Supply Chain Trustees Inc. recognizes the importance of strengthening governance in the protection of personal information we hold. This Privacy Policy aims to provide you with clear information regarding the types of personal information we collect, how we use them, to whom we disclose them, as well as the purposes and reasons for this collection, use, and disclosure. We want to inform you of your rights concerning your privacy and its protection.
1. DEFINITIONS
Personal information refers to information about an individual that allows for their identification. It is confidential and, except for exceptions, cannot be disclosed without the consent of the individual concerned. Within the Governance Framework, unless the context indicates otherwise, the following terms are defined as follows:
- Anonymize or generalize personal information: The process by which information about an individual becomes such that it is no longer possible to identify them directly or indirectly.
- Consent: The authorization given by the individual who owns the personal information to collect and use their personal data. Consent must be explicit, freely given, informed, specific, and the duration of its use must be clearly defined.
- Sensitive personal information: Personal information is considered sensitive when, by its nature or the context of its use or disclosure, it creates high expectations of privacy. This includes medical, biometric, genetic, or financial information, as well as data regarding sexual orientation, religious beliefs, or ethnic origin.
- Third party: Any natural or legal person external to the Supply Chain Trustees Inc. who is not part of our community of clients or staff. Third parties may include research centers, suppliers, subcontractors, partners, consultants, external organizations, etc.
2. SCOPE
This Privacy Policy (hereinafter referred to as the “Privacy Policy”), in addition to the governance framework on personal information, applies to all your interactions with us. This includes, among others, your visit to our website at www.supplychaintrustees.com , your various subscriptions to our newsletters or your job application within our organization.
Within Supply Chain Trustees Inc., we only collect personal information that is strictly necessary for the fulfillment of our missions. We take measures to ensure that the personal information we collect is appropriate, relevant, not excessive, and used only for specific purposes.
Upon request, we also provide the individual concerned with additional information, including the personal information collected from them, the categories of persons who have access to this data within Supply Chain Trustees Inc., the duration of retention of this information, and the contact information of the person responsible for the protection of personal information.
3. COLLECTION AND USE OF PERSONAL INFORMATION
Supply Chain Trustees Inc. is committed to collecting only the personal information that is strictly necessary for its activities and to respect your privacy. The types of personal information we collect include:
- Contact Information: This may include your name, personal and/or professional email address, and phone number. We typically obtain this information directly from you, such as when you fill out our contact form to schedule a consultation with one of our consultants or apply for a position within our organization.
- Information from Surveys: When you register as a user on our platform or participate in our surveys, we may collect information such as your organization’s name, industry sector, company size, region, your job position, and other relevant information.
- Financial Information: The banking information we collect is primarily related to settling various invoices.
- Employment-Related Information: When you apply for a position within our organization, we may collect information about your work experience and education. This information is used in the recruitment process. We may also obtain personal information from third parties during reference checks or pre-employment background checks.
- Online Activity-Related Information: We may collect information such as IP addresses (and their associated locations) and pages visited on our website. This collection is typically done using cookies or similar technologies. We treat this information as personal data when applicable.
For the use of your personal information, we commit to using your personal information only for the purposes for which it was collected, as described in this section. However, there may be instances where we use your personal information for other purposes for which we will seek your prior consent.
4. PROTECTION OF PERSONAL INFORMATION
At Supply Chain Trustees Inc., we implement appropriate and reasonable security measures to protect personal information against loss, theft, unauthorized access, disclosure, copying, illegal use, or modification. Only members of our staff who have a legitimate need to access personal information as part of their job responsibilities are authorized to do so. Managers are responsible for supervising and implementing personal information protection policies within their respective teams.
All third parties who have access to the personal information held by Supply Chain Trustees Inc. are informed of our Policy, Management Framework, Governance Framework, as well as other applicable policies and processes to ensure the security and protection of personal information. All third parties are required to commit in writing to adhere to these policies, frameworks, processes, and applicable laws.
5. DISCLOSURE OF PERSONAL INFORMATION
Supply Chain Trustees Inc. may share personal information without the consent of the individual concerned when required by Law 25 or as part of legal investigations. Additionally, this information may be shared with internal staff who need it for their duties. When shared with third parties or service providers, contracts or written agreements are used to ensure the confidentiality and appropriate use of this data in accordance with our Governance Framework and applicable laws. Personal information may also be disclosed for research, studies, or statistical purposes, subject to conditions prescribed by Law 25, with appropriate record-keeping by the person responsible for the protection of personal information (PRP). Supply Chain Trustees Inc. may also share personal information with the valid consent of the individual concerned.
6. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
At Supply Chain Trustees Inc., we retain the personal information we hold for the period necessary to achieve the purposes for which it was collected, in accordance with our retention schedule, unless legal or regulatory authorization or requirements dictate otherwise.
As a general rule, once the objectives for which personal information was collected or used have been achieved, we proceed to its irreversible destruction or anonymization for use in public interest purposes.
7. REQUEST FOR ACCESS OR RECTIFICATION OF PERSONAL INFORMATION
- Request for Access to Personal Information: Every individual has the right to access their personal information held by Supply Chain Trustees Inc., except in cases provided by the Access to Information Act. To be valid, the request must be submitted in writing by the concerned individual or their authorized representative, providing proof of identity. The request must contain sufficiently precise details to be processed.
- Request for Rectification: If an individual discovers that their personal information in a file is inaccurate, incomplete, ambiguous, or collected, communicated, or stored in a manner unauthorized by the Access to Information Act, they may request rectification. This request must be submitted in writing by the individual concerned or their authorized representative, with precise details for processing. If the rectification request is accepted, Supply Chain Trustees Inc. will provide a copy of the changes made to the personal information or a certificate of its deletion, as appropriate.
8. COOKIES AND OTHER TECHNOLOGIES
We use cookies to collect certain technical information when you visit our website. This information does not directly identify you and is used to improve the website’s content and ease of access. This information may be stored on the servers of our service providers located outside of Ontario and Canada and may therefore be subject to the laws of those countries, including any laws permitting government authorities to access it. We use Google Analytics, which allows us to see information about user activities, including pages visited, sources, and time spent on our website. This information is anonymized and presented in numerical form, meaning it cannot be used to identify the user. You can disable the use of Google Analytics by visiting the Google Analytics opt-out page.
9. IMPORTANT NOTES
All staff members, service providers, and third parties are required to comply with this policy starting in January 2025. However, we reserve the right to periodically update and revise this policy to reflect legislative, regulatory, or organizational developments concerning the protection of personal information.
If you have any questions or comments about how we manage your personal information, please feel free to contact our personal information protection officer at the following address: info@supplychaintrustees.com.