Privacy notice

The following principles govern how we ensure your privacy:

• Ensure secure management. We put proper management and protection practices in place to keep your personal information secure and oversee its use.
• Respect your rights.You have certain rights with regard to the personal information we hold about you. You may exercise these rights at any time.
• Be transparent. We provide you with all relevant information regarding our privacy practices.
• Act responsibly. Our employees, suppliers and representatives must comply with our privacy practices. Our Chief Privacy Officer ensures that they do, and that our practices are always up to date.

From whom do we collect your personal information?

We collect your personal information primarily from you. We may also collect it from others, depending on the circumstances. For example:

• Recruitment platforms
• Recruitment agencies
• Psychometric assessment firms
• Credit bureaus and reporting agencies
• Providers of criminal background checks
• Personal references
• Immigration law firms
• Your current or previous employer

How do we collect your personal information?

We may collect your personal information in various ways, including:

• By phone
• In person
• Through paper and online forms
• Through applications and platforms, such as Workday
• Through cookies

What personal information do we collect?

We only collect the personal information necessary to fulfill the purposes outlined in this notice.

Here are some examples of personal information we may collect:

We may also create or infer information based on the personal information we collect. For example, we may create a candidate profile or an ID for you. This is considered personal information. We manage and protect it in accordance with the same practices we use for the rest of your personal information.

We collect, use, disclose and retain your personal information only for the purposes outlined in this notice. We will inform you of the intended purposes at or prior to the time we collect your personal information.

The following purposes may be essential to our relationship with you:

Some purposes are optional. We must obtain your separate consent to collect, use, disclose and retain your personal information for the following purposes:

With whom may we share your personal information?

In order to fulfill the purposes outlined in this notice, we sometimes need to share your personal information with other individuals or organizations.

For example, we may share it with the following third parties: 

• Criminal background check providers, such as Mintz
• Credit bureaus and reporting agencies, such as Equifax or TransUnion
• Psychometric assessment firms
• Immigration law firms

We may disclose your personal information outside of Canada

We may disclose your personal information outside Canada if, for example, we are doing business with a supplier based in another country. In this case, we contractually ensure that our supplier meets our expectations in terms of managing and protecting your personal information. Before transferring your personal information outside Canada, we ensure that it will be adequately protected.

We may also disclose your personal information to another Canadian province or territory.

When do we obtain your consent?

We obtain your consent before we collect, use or disclose your personal information. We may obtain consent directly from you. It may also be obtained from someone else, such as a service provider or recruitment agency.

We will request your consent again if we wish to use or disclose your personal information for a purpose to which you have not consented.

When do we not request your consent?

In some cases, the law permits us to collect, use or disclose your personal information without your consent.

Here are a few examples:

• Disclosing your personal information to suppliers for a purpose outlined in this notice
• Conducting statistical studies using de-identified personal information, where permitted by law
• Taking appropriate action if we detect potential fraud
• In Quebec only, using your personal information if it is clearly to your benefit or for purposes related to those you have already agreed to
• Outside Quebec, using or disclosing your personal information if it is clearly to your benefit and we are unable to obtain your consent

We may also be required by law to disclose personal information, for example if ordered by a court or requested by a regulatory authority or self-regulatory body.

Our employees, representatives and other stakeholders play a role in protecting your personal information. Our in-house procedures clearly define each person’s roles and responsibilities in managing personal information.

We limit access to and use of your personal information

We keep access to your personal information to a minimum. Access to your personal information is restricted to individuals who need it to do their jobs.

Here are some of the measures in place to control access to and use of your personal information:

• We train our employees, representatives and consultants to handle your personal information with care and according to best management practices. Our suppliers must do the same.
• Our employees, representatives and suppliers may access and use the personal information we collect only if we have obtained consent for this purpose or if permitted by law.
• We regularly review the access rights of employees, representatives and suppliers based on their roles and responsibilities.

We protect our facilities and IT systems

We have security measures in place to protect our platforms, facilities and IT systems. Your personal information is protected at all times by a multidisciplinary team, monitoring tools and state-of-the-art technology environments.

Here are a few of the security measures in place:

We communicate with you securely

We have measures in place to ensure the security of our communications with you, including when we collect your personal information.

Here are some examples of these security measures:

• We always verify your identity, whether online, over the phone or in person. Other than to authenticate you, we avoid collecting certain personal information over the phone, such as your date of birth or your social insurance number.
• We will never ask for your password or your personal identification number (PIN).
• We will not contact you for the sole purpose of obtaining your personal information.

We retain your personal information only as long as necessary to:

• Fulfill the purposes for which we collected it, and
• Meet our legal obligations

We have implemented a retention schedule, which guides us on how long we should keep each type of personal information, depending on the context. We destroy the information once the retention period has elapsed. This period depends, among other things, on our legal and regulatory obligations and on the time needed to protect our rights in the event of legal recourse.

We may anonymize certain personal information before destroying it and retain a copy. Once the information is anonymized, it can no longer be used to identify you and is therefore no longer considered personal information. We use it, among other things, to identify trends and establish performance indicators.

Managing your consent preferences

You may consult and update your consent preferences for the collection, use and disclosure of your personal information at any time. However, please be aware that if you withdraw your consent for a purpose that is essential to our relationship with you (refer to the We collect your personal information for specific purposes section for more details), we will no longer be able to assess your application.

For optional purposes, you may withdraw your consent at any time without adversely affecting our relationship with you.

You can contact us through the link you received by email or update your preferences directly in Workday to withdraw your consent for the following purpose:

• Letting you know about job opportunities

Withdrawing your consent may take up to 30 days to be processed and applied.

Accessing, rectifying or deleting your personal information

You have a number of rights with regard to the personal information we hold about you. You may exercise these rights at any time.

You may submit a written request to exercise any of your rights in relation to your personal information. You will receive our written response within 30 days. If we deny your request in whole or in part, we will provide you with several pieces of information:

• Reasons for the denial
• References to the laws and regulations that justify this denial
• Your right to challenge this denial before the privacy regulatory authority in your province or territory
• Timeframe for appealing the denial

Filing a complaint

You may file a complaint if you feel that we have mishandled your personal information.

Please contact us first if you wish to file a complaint. We will take the time to analyze your complaint and work with you to resolve the situation.

You can also file a complaint with the privacy regulatory authority in your province or territory.