Introduction

The Regroupement des comités de parents autonomes du Québec (RCPAQ) is a non-profit organization that collects and uses personal information in the course of its activities.

The purpose of this policy is to ensure the protection of personal information and to govern the manner in which RCPAQ collects, uses, retains, manages and destroys such information. In addition, it is intended to inform interested parties about how RCPAQ handles their personal information.

It also applies to the processing of personal information collected by RCPAQ through a third-party technological means or online service.

Application and definitions

This policy applies to the RCPAQ, including its directors, employees, consultants, collaborators and volunteers. RCPAQ staff members who have access to personal information or are otherwise involved in its management must ensure its protection and comply with this policy.

This policy applies to RCPAQ’s main website (rcpaq.org), as well as any other sites or sub-sites controlled and maintained by RCPAQ.

This policy applies to all types of personal information, including information about individuals to whom RCPAQ provides services, its consultants and collaborators, its employees and volunteers, its members or any other person, including visitors to its websites or other online services used by RCPAQ.

For the purposes of this policy, personal information is any information concerning a natural person that allows, directly or indirectly, that person to be identified. Examples include a person’s name, physical address, e-mail address, IP address, telephone number, banking information, health information, gender, ethnic origin, language, political opinions, religious beliefs and so on.

Generally speaking, an individual’s professional or business contact information does not constitute personal information, such as an individual’s name, title, address, e-mail address or business telephone number. The collection, use, disclosure, retention, destruction and security of data do not apply to information about an individual relating to the performance of his or her duties within an organization or to personal information that is public information by law.

Collection and use

In the course of its activities, RCPAQ may collect various types of information for different purposes. The types of information that the RCPAQ could collect, their use or the intended objective as well as the means by which the information is collected are indicated in the following table:

RCPAQ will also inform individuals, at the time of collection of personal information, of any other information collected, the purposes for which it is collected and the means of collection, in addition to other information required by law.

Consent

• RCPAQ collects personal information directly from the person concerned and with his or her consent, unless an exception is provided for by law. Consent may be implied in certain situations, for example, when the individual decides to provide his or her personal information after having been informed by this policy of the use and disclosure for the purposes indicated herein.
• Normally, RCPAQ must also obtain the consent of the person concerned before collecting his or her personal information from third parties, before communicating it to third parties or for any secondary use thereof. However, the RCPAQ may act without consent in certain cases provided for by law and under the conditions stipulated therein.

Collection

• RCPAQ only collects information if it has a valid reason to do so. In addition, collection will be limited to the information needed to fulfill a specific purpose.
• Please note that RCPAQ does not obtain personal information about minors directly from them, but rather from a parent or guardian, with their consent.
• RCPAQ may collect personal information from third parties. Unless an exception is provided for by law, RCPAQ will seek the consent of the person concerned before collecting personal information about him or her from a third party. In the event that such information is not collected directly from the individual, but from another organization, the person concerned may request the source of the information collected from the RCPAQ.

In certain situations, RCPAQ may also collect personal information from third parties, without the consent of the person concerned, if it has a serious and legitimate interest in doing so and if the collection is in the interest of the person and it is not possible to collect it from him or her in a timely manner, or if such collection is necessary to ensure that the information is accurate.

RCPAQ may also collect personal information indirectly through :

• Google. Google has its own terms and conditions and privacy policy, which you can consult for more information.
• Meta. Meta has its own terms and conditions and privacy policy, which you can consult for more information.
• X Corp. X Corp. has its own terms and conditions and privacy policy, which you can consult for more information.

This collection of information through third parties may be necessary in order to use certain RCPAQ services. When required, the RCPAQ obtains the person’s consent at the appropriate time.

Cookies

Cookies are data files sent to a website visitor’s computer by their browser when they visit the site, and can serve several purposes.

Websites controlled and maintained by RCPAQ may use cookies including, but not limited to:

• Cookies to memorize visitors’ settings and preferences, for example for language selection and to enable tracking of the current session.
• Statistical cookies to track visitor behavior and content, and to help us improve our website.
• Session cookies are stored temporarily for the duration of your visit to the website only.
• Persistent cookies are kept on the computer until they expire, and are retrieved when the site is visited.

You can enable and disable the use of cookies by changing the preferences in your browser settings. You can also change or revoke your consent to the use of cookies on our website at any time by using the appropriate button on the bottom left.

Use

• RCPAQ ensures that the information it holds is up-to-date and accurate at the time of use.
• RCPAQ may only use an individual’s personal information for the purposes identified in this policy or for any other purposes provided at the time of collection. As soon as RCPAQ wishes to use this information for another reason or purpose, a new consent must be obtained from the person concerned. However, in certain cases provided for by law, the RCPAQ may use the information for secondary purposes without the consent of the individual:
• When such use is clearly for the benefit of that person;
• When it is necessary to prevent or detect fraud;
• When it is necessary to evaluate or improve protection and safety measures.

