Privacy Policy
Groupe Sutton Synergie Inc. (hereinafter "The AGENCY") provides a secure web environment to its Internet users.
The AGENCY is governed by the Private Sector Privacy Act (R.S.Q., c. P-39.1) (hereinafter, the "Act") and as such, The AGENCY strives to maintain the highest standards of confidentiality regarding the personal information provided by its clients, suppliers, and other businesses in the context of its real estate brokerage activities, including but not limited to, through The AGENCY's website (the "Website"), its social networks, its advertisements, as well as for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with the obligations imposed by the Act.
Personal information is information that concerns an individual and allows, directly or indirectly, for their identification. A written document, an image, a video, and a sound recording can contain personal information. In the course of its professional activities, The AGENCY may collect personal information such as name, residential address, date of birth, identification document information, social insurance number, income information, marital status, etc.
- Responsibility:
- Collection of Personal Information:
The AGENCY is responsible for the protection of personal information it holds in the course of its real estate brokerage activities. To this end, The AGENCY has adopted a privacy policy as well as policies and practices governing governance regarding personal information, with the aim of regulating the collection, use, communication, storage, and destruction of personal information.
The AGENCY only collects personal information necessary for the conduct of its activities in the field of real estate brokerage. For example, this may include information collected for the purpose of completing a real estate transaction, for record-keeping purposes, for monitoring professional practice by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ), or any other purpose determined by The AGENCY and brought to the attention of the person from whom consent is requested.
The AGENCY encourages its staff, team members, or any administrative assistant, as applicable, to explain in simple and clear terms to the person concerned the reasons for the collection of their personal information and to ensure their understanding.
For the purpose of collecting personal information, The AGENCY encourages its staff, team members, or any administrative assistant, as applicable, to use standardized forms developed by the OACIQ.
The AGENCY may also collect personal information verbally during correspondence with individuals involved in a transaction or through various documents submitted in the context of a real estate transaction (identity documents, financial documents, powers of attorney, etc.).
Personal information is used and disclosed for the purposes for which it was collected and with the consent of the individual. In some cases provided by law, personal information may be used for other purposes, such as, for example, to detect and prevent fraud or to provide a service to the individual.
The AGENCY may be required to disclose personal information to third parties, such as suppliers, co-contractors, subcontractors, agents, insurers (such as the Professional Liability Insurance Fund of the Real Estate Brokerage of Quebec [FARCIQ], the Real Estate Brokerage Compensation Fund of Quebec [FICI]), professionals, financial institutions, or credit verification agencies, as well as electronic document management (EDM) system providers and other regulators, or outside Quebec.
The AGENCY may, without the consent of the individual, disclose personal information to a third party if such disclosure is necessary for the execution of a mandate or service or business contract. In this case, The AGENCY establishes a mandate or a written contract specifying the measures that its agent must take to ensure the protection of the personal information entrusted to them, so that it is only used in the performance of the mandate or contract and is destroyed after its completion. The co-contractor must also undertake to collaborate with The AGENCY in the event of a breach of the confidentiality of personal information.
Before disclosing personal information outside Quebec, The AGENCY takes into account its sensitivity, the purpose of its use, and the protective measures it will receive outside Quebec. The AGENCY will only disclose personal information outside Quebec if its analysis demonstrates that it will receive adequate protection in the location where it is to be disclosed.
When the purposes for which personal information was collected or used have been achieved, The AGENCY must destroy it, subject to a retention period provided by law. In this regard, The AGENCY's professional obligations require it to retain its records for at least six (6) years following their final closure.
During the collection, use, retention, and destruction of personal information, The AGENCY applies the necessary security measures to protect the confidentiality of personal information. The collected personal data will be stored, including on servers and in electronic data management systems, with mechanisms and standards recognized for protection to ensure the security of the personal information provided by its clients, suppliers, and other businesses in the context of its real estate brokerage activities, including, but not limited to, its Website, social networks, advertisements, and for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with the obligations imposed by law.
An incident of confidentiality is unauthorized access, use, communication of personal information, or the loss of personal information, or any other breach of the protection of personal information.
The BROKER has implemented a protocol for managing a confidentiality incident in which individuals assisting the Personal Information Protection Officer are identified, and concrete actions to be taken in the event of an incident are outlined. This protocol includes responsibilities at each stage of incident management, including measures to ensure data security.
A. The BROKER, its staff, team members, or any administrative assistant, as applicable
- Ensures the confidentiality of information through good information management practices. In particular, provides directives, training, and instructions to staff regarding the collection, use, storage, modification, consultation, communication, and permitted destruction of personal information.
- Deploys adequate protection measures to reduce the risk of confidentiality incidents, such as information security, updating policies related to personal information, staff training, etc.
- Has standardized methods of classifying documents containing personal information.
- Has standardized methods of retaining documents containing personal information, particularly regarding the scanning procedure.
- Manages physical and computer access to personal information, especially based on its sensitivity.
- Ensures the secure destruction of personal information. Specifically, provides directives or instructions to staff regarding the method of secure destruction, destruction timelines, etc.
B. Personal Information Protection Officer
In accordance with the law, the BROKER is the Personal Information Protection Officer.
Ensures that these policies are respected and comply with applicable regulations. The name and contact information of this person are provided in the "Complaints" section.
The BROKER oversees the management of confidentiality incidents and, in this context, takes actions provided by the law.
The BROKER processes requests for access and rectification of personal information. It also handles complaints regarding the processing of personal information by the BROKER.
The BROKER establishes privacy factors for any project involving the acquisition, development, or redesign of an information system or electronic service delivery system involving the collection, use, communication, retention, or destruction of personal information. It may suggest measures to ensure the protection of personal information in such projects.
A member of the staff, team, or any administrative assistant of the BROKER may access personal information only to the extent necessary for the performance of their duties or mandate.
- The staff member, team member, or administrative assistant of the BROKER:
- Ensures the integrity and confidentiality of personal information held by the BROKER.
- Complies with all policies and directives of the BROKER regarding access, collection, use, communication, destruction of personal information, and information security, respecting the instructions provided.
- Respects the security measures in place on their workstation and on any equipment containing personal information.
- Uses only equipment and software authorized by the BROKER.
- Ensures, when the time comes, the secure destruction of personal information in accordance with the instructions received. Immediately reports to their superior any act, of which they are aware, that may constitute an actual or presumed violation of the rules of security regarding personal information.
An individual (or their authorized representative) may request access to the personal information concerning them held by the BROKER. An individual may withdraw their consent to the collection, use, and communication of their personal information at any time. This withdrawal is then recorded in writing.
An individual may request correction, in a file concerning them, of personal information they consider inaccurate, incomplete, or ambiguous.
An individual may request to transfer, electronically, the personal data held by the BROKER to a third party.
The BROKER may refuse a request for access or rectification in cases provided by the law (Private Sector Privacy Act).
An individual who feels aggrieved may file a complaint regarding the processing of their personal information by the BROKER. This complaint will be processed promptly within a maximum period of 30 days by the BROKER, and a written response will be provided to you.
To make a request for access, rectification of your personal information, or any other request to which you are entitled, and to submit a complaint regarding the processing of personal information, please contact [insert contact details].
Joel Groleau, Steve Robitaille, and Margot Langelier
1617, ch. Gascon Terrebonne (QC) J6X 2Z7
450-914-4872
This email address is being protected from spambots. You need JavaScript enabled to view it.