Confidentiality and personal information protection policy of the Fondation André Boudreau

SEPTEMBER 20, 2023

PREAMBLE

Since 1983, La FAB has supported awareness, prevention and treatment initiatives related to addictions for young people and members of their entourage. It is recognized as an active and mobilizing partner in carrying out projects that bring about change for the well-being of young people in the Laurentians.

We collect, use personal information for the purpose of soliciting contributions of various forms, participation in events, draws and lotteries. Confidentiality is one of the most important concerns for us and that is why the Fondation André Boudreau has adopted a privacy protection policy relating to the collection and use of the personal information you provide.

This Privacy and Personal Information Protection Policy is intended to help you better understand our practices with respect to the collection, use, disclosure, complaint handling, destruction and retention of personal information.

By agreeing to provide us with personal information (through our website, by completing a donation, purchase and/or event participation form by email, in person or by telephone), you agree that those are treated in accordance with what is indicated in this Privacy and Personal Information Protection Policy, and you authorize the Fondation André-Boudreau, their third parties and their service providers to process your personal information for the purposes set out below. .

This Privacy and Personal Information Protection Policy does not apply to third-party websites that can be accessed by clicking on links on the Fondation André-Boudreau website (fondationandreboudreau. com) and that of the Respire campaign (tuaslederniermot.com).

In short, the Fondation André-Boudreau is in no way responsible with regard to the websites of third parties. If you follow a link to a third-party website, that website will have its own privacy policies which you should review before submitting any personal information.

HOW DO YOU SHARE YOUR PERSONAL INFORMATION WITH US?

You share your personal information with us, as follows:

• When registering for events, contests and newsletters;
• When you register for fundraising activities;
• When you make a donation to the Fondation André-Boudreau, regardless of the form of your donation;
• You also share publicly available information with us, including on public platforms, including our website.

AUTOMATIC EXCHANGE OF INFORMATION

As soon as you access the site, your computer and the site server automatically exchange information. However, this exchange does not allow you to be personally identified (example: name, telephone, address, subject of the request). The information exchanged is:

• The name of your domain from your access provider (ex: companyX.com, if you use a private internet access account; university.edu, if your access is through a university; etc.) ;
• Your IP address (e.g. 123.45.67.980), which could allow an Internet provider to disclose the identity of the person associated with it;
• The type of browser (e.g. Netscape, Firefox, Internet Explorer) and operating system (e.g. Windows, MacOS) you use;
• The pages you visit;
• The date and time you access these pages;
• The address of the site of origin, from which you reached the site visited.

The site collects this information due to the technological requirements of Internet browsing. Indeed, the server needs it to send you files compatible with the computer equipment you use. However, under no circumstances will these requirements identify you.

The information is also stored and used for statistical purposes. They are used to count the number of visits, the most frequented pages, the technology used by visitors, the site of origin and the country of origin of its visitors. Under no circumstances are they used to draw up lists of users.

WITH WHOM MIGHT WE SHARE PERSONAL INFORMATION?

The Fondation André-Boudreau is a non-profit organization duly incorporated and recognized as charitable organizations, therefore the personal information we collect may be transmitted to certain third parties, including the following:

• We use personal information only for the purpose of achieving the primary purpose and applicable legitimate purpose for which it was collected, or for purposes consistent with that primary purpose.

• Third-party service providers and/or partners, including those who provide us with fundraising, database analysis, website, application development, hosting, maintenance and other services. These third parties may have access to or process personal information as part of the services they provide to us;

• Government authorities and law enforcement agencies when required by applicable laws;

• The organization uses the services of third-party sites, such as Google, Facebook, Instagram and Tik Tok to promote its content and offers.

• When you visit our website, these third parties may use cookies, web beacons or other similar technologies on your hard drive to collect or receive information about your use of the website and elsewhere on the Internet. These technologies make it possible to deliver relevant and targeted advertising based on your areas of interest. You can consult the cookies and destroy them if you wish. So you have full control. We advise you to refer to your browser settings to make the appropriate changes.

• For more information, we invite you to consult our Cookies Policy.

USE OF COOKIES

Cookies are used to facilitate navigation on the pages of this site. These cookies do not collect any personal information about you. You can configure your browser at any time to block cookies. However, this action may deprive you of certain functions offered on the site.

