necessary, a notice will be issued to inform the individuals concerned.
Note: The use of the masculine gender is intended to simplify this policy and make it easier to read.
Version and Change Log
Version Effective Date Changes from Last Version 1.0 August 23, 2023 N/A – First Version 2.0
Appendix A – Types of Personal Information, Uses, and Collection Methods
Below is a non-exhaustive list of the types of information that Complexe funéraire Lachance inc. may collect, their uses (or purposes of collection), and the methods by which they are gathered. Most personal information managed by Complexe funéraire Lachance inc. concerns clients, deceased individuals, employees, job applicants, consultants, suppliers, and partners.
| Relationship with Complexe funéraire Lachance inc., services, program, etc. | Type of Personal Information | Purposes of Collection / Uses | Method of Information Collection (Means) |
|---|---|---|---|
| Clients and Deceased Individuals | Any of the following information, when necessary: name, address, phone number, email, banking information, sex, date of birth, certain health issues, weight, place of birth, place of birth registration, parents’ names, place of death, date of death, marital status, information about the spouse, marriage information, declarant information, information about participation or registration in various public schemes, social insurance number. |
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| Job Applicants and Employees | name, phone number, email, banking information, social insurance number, date of birth, address. |
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| Consultants | name, phone number, email, banking information, address. |
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| Service Providers | name, phone number, email, banking information, language. |
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| Network and Partners (Ecosystem Stakeholders) | name, phone number, email, banking details (when necessary), language. |
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