Privacy Policy

Our Company Overview

FolloSoft stands out for offering personalized services and turnkey solutions in commercial snow removal, maintenance, landscaping, and all aspects of external facility upkeep for our clients.

Context

As a company committed to respecting privacy rights and protecting personal information, we’ve adopted a Privacy Policy in line with the Personal Information Protection Act in the private sector (RLRQ, c. P-39.1, hereafter referred to as the Act).

By providing us with personal information (including but not limited to service contracts, quotes, inquiries, online submissions, job applications), you agree to our processing of this information as outlined in this Privacy Policy.

Responsibility

FolloSoft is responsible for the personal information it holds. Our staff must take necessary measures to ensure the security of personal information across all forms of media: written, graphic, audio, visual, computerized, or otherwise.

Objectives

The Act protects an individual’s personal information to prevent and address identity theft, financial fraud, or reputational harm.

To promote sound, rigorous, and preventative practices, the Act requires a designated individual to oversee personal information protection. Within our company, Ms. Isabelle Lorrain, General Manager, ensures compliance and implementation of the Act.

Definitions

Anonymized Information: Information that no longer allows for the direct or indirect identification of an individual.

Personal Information: Information about an individual that directly or indirectly identifies them. For example, names, social insurance numbers, birth dates, or addresses.

Sensitive Information: Personal information considered sensitive due to its medical, biometric, or intimate nature, or because of the context of its use or disclosure, warrants a high expectation of privacy.

Collection

At FolloSoft, anyone collecting personal information must gather only what is necessary for predetermined purposes. We prioritize transparency during collection to ensure informed consent for the transmission of personal information. Access to personal data is limited to authorized company employees as part of their duties.

Roles and responsibilities

Management:

Ensures compliance with and implementation of the provisions of the Personal Information Protection Act in the private sector within FolloSoft;
May delegate in writing to a staff member the responsibility for document access and personal information protection;
Facilitates the role of the personal information protection officer;
Approves this policy and the means of its application;
Supports the implementation and dissemination of this policy.

The personal information access and protection officer:

Ensures compliance with and implementation of the provisions of the Personal Information Protection Act in the private sector within FolloSoft;
Oversees adherence to this policy and legal, regulatory, and administrative obligations related to document access and personal information protection;
Supports managers and acts as an advisor, supporter, and guide for the organization’s staff;
Provides tools necessary for implementing this policy;
Handles complaints related to personal information protection in accordance with the Act and records them in the complaints registry on personal information management;
Processes access requests to documents and personal information, as well as rectification requests according to the Act;
Assesses privacy factors for any project involving the collection, use, communication, conservation, or destruction of personal information;
Evaluates privacy factors for any communication of personal information outside of Quebec and determines if the communication has adequate protection.

Managers:

Hold responsibility for personal information under their care, ensuring its management and protection by staff;
Ensure compliance with this policy and related procedures or directives;
Ensure staff uses secure methods to collect, use, keep, communicate, or destroy personal information;
Take appropriate actions in case of non-compliance with this policy or personal information protection rules by their staff;
Educate their staff on the importance of protecting personal information, in collaboration with the personal information access and protection officer.

Staff:

Familiarize themselves with this policy and adhere to its spirit, provisions, and procedures;
Take necessary measures to ensure the protection of accessible personal information;
Access only the personal information necessary for their duties;
Use accessible personal information only for the purposes for which it was collected;
Inform their manager and the personal information protection officer of any incidents related to the protection of the company’s personal information;
Participate in awareness and training activities on personal information protection provided by FolloSoft.

Security Measures

We use personal information for various purposes, including preparing quotes, service contracts, equipment sales, and billing. We implement strict security measures to protect personal information from theft, loss, unauthorized access, use, and disclosure, considering the information’s nature, purpose, sensitivity, quantity, and storage medium.