If you use a computer in a public place or share a computer with other users, be sure to erase the traces of your navigation stored in the history before ending each session.

THE COOKIES POLICY DOES NOT COVER THIRD-PARTY WEBSITES

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We will only retain personal information for as long as necessary for the purposes set out in this Privacy and Personal Information Protection Policy and to comply with our legal and regulatory obligations.

To learn more about how long we retain personal information, please contact us using the contact information listed under “How to Contact Us”.

TRANSMISSION OF PERSONAL INFORMATION

The Fondation André Boudreau and its staff members or administrators, as well as the Foundation’s website and the Respire campaign website, do not collect any personal information without the visitor’s consent. The André Boudreau Foundation thus complies with the Act respecting access to documents held by public bodies and the protection of personal information.

Sections 64 and 65 of this Act require that any department or body requesting personal information ensure that it is necessary to obtain such information, identify themselves to this person and inform them:

• The name and address of the public body on whose behalf it is collecting this information;
• The use for which this information is intended;
• The categories of people who will have access to this information;
• The mandatory or optional nature of the request;
• The consequences of a refusal to respond to the request;
• Rights of access and rectification provided by law.

In general, you do not have to provide personal information. The only exceptions apply to certain services which may require you to do so. In this case, strict provisions have been made to ensure that the site is secure.

It is important to remember that the transmission of information by e-mail is not completely secure. This is why it is not advisable to divulge information such as your social insurance number by e-mail. In order to preserve the confidentiality of your personal information, the site team will not answer your questions by email when confidential data must be exchanged.

Electronic messages are treated with the same confidentiality measures as mail received by post. If you transmit personal information by e-mail, by filling out an unsecured online form or by subscribing to a mailing list, the site team will conclude that you consent to it. Be sure that :

• The Fondation André Boudreau will only use the information required to respond to and follow up on your request;
• This information is kept, then destroyed, in accordance with the requirements of the Act respecting access to documents held by public bodies and the protection of personal information;
• The Fondation André Boudreau will transmit this information to another government body only if your request is addressed to it or if this communication is required by law;
• The Fnondation André Boudreau will not transmit any information to a private organization.

In general, the Fondation André Boudreau collects personal information for the purpose of:

• Solicit donations from various: organizations, businesses and individuals;
• Fill out a form (comments, suggestions, contest);
• Respond to a satisfaction and evaluation survey.

LIMITATION OF COLLECTION, LIMITATION OF USE AND COMMUNICATION

The Fondation André Boudreau collects only the personal information necessary for the purposes identified above. It indicates, where applicable, the mandatory or optional nature of a request for personal information and the consequences resulting from the choice to communicate or not one or the other of this information.

The Fondation André Boudreau does not use or communicate personal information for purposes other than those for which it was collected, unless the person concerned consents or the law requires it.

The Fondation André-Boudreau does not transfer or trade any of its data, whether confidential or not, outside the province of Quebec.

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We will only retain personal information for as long as necessary for the purposes set out in this Privacy and Personal Information Protection Policy and to comply with our legal and regulatory obligations.

To find out more about how long we retain personal information, please contact us using the contact information provided under the “How to contact us” section.

EXACTNESS

The foundation ensures that personal information is accurate, complete and up-to-date at the time of use. Anyone is invited to communicate one or more changes by writing a message to the Fondation André Boudreau or by contacting it at the coordinates indicated in the “How to contact us” section.

SECURITY MEASURES

Personal information is protected by security measures appropriate to the circumstances. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We therefore cannot ensure or warrant the security of any information you transmit or provide to us and you do so at your own risk. We also cannot guarantee that such information will not be accessed, obtained, disclosed, modified or destroyed as a result of violation of our physical, technical or administrative safeguards. If you have reason to believe that personal information has been compromised, please contact us using the contact information listed under “How to Contact Us”.

If there is a confidentiality incident affecting your personal information, we undertake to notify you as soon as possible following our knowledge of this incident. We will take reasonable measures to reduce the risk of harm being caused and to prevent new incidents of the same nature from occurring.

RECEIVING AND PROCESSING OF COMPLAINTS REGARDING NON-COMPLIANCE WITH THE PRINCIPLES

HOW TO COMMUNICATE WITH US?

