CAPSANA'S POLICY ON THE PROTECTION OF PERSONAL INFORMATION
This document explains the Policy on the protection of personal information as applied by Capsana, its employees and representatives.
In its normal course of business, Capsana collects personal information about its employees, its clients and their employees, participants in its various campaigns and its subcontractors. All personal information collected respects the general laws and regulations that apply to confidentiality and/or is subject to Capsana's policy for the protection of personal information. Capsana is committed to ensuring the accuracy, confidentiality, security and private nature of the personal information it collects by stringently applying its policy and ensuring that it is respected by all of its employees and representatives.
The directors of business units and departments are responsible for ensuring that the policy is respected and taking the appropriate measures to facilitate its application on a day-to-day basis. In cases where the policy is not respected, they will take appropriate measures to correct the situation.
Determining how the collected information will be used
At the time it collects personal information, Capsana will specify in a document or an agreement how the information will be used and will provide written notification to the people from whom the information is being collected. The collection of information is limited to the purposes for which it was authorized. Otherwise, Capsana will obtain additional consent as required.
Capsana will inform and obtain consent from all persons concerned before it collects, uses or transmits personal information, unless it is inappropriate to do so under applicable laws.
Limits on the information collected
Capsana will take measures to ensure that only information needed for the purpose identified will be collected. The personal information will not be transmitted or used for any other purpose other than that for which consent was obtained.
Subject to applicable laws, Capsana may keep personal information on file for as long as necessary for pre-established purposes, even if the person is no longer an employee, client or participant.
Capsana's employees are required to inform the directors of business units or departments of any changes to information in their file. Clients, participants and subcontractors are also requested to provide any changes to information previously submitted to Capsana. Capsana will update personal information as soon as it is received from employees, clients, participants and subcontractors, when it is relevant to do so.
Personal information is protected by security measures that are commensurate with the degree of sensitivity of the information. Security measures protect personal information against loss or theft and against unauthorized consultation, transmission, copying, use or modification.
The nature of the security measures will vary depending on the degree of sensitivity of the personal information, the quantity, distribution and format of the information, as well as how it is conserved. Various methods may be used, such as rendering the information anonymous, restricting access, applying password protection or any other means judged to be appropriate under the circumstances.
This policy is distributed to all managers, administrators, employees and contributors and to any person who requests it.
Access to personal information
Capsana will inform anyone who inquires as to the existence of personal information how the information is used and the fact that it has been provided to third parties, and will allow them to consult it. It will be possible to confirm the accuracy and comprehensiveness of the information and to make corrections if required. Complaints will be handled according to the appropriate procedures and within a reasonable timeframe. This policy will be upgraded periodically.