DATA CONFIDENTIALITY POLICY
Recrutement Global du Québec, Inc. is committed to protecting the privacy and security of personal information collected and processed in the course of our business activities. This Data Privacy Policy sets forth guidelines and procedures for the safe and responsible disposal of personal digital data to ensure compliance with applicable data protection laws and regulations.
1. Purpose of Data Collection
Our primary goal in collecting personal data is to effectively perform the essential functions of our recruitment agency, including:
1. Candidate representation: We collect personal and professional information from candidates to match them with suitable career opportunities and facilitate the hiring process.
2. Client Engagement: We collect specific data from clients to understand their hiring needs and provide them with qualified candidates who meet their criteria.
3. Legal compliance: We collect data necessary for compliance with labor laws, regulations and identity verification.
2. Data Destruction Principles
2.1. Data Minimization: We retain personal data only for as long as necessary for the purposes for which it was collected or as required by applicable laws and regulations. Personal data that is no longer needed will be deleted 5 years after the end of the employment relationship with the company.
2.2. Secure Destruction: Personal data in digital format will be digitally deleted in a manner that ensures that it cannot be reconstructed or accessed by unauthorized persons.
2.3. Documentation: Records of data destruction activities, including date, method and persons responsible, shall be maintained for audit and compliance purposes.
3. Data Destruction Procedures
3.1. Identification of data for destruction: The Data Protection Officer (DPO) or designated staff will identify personal data that has reached the end of its retention period or is no longer needed for the original purpose.
3.2. Verification: After data destruction, a verification process will be carried out to ensure that the data is unrecoverable.
4. Data Destruction Schedule
4.1. Retention periods: The organization shall keep a record of the retention periods for the different categories of personal data in accordance with applicable laws and regulations.
4.2. Periodic Review: The DPO or designated personnel shall periodically review and update the data destruction schedule to ensure compliance with changing legal requirements and business needs.
5. Roles and Responsibilities of Staff Members
The Data Protection Officer (DPO), Matias Bichara, is primarily responsible for ensuring compliance with privacy laws and regulations. His responsibilities include:
– Oversee the development, implementation and maintenance of data protection policies and practices.
– Ensure that privacy and data protection considerations are integrated into all aspects of the organization’s operations.
– Monitor and audit compliance with privacy laws and regulations.
– Act as point of contact for privacy related inquiries and concerns.
– Collaborate with relevant departments to address privacy and data protection issues.
– Keep informed of changes in privacy laws and regulations and ensure that the organization remains compliant.
The Chief Executive Officer (CEO), Nicola Castro-Dorion, is responsible for the processing of personal data within the organization as part of his role. This includes:
– Make decisions regarding the collection, use and disclosure of personal data consistent with the organization’s mission and objectives.
– Ensure that the organization’s data processing practices are conducted in a manner consistent with applicable privacy laws and regulations.
– Collaborate with the DPO and other relevant personnel to address privacy issues and maintain compliance.
– Provide leadership and guidance to the organization on data protection and privacy related matters.
– Oversee the secure destruction of data that is no longer needed.
– Ensure that this process is carried out in accordance with applicable data protection laws and regulations.
6. Data Protection Complaint Procedure
If you have any questions or complaints regarding privacy issues, we encourage you to bring them to the attention of our designated point of contact, our data protection officer, Matias Bichara, by sending an email to info@recrutementglobal.com. Please write “Privacy Complaint” in the subject line. Once the complaint is received, the data protection officer will acknowledge receipt of the complaint and indicate the estimated response time for resolution.
Complaints will be carefully investigated and evaluated by the designated team, who will collect and review relevant evidence. The process will follow specific criteria and standards to thoroughly evaluate the complaint. Subsequently, the results of the investigation will be communicated to the complainant and a number of possible resolutions will be outlined. Throughout this process, qualified Global personnel are committed to maintaining the confidentiality of the complainant and the details of his or her complaint.
7. Escalation Process
If a complainant remains dissatisfied with the initial resolution provided by the organization, Global has established a clear and structured escalation process to address their concerns at a higher level. The escalation process is as follows:
- Escalation Contact: Complainants who wish to escalate their concern should contact Nicola Castro-Dorion. Mr. Castro-Dorion’s contact information is provided through the same communication channels used to file the initial complaint, such as email info@globalrecrutement.com. Please use the subject line “Complaint Escalation”.
- Secondary Review: The complaint will be reviewed by a higher authority within the organization, typically the Chief Executive Officer, Nicola Castro-Dorion. Mr. Castro Dorion will conduct a secondary review of the complaint, reassessing the evidence, the initial resolution and relevant policies and procedures.
- Re-evaluation and resolution: A data privacy panel will re-evaluate the complaint, considering any new information or issues that may not have been adequately addressed during the initial review. The goal is to reach a resolution that is fair and satisfactory to the complainant.
- Outcome of Escalation: Upon completion of the secondary review, the complainant will be informed of the outcome of the escalation process. This may include an explanation of the resolution, any additional action taken, or additional steps that will be implemented.
- Closure and Communication: Upon secondary review and resolution, the complaint will be considered closed. Global will remain committed to maintaining the confidentiality of the complainant and the details of their complaint throughout the escalation process.
By establishing this structured escalation process, Global aims to provide an avenue for complainants to have their concerns addressed at a higher level of authority, ensuring that privacy issues are handled thoroughly and fairly within the organization.
In addition, Global places a strong emphasis on record keeping to ensure complete documentation of all complaints and related actions. These records serve as valuable information for continuous improvement of our policies and procedures.
To ensure accessibility, Global makes the complaint process easily accessible through our website, and we are committed to training our employees on the complaint process and making them aware of the importance of privacy and data protection. By establishing this structured grievance process, Global aims to provide a transparent, efficient and respectful mechanism for individuals to voice their privacy concerns and to ensure that privacy issues are addressed promptly and fairly within the organization.
