Privacy Policy
(hereinafter the “Policy”)
In sum:
The SADC de la Haute-Côte-Nord (hereinafter the “SADC”) collects personal data when you interact with an authorized SADC representative and through our website https://www.sadchcn.com (hereinafter the “website”).
Said personal data is collected in several ways:
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Automatically when you access the website
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Automatically through cookies and pixels on the website
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Through emails
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Through telephone calls
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Electronically through online meetings and job interviews
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When you fill out financing application forms
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When you share personal information in the mail
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In person
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When you apply for a position at the SADC
Why do you collect personal information?
Personal information is collected for the following purposes:
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To communicate with job candidates and potential clients, and to ensure said communications are personalized
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To analyze financing applications
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To ensure financing projects are properly monitored
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To register clients for SADC activities
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To advertise to clients and job candidates
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To examine job applications
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To satisfy the needs of our clients, candidates and website users
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To examine the needs and interests of clients
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To ensure website users can access the website
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To ensure the website is working properly
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To assess the efficiency of the SADC’s efforts to acquire website users, clients and candidates
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To improve website performance and user retention
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To identify the legislative framework to which the personal information of website users is subject
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To advertise to clients and job candidates
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To ensure compliance with law, court order or legal proceedings
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To ensure the legal protection of the SADC
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To assess and improve protection and security measures
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To prevent and detect fraud
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To satisfy complaints, access and redress requests, and revoking of consent
How is my personal information shared?
The SADC shares personal information:
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With its employees who need to access the information to carry out their functions
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To any other person or entity when required or permitted by applicable law with or without the person’s consent
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To third party service providers with whom the SADC has a contractual agreement in which the third party service provider cannot use the personal information for any other purpose than in the provision of said service and must destroy the personal information shared with them when the contractual agreement is terminated
Consent
If you continue to use the SADC’s website, share your personal information with an authorized SADC representative or with the SADC by filling out an SADC-provided form, you are giving your consent to the collection and sharing of your personal information as explained above.
You must consent to the collection, use and sharing of your personal information before using the SADC’s website. Please familiarize yourself with the document below to identify when and how your personal information will be collected.
This policy outlines the measures and practices employed by the SADC (hereinafter the “SADC”) to provide a framework for its governance of and to protect your personal information. The SADC collects the personal information of its clients, website users and job candidates (hereinafter “you” or “your”). The SADC collects your personal information through (i) direct and indirect contact with an authorized SADC representative, and (ii) the website (https://www.sadchcn.com) for the purposes outlined in section 1.
In this policy, the expression “personal information” refers to any information collected by the SADC that, taken alone or in conjunction with other information, directly or indirectly identifies the person in question.
This policy intends to inform you about:
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The ways the SADC collects personal information
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The nature of the personal information collected by the SADC and the purposes for the collection of said information
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The way in which the SADC may use the personal information and the third parties with whom the SADC may share said personal information
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The security measures established by the SADC to protect the confidential nature of your personal information
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The rights you hold regarding your personal information, in particular the right to access your personal information and to request to correct your personal information
When you transmit personal information to the SADC through (i) direct or indirect contact with an authorized SADC representative, or (ii) by using the website, you are giving your express consent that the SADC collects, uses, shares and stores your personal information in accordance with the terms and conditions of this policy.
This policy and any amended version hereof is subject to legislation applicable in the province of Quebec, Canada.
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When, how and why does the SADC collect personal information?
The SADC collects personal information in the following two circumstances: (i) when you voluntarily give personal information to an authorized SADC representative and (ii) when you use the website.
(i) Voluntarily sharing your personal information with an authorized SADC representative
How is my personal information collected?
You may voluntarily share your personal information with an authorized SADC representative in several ways:
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When you answer questions from an SADC officer when communicating by telephone, in person, by mail or through emails
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When you provide personal information to an SADC officer by telephone, in person, by mail or through emails
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When you provide information to an SADC officer electronically, by telephone or in person during a job interview
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When you voluntarily fill out a financing application form (hereinafter “application form”)
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When you apply for a job (hereinafter “job application”) with the SADC
What personal information does the SADC collect through its authorized representatives?
In the aforementioned circumstances, the SADC may collect the following personal information:
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Your first and last names, preferred language and some of your contact information (telephone number, email address, etc.)
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For financing applications:
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Your date of birth to check your eligibility for certain packages
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Your social insurance number to carry out a credit check
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Your personal finance statement to evaluate risk
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Information about your business project
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For job applications:
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Information regarding your level of education or training (year of graduation, information about your primary, secondary, college and university studies)
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Criminal record
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Position applied for (full time, part time, student job)
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Previous work experience
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Personal information shared on your resume which we need to assess your application
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Whether you own a car and have a driver’s license
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Financial information when required to carry out a transaction
In all cases, the SADC authorized representative will let you know about the required personal information before collection.
How do SADC officers use my personal information?
