Privacy Policy

Our responsibility

TB4 Ronam Inc. is responsible for all personal information it possesses or manages, including personal information we receive directly – for example, from clients and staff members.

TB4 Ronam Inc. adheres to cybersecurity best practices by conducting, in collaboration with our IT partner, a holistic and rigorous cybersecurity program based on the NIST framework. As such, we have conducted a cyber risk assessment on our IT assets and developed a cyber risk management strategy aimed at implementing a series of mitigation measures to protect our IT assets, including personal information.

We have also appointed a privacy officer and delegated certain cybersecurity responsibilities to our IT partner through a managed cybersecurity services offering. The execution of our cybersecurity program, in partnership with our IT firm, ensures privacy protection and safeguarding of personal information on behalf of TB4 Ronam Inc. We have also published on our website and informed our staff about the existence of our Privacy Policy and our Policies and Governance Practices regarding personal information, as well as the role each individual must play in ensuring the protection of our clients’ personal information and our team members’ personal information.

If you have any questions regarding our practices in this matter, please do not hesitate to contact the privacy protection officer at jdebroux@tb4ronam.ca or at (418) 836-5569 extension 103.

Purposes of personal information collection

TB4 Ronam Inc. collects, uses, and discloses personal information regarding its team members to comply with laws, regulations, and professional standards; provide them with benefits; administer performance management tools; administer, manage, monitor, and enforce TB4 Ronam Inc.’s programs and policies and its relationships with employees; and, in general, establish and manage employment or association relationships or terminate them.

TB4 Ronam Inc. may also collect, use, and disclose personal information regarding individuals who apply for employment with us. In the event that we are not in a hiring period, or your job application is not considered for any other reason, the information you provide to us will be immediately destroyed without being reviewed.

TB4 Ronam Inc. may collect and use personal information from its current and prospective clients to improve the quality of services provided to them.

It is possible that personal information may be collected without the knowledge or consent of the individuals concerned, to the extent permitted by law.

Consent

TB4 Ronam Inc. ensures to obtain the consent of the individuals involved before collecting, using, or disclosing personal information, except in cases authorized or required by law.

Limitations on collection

TB4 Ronam Inc. collects personal information only through legitimate and legal means, and only to the extent reasonably necessary to fulfill its legal obligations, provide its services, and conduct its activities.

Limitations on use and disclosure

TB4 Ronam Inc. uses and discloses your personal information only for the purposes for which consent has been obtained, or as permitted or required by law. If TB4 Ronam Inc. needs to use or disclose personal information about an individual for a purpose that was not previously identified, TB4 Ronam Inc. will seek the individual’s consent, unless the law requires or permits the use or disclosure of personal information without consent.

We retain personal information only for as long as necessary to fulfill the identified purposes, unless otherwise authorized or required by law. All human resources records and other records containing personal information about TB4 Ronam Inc. employees are destroyed when they are no longer reasonably considered necessary for legal, regulatory, or administrative purposes.

Accuracy

To ensure that the collected personal information is relevant for the purposes for which it is used, TB4 Ronam Inc. makes reasonable efforts to maintain the integrity of individuals’ personal information and to keep it regularly updated.

Individuals who are the subject of the collected personal information should communicate in writing to the privacy officer to request corrections or updates.

Security measures

TB4 Ronam Inc. is committed to protecting personal information by implementing its cybersecurity program based on the NIST framework. TB4 Ronam Inc. adheres to cybersecurity best practices by conducting a holistic and rigorous program based on the NIST framework. A cyber risk assessment of our IT assets has been completed and is regularly reviewed, and a cyber risk management strategy has been developed to define and implement a set of risk mitigation measures to protect our IT assets, including personal information.

Transparency

TB4 Ronam Inc. will provide interested individuals with information about its Privacy Policy and its governance policies and Practices regarding personal information upon request. TB4 Ronam Inc. also commits to responding to any written information requests submitted to the privacy officer regarding matters related to its policies and practices for managing personal information.

Access

Individuals have the right to review the personal information we hold about them and to obtain a copy of it. To exercise this right, they should contact the privacy officer.

The right to access personal information is subject to certain legal restrictions, and we will take reasonable steps to verify the relevance of the request and the identity of an individual before granting access.

In most cases, applicants will receive a response within 30 days. If a person has any concerns regarding access, we encourage them to contact the privacy officer at jdebroux@tb4ronam.ca or at (418) 836-5569 extension 103.

Complaints

We understand the importance of protecting the privacy and personal information of individuals. If you have any questions or concerns about the privacy and protection of your personal information and the role we play in that regard, please contact our privacy officer at jdebroux@tb4ronam.ca or at (418) 836-5569 extension 103.

TB4 Ronam Inc. has established a procedure for receiving and addressing complaints regarding this policy and its personal information handling practices. An individual whose personal information is held by TB4 Ronam Inc. may complain about non-compliance with this policy. Any complaint regarding the protection of personal information should be directed to the privacy officer at the address provided above. In most cases, applicants will receive a response within 30 days.

If an individual is not satisfied with TB4 Ronam Inc.’s response to a complaint or with TB4 Ronam Inc.’s policies and practices regarding the handling of personal information, they may file a complaint with the Commission d’accès à l’information du Québec through the Commissioner’s website at https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.

Law 25 documents

Several other documents have been created in accordance with the new requirements of Law 25. The following documents were drafted in collaboration with the cybersecurity team of our IT provider:

• Policy and Governance Practices Regarding the Protection of Personal Information
• This document can be made available upon request to any person making the request.
• Privacy Incident Response Plan
• This document is available upon request to any employee or concerned party.

Policy update

This policy must be reviewed every three years. It must also be updated in the event of any substantial changes to legislation or regulatory requirements.

Last update : June 26th, 2023