Privacy Policy for Candidates and Employees

Last updated: June 18, 2024

In carrying out its activities and mission, Groupe Desgagnés Inc., its subsidiaries, and affiliated, related or associated companies (hereinafter referred to as “Desgagnés” or “we”) deal with personal information about its candidates and employees. As such, Desgagnés recognizes the importance of maintaining the privacy and protection of the personal information it holds.

To fulfill our obligations under applicable privacy legislation, notably the Act Respecting the Protection of Personal Information in the Private Sector and the Personal Information Protection and Electronic Documents Act, we have adopted the present Privacy Policy for Candidates and Employees (hereinafter the “Policy”).

When you provide us with personal information after having read this Policy, you agree that this information will be treated in the manner described herein.

1. What is the scope of this Policy?

This Policy describes how Desgagnés collects, uses, communicates, and protects personal information about candidates for employment or internships with Desgagnés as well as Desgagnés employees. It also explains how candidates and employees may exercise their rights with respect to their personal information, for example, to access or rectify such information. It applies to personal information that you provide to us through our websites or by any other means, whether such information is held by Desgagnés or by a third party. Entities subject to this Policy include all subsidiaries and affiliated, related or associated companies of Groupe Desgagnés Inc.

2. What is “personal information”?

“Personal information” refers to any information that relates to an individual and allows, directly or indirectly, that individual to be identified, such as their name, social insurance number, an online tracking identifier such as an IP address, or one or more specific characteristics relating to their identity.

3. How do we collect your personal information?

We collect your personal information in a number of ways, including when you:

browse our websites, for example, through the use of cookies or other tracking tools;
supply it through our websites, for example, through one of our application forms;
provide it to us by telephone, e-mail, or in person.

4. What personal information do we collect and why?

We will only collect, use, and disclose personal information about our candidates and employees in accordance with applicable privacy legislation. For example, we only use your personal information for the purposes for which we have obtained your consent or for other purposes that may be required or permitted by law.

The following table presents the types of personal information we collect and the purposes for which we collect it.

As part of the recruitment and hiring process

Types of information collected	Why?
Personal contact information, including name, address and telephone number Date of birth Gender Citizenship and residency status Immigration record, including work permit, where applicable Minority status Government identification, including driver’s licence Seafarer’s book, where applicable Education and schooling, including diplomas, academic transcripts and certifications Content of resume and references Professional qualifications and skills Employment history Pre-employment test results Confirmation of medical fitness for work Credit rating Results of criminal record check	To assess your application and facilitate the hiring process To arrange an interview, if required To conduct third-party pre-employment checks (e.g., reference, criminal record and credit checks) To collect demographic data on employees and applicants to ensure the success of various equity, diversity and inclusion programs and strategies With your consent, to contact you regarding other employment opportunities Some of this information will also be used in your employee file, where applicable, for the purposes specified in the following table.

Types of information collected

Why?

Personal contact information, including name, address and telephone number
Date of birth
Gender
Citizenship and residency status
Immigration record, including work permit, where applicable
Minority status
Government identification, including driver’s licence
Seafarer’s book, where applicable
Education and schooling, including diplomas, academic transcripts and certifications
Content of resume and references
Professional qualifications and skills
Employment history
Pre-employment test results
Confirmation of medical fitness for work
Credit rating
Results of criminal record check

To assess your application and facilitate the hiring process
To arrange an interview, if required
To conduct third-party pre-employment checks (e.g., reference, criminal record and credit checks)
To collect demographic data on employees and applicants to ensure the success of various equity, diversity and inclusion programs and strategies
With your consent, to contact you regarding other employment opportunities
Some of this information will also be used in your employee file, where applicable, for the purposes specified in the following table.

As part of the employment relationship

Types of information collected	Why?
Personal contact information Date of birth Social insurance number Gender Marital status Minority status Employee photo Emergency contacts Immigration file (if applicable), including family information, as well as birth and marriage certificates Basic medical information (e.g., allergies)	To create your employee file and manage the employment relationship To communicate with you or your emergency contacts, for the duration of the employment relationship
Personal contact information Social Insurance Number Health Insurance number Medical information Bank account information	To manage financial and other benefits related to your employment, such as payroll, group insurance, access to telemedicine, reimbursements and payroll deductions To process disability or sick leave claims, based on medical certificates issued by health professionals To adapt your working environment
Login details Professional e-mails Documents saved on Desgagnés hardware Usage, browsing and search logs and records, as well as information about your interactions with websites and applications from hardware provided by Desgagnés, including mobile phones. Details of access to secure areas of Desgagnés premises (using access cards logs and surveillance cameras)	To monitor and safeguard our equipment and information assets To manage security and confidentiality incidents To facilitate the resolution of technical problems For security purposes, through various monitoring and control systems, including the presence of employees, candidates and other individuals on Desgagnés premises
Employee file, including annual performance, development plan, training attendance certificates, remuneration, disciplinary measures and dismissals	To manage your employment, including performance reviews and compensation adjustments To manage the termination of your employment
Results of mandatory screening tests (crews only) Toxicological test report (crews only)	To manage crew health and safety and ensure compliance with legal obligations and Desgagnés policies on drugs and alcohol

5. How do cookies work?

Our websites use cookies in the manner and for the purposes described in our Privacy Policy.