To ask questions, make comments or complain about this Privacy and Personal Information Protection Policy, contact the Fondation André-Boudreau:

You must address your complaint by writing a message to the attention of Lucie Martineau, General Manager, by:

Email: info@fondationandreboudreau.com

Telephone: 450-848-5348
Mail: 148, rue Castonguay, Saint-Jérôme, Quebec, J7Y 2J2

* Upon request, a complaint filing template will be sent to you.

YOUR RESPONSIBILITIES AS DONORS

• You ensure that you consent or not to the transmission of personal information so that the Fondation André Boudreau complies with the provisions of the Act respecting access to documents held by public bodies and the protection of personal information.

RECORD RETENTION AND DESTRUCTION POLICY

1.Objective

The purpose of this policy is to provide procedures for closing, retaining and destroying client records maintained by La Fondation André-Boudreau.

2. Definitions

2.1 In this policy:

“File Closing Date” means the date on which the person in charge of a file has determined that the file is closed and from which he determines the destruction of the file.

“Record Destruction Date” means the date from which a Record is destroyed.

3. Examine and close the file

3.1 The Fondation André-Boudreau appoints a person responsible for the application of this policy. Failing this, the Executive Director of La Fondation André-Boudreau is responsible for the application of this policy.

3.2 When a file is completed, the person in charge of the file determines the date of closure of the file and its date of destruction. For records concerning donors and potential donors, it is agreed that the record must be destroyed after ten (10) years from the date of his last donation or his last consent to the use of his personal information, the most recent date taking precedence.

3.3 Prior to closing the file and sending a physical document or other asset associated with the file to an external storage site or shredding service, the case officer must take steps to remove from the file hard copies of documents that have been imaged or otherwise saved in the electronic library of La Fondation André-Boudreau.

3.4 The Fondation André-Boudreau keeps registers identifying closed files, including the closing date and, where applicable, the date of destruction.

4. Retention of closed files

4.1 Closed and undestroyed records are stored in a physical location to maintain the confidentiality of data subjects and to protect them from damage or loss. They can also be kept on the following computer medium of The Fondation André-Boudreau.

5. Destruction of records

5.1 When the person in charge of the file closes the file and if the file is ready for destruction (see article below), the date of destruction is determined according to the standard of The Fondation André-Boudreau as defined in article 5.2 at unless the Case Officer determines that another destruction date would be more appropriate.

5.2 The Fondation André-Boudreau keeps files closed mainly to satisfy concerns about risk management. Consequently, it is prudent to keep the file closed for a period determined according to the legal requirements that would be required.

5.3 The date of destruction shall be suspended in the following cases relating directly or indirectly to:

a) an actual or potential claim against La Fondation André-Boudreau;

(b) a request for the disclosure of information concerning the file or donor concerned;

c) Government Audits and Investigations. This can be ordered by the case officer.

5.4 The date for the destruction of records can be postponed at any time if necessary (for example, if a new consent is granted in the meantime).

5.5 This policy shall be applied in a manner that ensures the maintenance of the confidentiality of personal information and compliance with applicable federal and provincial laws relating to the protection of personal information.

5.6 The Fondation André-Boudreau maintains a register of destroyed files which includes the name of the donor, the file number, the date the file was closed, the date the file was destroyed and the name of the person in charge of the file.

The Fondation André-Boudreau proceeds to the destruction of paper files and electronic files, in particular electronic information and data including in particular e-mails, preliminary versions of documents located on a server or a document management system, images of documents or scanned documents, faxes (where a hard copy does not exist), voicemail, metadata, and other case-related information or data that is saved and stored in electronic format (e.g., on servers, magnetic media, magneto-optical systems, compact discs, DVDs).

COMPLAINTS POLICY

This policy aims to ensure adequate, uniform and diligent processing of complaints. It is intended for anyone dissatisfied with the processing of their personal information.

POLICY PURPOSE

The complaints handling policy aims to establish a fair and transparent procedure to handle complaints received by La Fondation André-Boudreau. It also aims to support the quality of services and to offer everyone the opportunity to express their dissatisfaction.

This document governs the receipt of complaints, the transmission of the acknowledgment of receipt, the creation of the complaint file and the compilation of the complaints received, and this, with a view to listening to the clientele and continuous improvement.

