Privacy Policy

Fibre Argenteuil attaches great importance to the respect of privacy and the protection of personal information. To ensure the security and confidentiality of the personal information it holds, Fibre Argenteuil has created a Privacy and Personal Information Protection Policy. This policy seeks to establish responsible and transparent practices with respect to the management of personal information in our relations with our clients and our employees. This policy has been prepared in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) R.S.C. 2000, c.5 and the Telecommunications Act, R.S.C. 1993, c. 38. Personal information is required when entering into service agreements with our clients and when hiring the personnel needed for our operations.

Accountability

Fibre Argenteuil is responsible for personal information under its control. A Privacy Officer is accountable for the company’s compliance with the principles set out below.
At the time of publication, this person is:

Denis Huberdeau, General Manager
Fibre Argenteuil Inc.
412 Rue Principale
Lachute (Québec) J8H 2E5
info@fibreargenteuil.ca

SECTION 1

1.0 Consent to Collection, Use or Disclosure of Personal Information – Principle 1

1.1 When you become a Fibre Argenteuil Inc. subscriber, the personal information you disclose to us allows us to provide you with the products and services best suited to your needs. We only collect personal information that is strictly necessary for the provision of our services. You may choose not to provide us with your personal information. However, if you make this choice, we may not be able to provide you with the service or information you have requested.
1.2 When dealing with certain legal, security or emergency issues, Fibre Argenteuil Inc. may be required by law to disclose your personal information without seeking or obtaining your consent.
1.3 Unless you give your express consent or disclosure is required by law or legal authorities, none of the personal information that Fibre Argenteuil Inc. (including its agents) has about you may be communicated to anyone other than:
1.3.1 yourself;
1.3.2 a person who, in the reasonable judgment of Fibre Argenteuil, is seeking to obtain information while acting as your agent;
1.3.3 a telephone company other than Fibre Argenteuil, provided that the information is required for the efficient and cost-effective provision of telephone service, that the disclosure is made on a confidential basis and that the information will be used only for that purpose;
1.3.4 a company engaged in providing you with services related to the telephone service or telephone directories, provided that the information is required for that purpose, disclosure is made on a confidential basis and the information is used only for that purpose.
1.4 At Fibre Argenteuil Inc., we use your personal information for certain purposes, such as:
1.4.1 approving your application for subscription to the services of Fibre Argenteuil Inc.;
1.4.2 maintaining communication with you;
1.4.3 keeping you informed of current offers and promotions on our products and services;
1.4.4 detecting and preventing possible fraud or the illegal, inadequate or inappropriate use of our products and services;
1.4.5 evaluating your degree of satisfaction with our products and services;
1.4.6 complying with legal obligations;
1.4.7 the collection of a client’s account by an agent retained by Fibre Argenteuil Inc.
1.5 Note that under no circumstances will we sell information about our clients to anyone, nor do we divulge information about our clients to organizations, including our affiliates, except, in the latter case: (i) with your consent solely for the purpose of enabling our affiliates to offer you their own products or services; or (ii) if the affiliate is acting as our agent.

2.0 Statement of Purpose – Principle 2

2.1 The purpose of the Privacy and Personal Information Protection Policy is to protect our clients and employees in the provision of our services.

3.0 Limiting Collection – Principle 3

3.1 Fibre Argenteuil Inc. collects most personal information directly from the person concerned, but may sometimes collect it from other sources where permitted by law. For example, Fibre Argenteuil Inc. may collect personal information from credit bureaus or from third parties who are permitted to disclose the information.

4.0 Retention of personal information – Principle 4

4.1 Fibre Argenteuil Inc. retains personal information only as long as necessary or appropriate for the identified purposes or as required by law. As appropriate, where personal information has been used to make a decision about a person whose personal information is held by Fibre Argenteuil Inc., Fibre Argenteuil Inc. will retain an account of the reasons for the decision for a reasonable period of time to allow the person access to the reasons for the decision.
4.2 Fibre Argenteuil Inc. implements reasonable and systematic control measures, schedules and practices for retaining and disposing of personal information and files that are no longer necessary or relevant to their intended purposes or that are not longer required by law. This information is destroyed, deleted or made anonymous.
4.3 Retention of log files: Fibre Argenteuil Inc. retains, by default, log files for a period of 90 days, unless required by law to retain the data for a longer period, for example, in the case of a copyright infringement notice or a court warrant. In such cases, Fibre Argenteuil Inc. must extend the retention time for log files without obtaining your consent.

5.0 Accuracy – Principle 5

5.1 Fibre Argenteuil Inc. will update personal information when necessary. Any person whose personal information is held by Fibre Argenteuil may challenge the accuracy and completeness of the information and have it amended as needed.
5.2 Fibre Argenteuil Inc. will promptly correct or complete any personal information that is deemed to be inaccurate or incomplete. Any unresolved dispute with respect to the accuracy or completeness of personal information must be recorded in the file of the person in question. If applicable, Fibre Argenteuil Inc. will communicate all modified personal information to third parties who have access to this personal information or inform them that unresolved disputes exist.