6. To whom do we disclose your personal information?

We may disclose your personal information to third parties, such as our partners or service providers, for the purposes identified in the section “What personal information do we collect and why?”.

In such cases, we will use all reasonable efforts to protect the personal information thus disclosed by means of written agreements and undertakings requiring such third parties to adopt good privacy practices and security measures that comply with applicable privacy laws.

The following table lists the categories of third parties to whom we may disclose your personal information and what they do for us.

Third party categories	What do they do for us?
Service providers (and their own service providers)	We may use service providers to perform certain services on our behalf. For example, we work with service providers in the following areas: Managing group insurance plans, telemedicine and various other employee benefits managing compensation files managing payroll, accounting and invoicing recruitment and human resource management pre-employment screening of applicants (credit checks, criminal background checks, etc.) data hosting services and website management managing our information assets Where necessary to provide our services, or as required by law, we may disclose your personal information to our financial, legal or other advisors.
Government partners or agencies	From time to time, we may disclose personal information to certain agencies that do not act on our behalf but have the authority to request it. For example, this may include government bodies such Revenu Quebec, to meet our tax obligations.

Third party categories

What do they do for us?

Service providers

(and their own service providers)

We may use service providers to perform certain services on our behalf.

For example, we work with service providers in the following areas:

Managing group insurance plans, telemedicine and various other employee benefits
managing compensation files
managing payroll, accounting and invoicing
recruitment and human resource management
pre-employment screening of applicants (credit checks, criminal background checks, etc.)
data hosting services and website management
managing our information assets

Where necessary to provide our services, or as required by law, we may disclose your personal information to our financial, legal or other advisors.

Government partners or agencies

From time to time, we may disclose personal information to certain agencies that do not act on our behalf but have the authority to request it.

For example, this may include government bodies such Revenu Quebec, to meet our tax obligations.

7. How long do we retain your personal information?

We will keep your personal information as long as necessary for the fulfillment of the purposes described in this Policy, unless the law or an exceptional situation requires us to keep it longer. This could be the case, for example, in the event of a dispute.

8. Where do we store your personal information?

We currently store the personal information collected on our websites and in connection with our operations on our servers in the province of Quebec. However, our service providers may be located elsewhere in the world and thus host your personal information in another jurisdiction in order to provide their respective services. In such cases, they are subject to the laws of the

country, state, or province in which they are located and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of that location. If we disclose personal information outside Quebec where applicable privacy laws may differ, we will ensure that it has a level of protection equivalent to that in Quebec, for example, through contractual arrangements. Our practices regarding your personal information will at all times remain governed by this Policy and applicable privacy laws.

9. How do we protect your personal information?

We maintain reasonable procedures and safeguards to protect your personal information, whether it is stored on our servers or by one of our service providers. For example, we have policies and practices in place to ensure that only authorized individuals can access your personal information. We maintain access logs and actively monitor all our networks. We have also developed and implemented a privacy incident response plan to deal with any issues involving personal information.

Warning: However, no security measure is perfect or fully guaranteed. If you have reason to believe that your interactions with us are no longer secure (for example, if you believe that the security or accuracy of any information you have provided to us has been compromised), please contact us as soon as possible using the contact information provided in the “How to reach us?” section.

10. What are your rights regarding your personal information?

You have a number of rights with respect to your personal information, including:

Right to access, rectify and delete	Right to withdraw your consent
You may request access to, and a copy of, the personal information we hold about you.	You may request to withdraw your consent to our use or disclosure of your personal information.
If any personal information we hold about you is inaccurate, incomplete or ambiguous, you may request that it be corrected. You may request that personal information about you be deleted: if its collection, communication or storage is not authorized by law, if it is out of date or obsolete, or if required by law.	In most cases, withdrawing your consent means that we will no longer be able to fulfill your request or provide you with the required service. In all other cases, we will inform you of the consequences of your request in our response.

Right to access, rectify and delete

Right to withdraw your consent

You may request access to, and a copy of, the personal information we hold about you.

You may request to withdraw your consent to our use or disclosure of your personal information.

If any personal information we hold about you is inaccurate, incomplete or ambiguous, you may request that it be corrected.

You may request that personal information about you be deleted:

if its collection, communication or storage is not authorized by law,
if it is out of date or obsolete, or
if required by law.

In most cases, withdrawing your consent means that we will no longer be able to fulfill your request or provide you with the required service. In all other cases, we will inform you of the consequences of your request in our response.

To exercise your rights, please send a written request to our Privacy Officer at the contact information provided in the “How to reach us?” section. We may ask you to provide proof of identity before responding to your request. This identification information will be used solely for this purpose. To obtain further information about your rights under Quebec law, please visit the website of the Commission d’accès à l’information.

11. How to reach us?

You may address any request, question, complaint or comment regarding this Policy to our Privacy Officer using the following contact information:

Privacy Officer
Groupe Desgagnés inc.
confidentialite@desgagnes.com
21 rue du Marché Champlain
Quebec, Quebec G1K 8Z8
Canada

12. When will we update this Policy?

This Policy is effective as of the last updated date at the top of this page. We may change this Policy from time to time and will notify you of any material changes when we do so. Any changes we make will take effect immediately upon notice of the change being made available to you.