Privacy and Personal Information Protection Policy

Camp LIFT is committed to protecting the confidentiality of personal information it collects in the course of its activities. 

The purpose of this policy is to outline the means that Camp LIFT has put in place to achieve this. It also aims to make known the process that Camp LIFT has adopted to handle complaints relating to the protection of personal information and confidentiality incidents. 

We implement recognized measures to protect your personal information against loss, unauthorized access or unlawful processing, by limiting access to strictly necessary personnel. However, no electronic transmission or storage is completely secure, and we cannot guarantee the absolute security of your data, which you share at your own risk. In the event of a breach, we will inform you promptly and take the necessary measures to limit the impact and prevent it from happening again. 

Last updated: November 22, 2024

DEFINITIONS 

" Employee employee " 

Anyone who works for Camp LIFT for pay, including management or coordination, as well as all unpaid individuals (volunteers, interns). 

"Privacy incident" 

Any access, use or communication of personal information not authorized by law, as well as the loss of personal information or any other breach of its protection. 

“Privacy Incident Log” 

All recorded information about incidents relating to the circumstances of the incident, the number of people involved, the relevant dates, the assessment of the severity of the risk of harm and the measures taken in response to the incident. 

“Risk of serious harm” 

The risk assessed following a confidentiality incident that could cause serious harm to the persons concerned. This risk is analyzed by the person responsible for the protection of personal information. For any confidentiality incident, the person responsible assesses the seriousness of the risk of harm to the persons concerned by estimating, in particular, the sensitivity of the information concerned, the anticipated consequences of its use and the likelihood that it will be used for harmful purposes. 

"Personal information" 

Any information communicated to Camp LIFT in any medium whatsoever (verbal, written, audio, video, photographic, computerized or other) which concerns a natural person and which may allow, directly or indirectly, to identify them. 

We collect and process various types of personal information in the course of our activities and services, including: 

∙ Personal and professional contact details : first name, last name, address(es), email(s), date of birth, telephone number(s). 

∙ Biographical information : job title, employer name, professional or personal background, photos, video or audio content. 

∙ Marketing Data and Preferences : food preferences, comments, survey responses, communication preferences. 

∙ Contribution history and financial data : participation in events, billing addresses, banking or payment information.

∙ Service related information : details concerning the services provided for you. 

∙ Professional career and networks : professional affiliations, social involvement, family ties. 

∙ Recruitment : CV, education, employment history, professional affiliations, information relevant to recruitment by Camp LIFT.

∙ Website Use and Technical Data : interactions with our online content. 

∙ Information provided by customers : personal data relevant to the provision of services, which may include special categories such as ethnic origin or sexual orientation. 

∙ Community Donations and Investments : donation policy, beneficiaries, contributions, recognition obtained, decision-making process, and stakeholders. 

∙ Other information provided : any other personal information you share. 

If you provide us with information about other people (customers, directors, officers, shareholders or owners), you must have informed them and obtained their consent for this communication. We may also keep evidence of your consent (date, time, method) if necessary to process your personal data. 

CONFIDENTIALITY OBLIGATION 

1.1 

All persons involved in Camp LIFT are required to sign an agreement or commitment to confidentiality and the protection of personal information before carrying out their duties or carrying out mandates for the organization. This agreement or commitment may be the subject of a separate document or the commitment may be contained in an employment contract. 

1.2 

The obligation of confidentiality applies for the duration of the relationship with the person employed by the organization or involved in one or more proceedings. This obligation survives the end of this relationship. 

COLLECTION AND USE OF PERSONAL INFORMATION

2.1 

Camp LIFT may, if necessary, create one or more files containing personal information concerning employees. The purpose of creating such files is to: 

• keep contact details up to date; 
• document work, internship or volunteer situations;
• allow, in the case of paid employees, the performance of administrative tasks required or permitted by law (income tax, group insurance, pension plan, etc.). 