Communication

• Generally, and unless an exception is indicated in this policy or otherwise provided for by law, RCPAQ will obtain the consent of the person concerned before disclosing his or her personal information to a third party.
• Personal information may be communicated to third parties without the consent of the person concerned in certain cases, in particular, but not exclusively, to a public or government agency which, through one of its representatives, collects it in the exercise of its powers or the implementation of a program under its management.
• It is possible that personal information held by RCPAQ may be transferred outside Quebec, for example, when RCPAQ uses online services whose servers are located outside Quebec or when RCPAQ deals with subcontractors located outside Quebec.

Retention and destruction of personal information

Unless a minimum retention period is required by applicable law or regulation, RCPAQ will retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.

Personal information used by the RCPAQ to make a decision concerning an individual must be kept for a period of at least one year following the decision in question, or even seven years after the end of the fiscal year in which the decision was made if it has tax implications.

At the end of the retention period or when the personal information is no longer required, RCPAQ will ensure that it is destroyed or made anonymous if it is to be used for legitimate purposes.

The destruction of information by the RCPAQ must be done in a secure manner to ensure the protection of this information.

Security

RCPAQ is committed to implementing reasonable security measures to ensure the protection of personal information under its control.

The RCPAQ must put in place the necessary measures to restrict the rights of use of its information systems so that only employees who need to have access to them are authorized to do so.

Rights of access, rectification and withdrawal of consent

To exercise his or her right of access, rectification or withdrawal of consent, the person concerned must submit a written request to this effect to the RCPAQ Privacy Officer, at the e-mail address indicated in the following section.

Subject to certain legal restrictions, individuals may request access to and correction of their personal information held by RCPAQ if it is inaccurate, incomplete or equivocal. They may also demand that the dissemination of personal information concerning them cease.

The RCPAQ Privacy Officer must respond in writing to such requests within 30 days of receipt. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the remedies available under the law and the deadline for exercising them. The person in charge must help the applicant understand the refusal if necessary.

Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the disclosure or use of the information collected.

They may also ask the RCPAQ what personal information has been collected from them, what categories of RCPAQ staff have access to it and how long it is kept.

Complaints handling process

Any person who wishes to make a complaint regarding the application of this policy or, more generally, regarding the protection of his or her personal information by the RCPAQ, must do so in writing to the RCPAQ Privacy Officer.

The individual must provide his or her name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for it, giving sufficient detail for the complaint to be evaluated by the RCPAQ. If the complaint is not sufficiently specific, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.

RCPAQ undertakes to treat all complaints received confidentially.

Within 30 days following receipt of the complaint or following receipt of all additional information deemed necessary and required by the RCPAQ Privacy Officer in order to process it, the latter must evaluate it and formulate a reasoned response in writing by e-mail to the complainant. The purpose of this evaluation will be to determine whether RCPAQ’s handling of personal information complies with this policy and any applicable legislation or regulations.

If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons for the extension, the progress made in processing the complaint and the reasonable time required to provide a definitive response.

The RCPAQ must keep a separate file for each complaint it receives. Each file contains the complaint, the analysis and documentation supporting its assessment, and the response sent to the person who lodged the complaint.

You may also file a complaint with the Commission d’accès à l’information du Québec or any other privacy oversight body responsible for the application of the law concerned by the subject of the complaint.

However, the RCPAQ invites all interested parties to first contact their privacy officer and wait until the RCPAQ has completed its processing.

Liability

In general, RCPAQ is responsible for protecting the personal information it holds.

In accordance with the law, an RCPAQ Privacy Officer is responsible for ensuring compliance with applicable privacy legislation.

The manager is responsible for implementing this policy and ensuring that it is known, understood and applied. In the absence or inability to act of the Privacy Officer, the Chairman of the Board of Directors of the RCPAQ assumes the duties of the Privacy Officer on an interim basis.

RCPAQ’s Privacy Officer, whose contact information is as follows, has been appointed by RCPAQ’s Board of Directors:

Sylvain Martel
1200 Saint-Martin Boulevard West, Suite 130
Laval, Quebec H7S 2E4
smartel@rcpaq.org

For all requests, questions or comments regarding this policy, please contact the person in charge by e-mail.

Publication and modifications

This policy is published on the RCPAQ website, as well as on all websites controlled and maintained by RCPAQ, to which this policy applies, with respect to the personal information collected therein. This policy may also be disseminated by any means likely to reach the people concerned.

The RCPAQ must also do the same for all modifications to the present policy, which must also be the subject of a notice informing the persons concerned.