Consent

FolloSoft ensures that consent for the collection, use, or disclosure of an individual’s personal information to a third party is explicit, free, informed, and given for specific purposes. Consent must be clear, provided willingly, with full awareness, and be precise. It is requested for each of these purposes in simple and clear terms. The individual concerned must be well informed. In the case of sensitive information, consent must be expressly given.

When consent is requested in writing, it must be presented distinctly from any other information provided to the individual concerned. They may request assistance to understand the scope of the consent being requested. It is valid only for the duration necessary to achieve the purposes for which it was requested.

In certain situations, FolloSoft may use personal information without the consent of the individual concerned, specifically:

When its use is for purposes compatible with those for which it was collected;
When its use is clearly in the benefit of the individual concerned;
When its use is necessary for the prevention and detection of fraud or for evaluating and improving security measures;
When its use is necessary for the delivery of a product or the provision of a service requested by the individual concerned;
When its use is necessary for research, study, or the production of statistics, and it is depersonalized.

Holding and Use

FolloSoft ensures that personal information is accurate, up-to-date, and used only for its collected purposes. If inaccuracies are found or personal information changes, we should be notified immediately.

Conservation, Destruction, and Anonymization

Personal information is kept as long as necessary for its collected purposes and according to applicable laws and regulations. When no longer needed, information is destroyed or anonymized.

Communication

An employee of FolloSoft cannot disclose personal information they hold about someone else unless the individual concerned consents or the law requires it.

FolloSoft may, without the consent of the individual concerned, disclose personal information to any person or organization if such communication is necessary for carrying out a mandate or for executing a service or business contract to be entrusted to that person or organization. In such cases, FolloSoft commits to ensuring that the mandate, service contract, or business agreement is documented in writing and specifies measures for protecting the confidentiality of the communicated personal information.

Similarly, without the consent of the individual concerned, FolloSoft may disclose personal information it holds about someone else, specifically to:

Its attorney;
The director of criminal and penal prosecutions if the information is required for prosecuting a violation of a law applicable in Québec;
A person to whom the information must be disclosed under a law applicable in Québec or for the enforcement of a collective agreement;
A person who, by law, can collect debts on behalf of others and requires the information for performing their duties;
A person if the information is necessary for recovering a debt owed to the company.

Incident Management

A confidentiality incident includes unauthorized access, use, disclosure, loss, or any other compromise of personal information. Significant risk incidents must be promptly reported to the Québec Access to Information Commission and affected individuals, except where it might hinder an investigation.

Liability Limitation

The use of technologies like the Internet carries significant risks. While we take reasonable measures to protect your data, complete security cannot be guaranteed. Users acknowledge that FolloSoft and its employees cannot be held liable for any direct or indirect damage resulting from data confidentiality breaches.

Access Requests and Complaints

For questions, complaints, access to personal information, or correction requests, please contact our personal information protection officer, Ms. Isabelle Lorrain, General Manager.

Complaint Handling Procedure

Reception of Complaints

Complaints can be submitted in writing, by phone, email, or any other official communication channel, addressed to our personal data protection officer. Upon receipt, they will be logged in a centralized register accessible only by the officer.

Preliminary Evaluation

The designated responsible person reviews each complaint to assess its relevance and seriousness. Frivolous, defamatory, or baseless complaints may be dismissed, but an explanation will be provided to the complainant.

Investigation and Analysis

The responsible person conducts a thorough investigation, collecting evidence, interviewing involved parties, and gathering all relevant documents. They remain impartial with the authority to resolve the complaint, ensuring confidentiality and fair treatment of all parties involved.

Complaint Resolution

The responsible person proposes suitable solutions to resolve the complaint promptly.

Communication with the Complainant

The responsible person regularly updates the complainant on the investigation’s progress and the complaint’s resolution. All communications must be professional and respectful.

Closure of Complaint

Once resolved, the responsible person provides the complainant with a written summary of the actions taken and solutions offered. All information and documents related to the complaint are kept in a confidential file.

Policy Modification and Update

This Privacy Policy may be updated at any time. Last updated on Thursday, February 1, 2024.