2.2 

Camp LIFT may, as needed, collect personal information about members of the bodies (board of directors, executive board, committees, etc.) and various other individuals (members, subscribers, participants, etc.).  

2.3 

Camp LIFT may only collect personal information that is necessary for the purposes of a service or activity and must use it for those purposes only. 

We may process your personal information in a number of ways, based on your consent or another appropriate legal basis. Each use is based on specific grounds: 

∙ Provision of services : to provide and manage our services, as well as fulfill our obligations arising from any agreements entered into between you and us. 

∙ Optimizing user experience : to facilitate your navigation on our website and ensure that their content is relevant and optimally displayed on your device. 

∙ Marketing and business development : to send you information about our new services, news related to our organization and our sector, as well as invitations to events, provided that you have chosen to receive these communications. 

∙ Research and development : to conduct analyses to better understand our customers' needs and improve our services and offerings, including in terms of security. 

∙ Recruitment : to review and process applications, and assess whether an individual meets the criteria for a position with Camp LIFT.

∙ Legal compliance and risk management : to comply with our legal and regulatory obligations. 

∙ Fraud prevention : to carry out checks, prevent fraudulent acts and, if necessary, transmit information to the competent bodies. In the case of special categories of data, this may include reasons of public interest, such as the prevention or detection of crime, or the management of legal claims. 

∙ Protection of rights : to enforce our rights, meet legal disclosure obligations, or protect the rights of third parties. 

∙ Payment collection : to ensure the payment of amounts owed to us, by using specialized agencies or legal recourse, if necessary. 

∙ Reorganization of the body : in the event of a reorganization (merger, transfer, etc.), personal information may be transferred to relevant third parties, while ensuring their security and confidentiality in accordance with this data protection policy. 

2.4 

Personal information may only be collected from the individual concerned, unless the individual consents to the collection being made from others or is otherwise permitted by law. 

2.5  

The organization that collects personal information from a person under 14 years of age must have obtained prior consent from one of the person's parents or legal guardian, unless the collection is clearly for the benefit of the young person (emergency situation, etc.). In the case of a person aged 14 and over, the person may give their consent themselves. 

STORAGE AND MANAGEMENT OF PERSONAL INFORMATION 

3.1 

The name of the person responsible for the protection of personal information and how to contact them are indicated on the organization's main website. 

The responsible person ensures that a register of confidentiality incidents is kept.

3.2 

Subject to section 3.3, the Responsible Person is authorized to access any personal information held by Camp LIFT. Other employees are authorized to access personal information to the extent that such access is necessary to perform a task in the exercise of their duties. 

3.3 

Employees having access to records under Article 3 must: 

• Ensure that personal information is kept safe from physical damage or unauthorized access; 
• Ensure that all electronic documents containing personal information, including those copied to a portable storage device, are protected by passwords. These passwords are changed on a regular basis and whenever the persons having access to the files concerned are replaced; 
• Keep personal information in paper format in lockable filing cabinets and ensure that the filing cabinets are locked at the end of each work day. Keys to the filing cabinets must be kept in secure locations. 

3.4 

Where the employee may also be qualified in another capacity, personal information will be kept in separate files.  

3.5 

When any person connected to the organization notices a confidentiality incident, they must promptly inform the person responsible for the protection of personal information in order to document the confidentiality incident in the register, take reasonable measures to reduce the risk of harm being caused and prevent new incidents of the same nature from occurring.  

The registry retains information about a privacy incident for a minimum period of five years from the date or period the organization becomes aware of the incident. 

3.6 

The person responsible for the protection of personal information judges whether the incident presents a risk of serious harm.  

If the incident presents a risk of serious harm, the person responsible must promptly notify the Commission d'accès à l'information and any person whose information is affected by the incident. 