6.0 Safeguards – Principle 6

6.1 Fibre Argenteuil Inc. will ensure that your personal information is protected against unauthorized access or any other form of misuse by maintaining industry standard security safeguards.
6.2 Electronic data containing personal information is restricted to authorized users only.
6.3 All Fibre Argenteuil Inc. employees who have access to personal information are required, as a condition of employment, to respect the confidential nature of such personal information.

7.0 Transparency – Principle 7

7.1 Upon request, Fibre Argenteuil Inc. will make available to individuals a description of the type of personal information it may hold about them and specific information about its policies and practices relating to the management of personal information.

8.0 Access to personal information by clients and employees – Principle 8

8.1 Subject to the exceptions provided for in the Act, Fibre Argenteuil Inc. will, upon request, inform any person of the existence of personal information about them, the use made of the information, and whether it has been disclosed to third parties. Subject to the exceptions provided for in the Act, Fibre Argenteuil Inc. will, upon request, allow the person concerned to consult the personal information contained in their file.
Personal information must be provided in an understandable way, within a reasonable delay and at little or no cost to the person in question. Between the submission of a request for access and the release of personal information to the person concerned, Fibre Argenteuil Inc. may revise the content of the files for the sole purpose of ensuring that personal information concerning other persons is not also disclosed. Any changes made at this time will be done in compliance with the Act. Under certain circumstances, it may not be possible for Fibre Argenteuil Inc. to provide a person with access to all the personal information that Fibre Argenteuil
Inc. holds about them. For example, Fibre Argenteuil Inc. is unable to provide access to information if doing so would reveal confidential business information, if the information is protected by attorney-client privilege, if the information was obtained in the course of a formal dispute resolution process, or if the information was gathered during an inquiry into a breach of contract or violation of a federal or provincial law. Upon request, Fibre Argenteuil Inc. will specify the reason for refusing access to personal information.
8.2 In providing an account of disclosure of personal information, Fibre Argenteuil Inc. will provide a list of third parties to whom it may have disclosed personal information about a person, when it is not possible to provide a specific list.
To ensure the protection of personal information, a person may be required to provide adequate identification in order for Fibre Argenteuil Inc. to provide an
account of the existence, use and disclosure of personal information and to allow access to their file

9.0 Complaints for non-compliance with the principles of the Policy

9.1 Any person may file a complaint regarding non-compliance with the principles of this Policy by contacting the person accountable for compliance with Fibre Argenteuil’s Policy.
9.2 Fibre Argenteuil Inc. will investigate all complaints regarding compliance with the Policy. If a complaint is deemed valid, Fibre Argenteuil Inc. will take appropriate measures, including amending the Policy and its practices as necessary.
If a complainant is not satisfied with the decision of Fibre Argenteuil’s Privacy Officer, he or she may contact the office of the Privacy Commissioner of Canada, 112 rue Kent, Ottawa, Ontario, K1A 1H3.

SECTION 2

1.0 Client Information Collected, Retained, Disclosed and Destroyed

1.1 Information Collected
Fibre Argenteuil collects your personal information in order to provide you with telecommunications services. The following is a list of the information collected:
1.1.1 Identification information
1.1.1.1 First and last name;
1.1.1.2 Email address, postal address and address where services are delivered;
1.1.1.3 Primary and secondary telephone numbers.
1.1.2 Authentication information
1.1.2.1 Fibre Argenteuil account number;
1.1.2.2 Username and password;
1.1.2.3 Answers to security questions.
1.1.3 Information about your communications with us
1.1.3.1 Summary of your appointments;
1.1.3.2 Log, history, recording, and summary of our communications with you;
1.1.3.3 Written communications by email or chat;
1.1.3.4 Responses to surveys or consultations;
1.1.3.5 Video recording of security cameras in and around our office.
1.1.4 Information about your use of our website and application
1.1.4.1 Information collected through cookies;
1.1.4.2 Browsing preferences (language, etc.);
1.1.4.3 Clickstream data and browsing history on our website and application;
1.1.4.4 IP address;
1.1.4.5 Information about your device, operating system or browser.
1.1.5 Information about your products and services
1.1.5.1 Information on invoices and missed payments;
1.1.5.2 Information on balances and deposits;
1.1.5.3 Information related to your transactions and operations (banking information, contract number, transaction date and amount, description, etc.);
1.1.5.4 Information on preauthorized payments;
1.1.5.5 Communications related to outages, maintenance, modifications to your services.
1.1.6 Other information to comply with our legal obligations Employees
1.1.6.1 Social insurance number (SIN);
1.1.6.2 Driver’s license;
1.1.6.3 Banking information for payroll deposits.