SADC officers use the collected personal information in several ways:
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To communicate with job candidates and potential clients, and to ensure said communications are personalized
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To analyze financing applications
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To ensure financing projects are properly monitored
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To register clients for SADC activities
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To advertise to clients and job candidates
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To examine job applications
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To respond to your requests
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To assess your needs and interests
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To ensure compliance with law, court order or legal proceedings
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To ensure the legal protection of the SADC
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To assess and improve protection and security measures
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To prevent and detect fraud and other illegal acts
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To satisfy complaints, access and correction requests, and revoking of consent
(ii) Collecting personal information through the website
How is my personal information collected?
When you use our website, personal information is collected in several ways:
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Automatically, when you access the website (your computer and the website’s server automatically exchange personal information)
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Automatically, through temporary cookies and pixels
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Automatically, through our logging process
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Through your email communications (if you send us personal information over email)
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Through the information you submit in forms on our website
What personal information does the SADC collect?
The SADC may collect the following personal information:
A) Information automatically collected:
When you use our website, some personal information is automatically collected:
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The domain name of your internet service provider
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Your IP address
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Your browser (Explorer, Firefox, etc.)
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Your operating system (Windows, macOS, etc.)
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The date and time you access the website
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The pages you consult
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The address of the referring website (if you have come to the website by following a link on another site)
B) Information collected relating to financing applications:
When you fill out a financing application form on the website, you need to share certain information:
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Your first and last names, preferred language and some of your contact information (telephone number, email address, etc.)
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Your date of birth to check your eligibility for certain packages
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Your social insurance number to carry out a credit check
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Information about your business project
C) Other information collected:
When you communicate with us via email, whether you’re making a request or chatting with us directly, you may share other personal information, which will vary depending on the nature of our conversation.
Please note that any personal information included in these types of conversations with the SADC is collected.
Finally, to fulfil any request to access, rectify or revoke your consent, in accordance with the terms of section 7 herein, you will need to prove your identity by showing us a piece of valid photo ID. All other personal information on said piece of ID, with the exception of your name and photo, can be hidden.
Why does the SADC collect personal information?
The SADC collects personal information for the following purposes:
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To ensure website users can access the website
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To ensure the website is working properly
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To assess the efficiency of the SADC’s efforts to acquire website users, clients and candidates
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To improve website performance and user retention
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To identify the legislative framework to which the personal information of website users is subject
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To communicate with job candidates and potential clients, and to ensure said communications are personalized
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To advertise to clients and job candidates
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To examine the needs and interests of clients
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To assess your job application
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To ensure compliance with law, court order or legal proceedings
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To ensure the legal protection of the SADC in the event of a dispute caused by your action or inaction, or in the event of a dispute between you and the SADC
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To assess and improve protection and security measures
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To prevent and detect fraud
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To satisfy complaints, access and correction requests, and revoking of consent
Links to third-party websites
The website may propose links to third-party websites. When accessing these sites, your personal information will no longer be subject to this privacy policy, but rather the privacy policy of said third-party site.
2. With whom may the SADC share my personal information?
In general, the SADC will only use your personal information internally.
However, the SADC may have to share, transmit or give the following people or entities access to your personal information:
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Its employees who need to access the information to carry out their functions
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Any other person or entity, when required or permitted by applicable law
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Any other person or entity with whom you consent to sharing said information
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To third party service providers with whom the SADC has a contractual agreement in which the third party service provider cannot use the personal information for any other purposes other than in the provision of said service and must destroy the personal information shared with them when the contractual agreement is terminated
The SADC may share your personal information with people and entities from the above-mentioned categories located outside of the borders of the province of Quebec.
3. Restrictions to the sharing and use of personal information
Collected personal information is destroyed once its purpose has been fulfilled, unless a law or regulation requires the SADC to store said information or imposes a specific storage term.
The SADC does not sell personal information to third parties and does not provide third parties with access to personal information unless required to carry out the aforementioned purposes or if a law or regulation authorizes or requires said information to be shared without your consent.
By default, the privacy settings regarding your use of the website are set to the highest level of privacy, without you having to do anything.
4. How does the SADC protect the privacy of my personal information?
The SADC takes appropriate physical, technological, contractual and administrative measures to protect your personal information and reduce the risk of its unauthorized access, use, sharing and destruction.
Without limiting the generality of the foregoing, the website has certain security mechanisms to protect your personal information, such as:
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Personal information collected from the website is encrypted
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Personal information shared between different components of the website is encrypted
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The SADC’s IT service providers are contractually required to comply with several security-related obligations involving periodic checks of their security practices and procedures, and continuous monitoring and upgrading of the website’s software components
Beyond this, the SADC also:
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Has an internal access management policy for its employees. Said policy states that employees may only access personal information when it is necessary for the completion of their duties
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SADC employees are subject to an internal information protection policy to ensure the integrity, availability and confidentiality of your personal information
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The SADC compiles a confidentiality incident log that helps inventory minor and major incidents regarding your personal information to ensure that said incidents are not repeated and to identify necessary corrective measures
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A personal information storage calendar to ensure personal information is destroyed when no longer required for the aforementioned purposes and if the law does not require its storage
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A confidentiality incident response plan that enables the SADC to respond appropriately and quickly to violations of your privacy
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An access log for personal information
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Annual training for staff members.
