If you have any questions or concerns, if you wish to exercise your rights or if you wish to file a complaint regarding the protection of personal information, please contact the Privacy Officer using the information below.
Christine O’Doherty, Lawyer, Executive Director
Canadian Institute for the Administration of Justice
514-731-2855, ext. 1
christine.odoherty@ciaj-icaj.ca
Goal of the Policy
The CIAJ Governance Committee has adopted this policy to comply with the spirit and letter of the Act to Modernize Legislative Provisions respecting the Protection of Personal Information, which came into force in Quebec in 2022.
Guiding Principles of the Policy
- The protection of personal information held by the organization about its members, program participants, volunteers, donors, collaborators and partners is a priority and a legal and moral obligation.
- CIAJ is a good corporate citizen and complies with the obligations set out in the Act to Modernize Legislative Provisions respecting the Protection of Personal Information.
Policy Statement
Personal Information Held by CIAJ
The personal information held by CIAJ is that listed in this Section A of the Policy Statement. None of this information is sensitive. According to the Commission d’accès à l’information du Québec, personal information is considered sensitive when, due to its medical, biometric, or other intimate nature, or due to the context of its use or communication, it gives rise to a heightened reasonable expectation of privacy.
Members and Program Participants
- Name, work address, email and telephone numbers of members and program participants.
- Consent of members and participants to share their personal information with collaborators.
- Banking information or credit card numbers.
Volunteers
- Volunteers’ name, work address, personal email address and telephone numbers.
Employees
- Employees’ name, home address, personal email address and telephone numbers.
- Curriculum vitae and other similar professional information about the employee (work history, academic background, etc.).
- Banking information.
- RAMQ cards and driver’s license (for criminal record checks).
Donors
- Name, home address, personal email address and telephone numbers of donor.
- Donor donation history.
Collaborators and Partners
- Name, work or home address, personal email address and telephone numbers of partners’ employees or business relationship.
How CIAJ Collects and Protects Personal Information
Information Collection
- CIAJ collects personal information during interviews, in person, by telephone or videoconference, and during exchanges by email or other electronic means.
- Interviews or face-to-face exchanges take place at the organization’s head office or during extra-mural activities.
- Personal information is collected to provide services to members and program participants, to ensure the proper functioning of the organization’s operations and to interact effectively with the organization’s volunteers, donors, collaborators, and partners.
- The organization’s Web site provides a link to this policy and reminds individuals that if they do not wish CIAJ to collect their personal information, they must the executive director. Failure to do so will be deemed to constitute agreement that CIAJ may keep (or acknowledgement that CIAJ keeps) the personal information provided by the individual.
Protection of Information
- CIAJ follows generally accepted standards to protect the personal information it holds. CIAJ maintains appropriate physical, technical and administrative safeguards. Only employees authorized by the executive director have access to personal information held by the organization. Such access is granted when employees need it to perform their duties.
CIAJ Measures for the Retention and Destruction of Personal Information
Retention
- A member or participant’s file and all the personal information it contains are kept securely for a period of five years after it is closed. A file is closed when the member or participant permanently ceases to use the organization’s services. During the retention period, the printed version of the file is kept in a locked filing cabinet, while the electronic version is protected by a code known only by the executive director and authorized persons.
Destruction
- After a five-year retention period, the organization shreds the printed version of the closed file and destroys the electronic version.
Measures applied by CIAJ in the event of a confidentiality incident involving personal information.
- Any employee of the organization who becomes aware of a confidentiality incident involving personal information must immediately notify the executive director.
- The executive director must investigate to understand the circumstances surrounding the confidentiality incident. The organization must record the incident in its Incident Register and promptly notify the person or persons whose personal information has been compromised, drafts a notice to the Commission d’accès à l’information, using the form provided for this purpose by the Commission, and takes the necessary steps to reduce the risk of a similar confidentiality incident recurring.
Complaints Management Policy
- Individuals wishing to file a complaint concerning personal information are invited to use the procedure described in the organization’s Complaints Management Policy.
Policy Implementation
The executive director is responsible for implementing the Confidentiality and Personal Information Management Policy. His or her name and contact information are listed on the organization’s website.
Policy Adoption
The Policy on Privacy and the Management of Personal Information was adopted by the CIAJ Governance Committee on September 22, 2023.