3.7 

Camp LIFT doing business with one or more technology service providers to store personal information must obtain from them a commitment to ensure their protection and to preserve their confidentiality. This commitment must be provided for in the contract binding it to its suppliers. Suppliers must also specify in their contract the means they have taken to ensure the protection of personal information and that the latter will only be used in the context of the execution of the contract. 

Camp LIFT must ensure that it includes a provision in its contracts with its technology service providers that it is notified of any confidentiality incident involving personal information collected by it.  

In the event that it is necessary to do business with a company located outside Quebec, it takes all reasonable means at its disposal to protect personal information and ensure that it will not be used for purposes not relevant to the purpose of the collection.  

DESTRUCTION OF PERSONAL INFORMATION 

4.1 

Subject to section 4.2, personal information is retained for the period necessary to carry out the activities for which it was collected. However, it may be retained for a different period when required by law. This personal information is then destroyed securely.  

4.2 

Records relating to employees are retained by Camp LIFT for a minimum period of seven years.  

DISCLOSURE OF PERSONAL INFORMATION TO A THIRD PARTY 

5.1 

Subject to the situations for which the law requires it and to the other provisions of this Article 5, personal information may only be disclosed to a third party after obtaining the manifest, free and informed consent of the person concerned. Such consent may only be given for a specific purpose and for the duration necessary to achieve this purpose. The consent obtained will be in writing if the situation allows it. 

5.2 

Personal information may be disclosed without the consent of the individual concerned if the life, health or safety of the individual is seriously threatened. Disclosure must then be made in the least harmful way for the individual concerned. 

COMMUNICATION OF PERSONAL INFORMATION TO THE PERSON CONCERNED 

6.1 

Subject to Section 6.2, individuals have the right to know what personal information Camp LIFT has received, collected and maintains about them, to have access to such information and to request that it be corrected or that it be de-indexed or anonymized. 

6.2 

Camp LIFT must restrict access to personal information when required by law or when disclosure would likely reveal personal information about a third party. 

6.3 

A written request in connection with Article 6.1 must be processed within a maximum of 30 days. 

6.4  

Persons under the age of 14 cannot demand to be informed of the existence of medical or social information concerning them or obtain communication of this information, unless it is in the context of legal proceedings, through their lawyer.  

BREACH OF CONFIDENTIALITY 

7.1 

An employee breaches his or her duty of confidentiality when that person: 

• Communicates personal information to individuals who are not authorized to have access to it; 
• Discusses personal information inside or outside Camp LIFT where individuals not authorized to have access to it may overhear it;

• Leaves personal information on paper or computer media in plain view in a place where individuals who are not authorized to have access to it are likely to see it; 
• Fail to follow the provisions of this policy. 

7.2 

In the event of a breach of the confidentiality obligation, appropriate disciplinary measures, which may include termination of the employment contract or any other relationship with Camp LIFT, will be taken against the person, in addition to ensuring compliance with the procedure on confidentiality incidents provided for in this policy. 

APPEAL 

8.1 

If it appears that personal information has been used in a manner contrary to a provision of this policy, the person concerned may file a complaint with the person responsible for the protection of personal information at Camp LIFT. If the complaint concerns this person, it may be filed with the management or coordination of Camp LIFT. 

The complaint must be in writing and contain the person's name, contact details and the reason(s) for the complaint. 

8.2 

The person who has been refused access to or rectification of personal information concerning him or her may file a complaint with the Commission d'accès à l'information for review of the disagreement within 30 days of Camp LIFT's refusal to grant his or her request or of the expiry of the deadline for responding to it.  

THIRD PARTY WEBSITES 

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This privacy policy does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend that you read the privacy statements of these websites before using them.

POLICY ON THE USE OF COOKIES 

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The use of cookies on our website is for analytical purposes only and does not collect any personal information.  

CHANGES TO THIS PRIVACY POLICY 

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We reserve the right to change this privacy policy. It is recommended that you review this privacy policy regularly to be aware of any changes. In addition, we will actively inform you whenever possible.