Despite these measures, it is impossible for the SADC to guarantee the safety of your personal information. If you suspect that the personal information the SADC holds on you has been compromised, please contact our personal information protection officer and executive director, Ms. Marie-Christine Perron, by email: direction@sadchcn.com, or by mail: 459 Route 138, office 200, Les Escoumins, QC, G0T 1K0.
5. What does the SADC do in the event of a confidentiality incident?
The SADC keeps a confidentiality incident log in accordance with applicable legislation. In the event of a breach of privacy that poses a risk of serious harm to you, the SADC will take the necessary measures to notify you, in accordance with applicable legislation. The SADC also applies measures to limit the harm that could result from a breach of privacy and to reduce the likelihood of a breach.
6. How long does the SADC store my personal information?
In accordance with our procedures for the safe storage and destruction of personal information, we only store your personal information for as long as is required to complete the purposes listed in section 1 above or for the duration required by our statutory obligations, whichever is longer.
7. Requests regarding personal information
(i) Access requests
You or a person authorized by the Act Respecting the Protection of Personal Information in the Private Sector may make a request to access your personal information by contacting the personal information protection officer as outlined above. The personal information protection officer will provide you with access to your information, unless:
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The SADC is not legally permitted to provide you said access
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The SADC has a serious and legitimate reason to not provide access
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Granting access to said information risks seriously harming a third party
In principle, exercising your right to access is free. However, a reasonable fee may be charged to offset the costs of transcription, reproduction or transmission. In such a case, the applicant will be notified of the amount before their request is processed.
You may also request to obtain a copy of your personal information by submitting a written request to the personal information protection officer in accordance with the above procedure.
If the SADC grants a request to obtain a copy of your computerized personal information, the SADC will ensure said copy is transmitted to you (or to any other person or organization authorized by law to collect said personal information) in a structured and commonly used technological format. Unless providing such a copy raises serious practical difficulties, or the SADC or one of its service providers has generated or created the personal information.
(ii) Amendment requests
We ask that you notify us of any changes affecting the authenticity or accuracy of your personal information.
You or a person authorized by the Act Respecting the Protection of Personal Information in the Private Sector may make a request to amend your personal information. By making a request, we can amend:
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Inaccurate personal information
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Outdated personal information
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Ambiguous personal information
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Incomplete personal information
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Unfairly collected personal information
Alternatively, you can send a request to our personal information protection officer asking for your outdated or unfairly collected personal information to be destroyed. Requests to amend or destroy personal information must be addressed to the personal information protection officer, as specified above.
(iii) Requests to cease the sharing of personal information, to de-index or re-index
The SADC may also, when requested by the person in question or any other person authorized by the law to make such requests, cease the sharing of personal information, or de-index or re-index, depending on the case, any hyperlink linked to the person in question’s name, in accordance with the criteria established in applicable, current legislation.
(iv) Requests to revoke consent
Subject to your contractual commitments with the SADC and applicable legislation, the Act Respecting the Protection of Personal Information in the Private Sector (if applicable) allows you to revoke your consent to the use and sharing of your personal information in some circumstances. Please note, exercising your right may affect the services the SADC can provide to you. If you make such a request, the SADC will identify the consequences revoking your consent will have on our services.
8. Procedure for making requests
All requests to access or amend personal information must be made in writing to our personal information protection officer, Ms. Marie-Christine Perron. You may make your request by sending an email to the following address: direction@sadchcn.com.
Requests must be sufficiently detailed to enable our officer to evaluate and find the personal information in question. The applicant must, in particular, remain contactable, ensuring that they can assist the officer in clarifying their request to facilitate the identification of the personal information, and share the acceptance or refusal of the request, where applicable.
The personal information protection officer has 30 days to process requests. If your request has not been processed within 30 days, it is deemed to have been refused.
9. Procedure for filing complaints
You may file a complaint regarding our personal information protection and governance methods, practices and policies by contacting the personal information protection officer at the following email address: direction@sadchcn.com.
The personal information protection officer will respond to all complaints within 30 days. If your complaint is accepted, a summary of the changes made to our methods, practices and policies will be sent to you.
10. Amendments to the privacy policy
The SADC may unilaterally amend this privacy policy. Before applying any changes, the SADC will place a notice on the website detailing the upcoming changes. We therefore suggest you consult this privacy policy from time to time to check if any changes have been made. To help, we will always indicate the date the policy was last updated at the end of the policy.
If you have shared your email address with us, you will also receive this notice or a similar notice by email. Your use the website, sharing of your personal information with an authorized SADC representative or on an SADC application form online following the introduction of an amended policy will be deemed to constitute your acceptance of said changes.
11. Miscellaneous
If you have any questions about your rights or otherwise, or wish to make any comments, please contact the personal information protection officer.
FAO: Marie-Christine Perron, personal information protection officer
SADC de la Haute-Côte-Nord
459 Route 138, Office 200
Les Escoumins, Québec G0T 1K0
Policy last updated: October 25, 2023