RESPONSIBLE

The person responsible for applying the policy is Ms. Lucie Martineau, General Manager of La Fondation André-Boudreau. She acts as a respondent and ensures that staff are properly trained in this regard. The manager must also provide employees with all the information necessary to comply with this policy.

The main functions of the manager are:

• Ensure the application of this policy;
• Ensure that an acknowledgment of receipt is sent to the complainant;
• Investigate the claims made by the complainant;
• Respond to complainant.

COMPLAINT

For the purposes of applying the policy, a complaint constitutes the expression of at least one of the following three elements:

• Dissatisfaction with La Fondation André-Boudreau by an individual who feels wronged;
• Damage suffered as a result of an event, situation, act or omission with respect to the provision of the service provided by La Fondation André-Boudreau;
• The claim for corrective action.

Does not constitute a complaint, any informal approach aimed at correcting a particular problem, insofar as the problem is dealt with within the framework of the regular activities of the Fondation André-Boudreau and without a written complaint having been filed by an individual.

RECEIPT OF THE COMPLAINT

Individuals wishing to file a complaint must do so in writing to the following email address:

info@fondationandreboudreau.com

The communication must indicate the following:

• Complainant’s name;
• His address;
• His telephone number;
• His email or fax number, if applicable;
• Capacity of the complainant: in his own name or as a representative;
• Grounds for complaint submitted.

All complaints are treated confidentially. An anonymous complaint is considered not received.

Any member of the board of directors or any person who acts in the name or on behalf of The Fondation André-Boudreau and who receives a complaint must forward it, upon receipt, to the person responsible for applying the policy. .

Any representative of The Fondation André-Boudreau who receives a verbal complaint must inform the complainant of this policy and invite him to send the Fondation André-Boudreau his complaint in writing.

The manager must acknowledge receipt of the complaint within 5 working days of receipt.

The acknowledgment must contain the following information:

• A description of the complaint received, specifying the reproach made to La Fondation André-Boudreau, the prejudice or the corrective measure requested;
• The name and contact details of the person responsible for handling the complaint;
• In the case of an incomplete complaint, a notice containing a request for additional information to which the complainant must respond within a set deadline, i.e. 5 working days, failing which the complaint is deemed abandoned;
• The complaints handling policy.
• CREATION OF THE COMPLAINT FILE

In order to ensure fair and transparent treatment, each complaint is the subject of a separate file. The file contains the following items:

• The written complaint;
• The result of the complaint handling process (analysis and related documents);
• The final response to the complainant in writing and reasoned.

PROCESSING A COMPLAINT

The process for processing a complaint is initiated within 5 working days of its receipt.

The processing of the complaint must be carried out within a reasonable time, that is, within 30 days of receipt of all the information necessary for its study. In the exceptional event that a complaint cannot be processed within the time limit, the complainant must be informed of the reasons for the delay and of the steps taken by La Fondation André-Boudreau to date in the processing of their complaint. He must also be notified of the time within which the decision will be sent to him.

Once the complaint has been examined and the analysis completed, the manager must send the complainant a final, written and reasoned response.

COMING INTO FORCE

This policy comes into effect on September 20, 2023

FOR ANY QUESTIONS OR COMMENTS CONCERNING THE PROCESSING OF COMPLAINTS, WE INVITE YOU TO COMMUNICATE DIRECTLY WITH THE MANAGER:

LUCIE MARTIENAU, Managing Director

FONDATION ANDRÉ-BOUDREAU

148, rue Castonguay, Saint-Jerome (Quebec) J7Y 2J2

450-848-5348

FOR MORE INFORMATION ON THIS POLICY

LAWS

Act respecting access to documents held by public bodies and the protection of personal information: https://www.legisquebec.gouv.qc.ca/fr/document/lc/A-2.1

Act respecting the legal framework for information technology: https://www.legisquebec.gouv.qc.ca/fr/document/lc/C-1.1

WEBSITES

Information Access Commission: https://www.cai.gouv.qc.ca

Secretariat for the Reform of Democratic Institutions and Access to Information: https://www.quebec.ca/gouvernement/ministeres-et-organisations/institutions-democratique-acces-information-laicite