1.2 Information Retained
We retain all the information listed in the previous point for the purpose of identifying you, notifying you of any changes and sending you important information.
Information is stored on the following media:
1.2.1 Paper
1.2.1.1 Original;
1.2.1.2 Copies.
1.2.2 Digital storage
1.2.2.1 Computer hard drive, etc.
1.2.3 Cloud storage
1.2.3.1 Fibre Argenteuil’s servers;
1.2.3.2 The servers of Fibre Argenteuil’s suppliers.
1.2.4 Equipment with hard drives
1.2.4.1 Computers;
1.2.4.2 Servers.
1.3 Information Disclosed
The information collected may be disclosed to:
1.3.1 The client;
1.3.2 Authorized account users;
1.3.3 Another telecommunication company, to ensure the effectiveness and efficiency of telecommunications services;
1.3.4 A company involved in providing telecommunications or directoryservices;
1.3.5 A financial institution in order to set up a pre-authorized payment;
1.3.6 A third party for the design, improvement, marketing or provision of a Fibre Argenteuil product or service;
1.3.7 An agent retained by Fibre Argenteuil to collect a client account;
1.3.8 Credit card providers and credit bureaus;
1.3.9 A person who, in the opinion of Fibre Argenteuil, is requesting the information as an agent of the client;
1.3.10 One or more third parties, where the client consents to the disclosure or where the disclosure is required by law.

1.4 Information Destroyed
We retain personal information for as long as is reasonably necessary or relevant to its intended purposes or as required by law. We may retain certain personal information for an extended period of time, even when you are no longer our client (such as for tax and financial record keeping, security, fraud prevention and business management purposes). When personal information is no longer reasonably necessary or relevant to its intended purposes or is no longer required by law, it is destroyed, deleted or made anonymous. Once the retention period has expired, we ensure that your personal information is destroyed or made anonymous. While destruction is a final and irreversible disposal process, anonymization means that your personal information is irreversibly altered so that it can no longer directly or indirectly identify you. Destruction and anonymization are carried out in a safe and secure manner in accordance with applicable best practices.

2.0 Data Retention Process

We collect personal information during telephone calls, email exchanges and on social networking sites, as well as during in-person visits to the Fibre Argenteuil office, for the purposes listed in Point 1.1 of this section. Telephone calls are recorded in a secure file on the Fibre Argenteuil server. Only authorized persons have access to this file.

Email messages are stored in the Outlook folder. Conversations on social networks are stored on platforms such as Meta. Fibre Argenteuil’s account is protected by access codes and only authorized persons have access to it.
The information collected (see Point 1.1 of this section) is entered in software applications used to open new customer accounts, to provide services, for billing, and other purposes. This information is stored on cloud storage as stated in Point 1.2 of this section. Access to these software applications is restricted to authorized persons who are granted different levels of security depending on the tasks to be completed.

As new information is provided to us, we update existing records. Once the retention period for personal information has ended, the information is destroyed.

3.0 Data Destruction Process

Once the retention period for personal information has ended, we proceed to destroy the data.
3.1 Paper
3.1.1 Shredding, preferably cross-cut shredding.
3.2 Digital storage media to be reused or recycled
3.2.1 Formatting, rewriting, digital shredding.
3.3 Equipment with hard drives
3.3.1 Overwriting of information on the hard drive or removal and destruction of hard drive when the equipment is replaced.
3.3.2 Machines with hard drives
3.4 Cloud storage
3.4.1 Erasure of data and purging of the dataset.

4.0 Confidentiality Incident

A confidentiality incident can be described as the unauthorized disclosure of or access to personal information, or the loss of personal information, as a result of a breach of an organization’s security measures or failure to implement those measures. A confidentiality incident may also be defined as follows:

Access to personal information that is not authorized by law;
Use of personal information that is not authorized by law;
Disclosure of personal information that is not authorized by law; or
Loss of personal information or any other breach of the protection of such information.

4.1 Procedure for handling confidentiality incidents
4.1.1 Cause to believe that a confidentiality incident has occurred;
4.1.2 Reduce the risk of harm being caused or recurring (immediate mitigation measures);
4.1.3 Establish the circumstances of the incident, identify the personal information, the persons concerned and the problem;
4.1.4 Determine the nature of the harm in collaboration with the Privacy Officer, taking into account:
4.1.4.1 The sensitivity of the information;
4.1.4.2 The anticipated consequences;
4.1.4.3 The likelihood that the information will be used for injurious purposes; If there is no risk of serious harm:
4.1.4.4 Take other mitigation measures to reduce harm and prevent new incidents of the same nature from occurring;
4.1.4.5 Enter the confidentiality incident in the register;
4.1.4.6 Continuously revise the process.
4.1.5 If there is a risk of serious harm, notify:
4.1.5.1 The Commission d’accès à l’information – mandatory;

4.1.5.2 The persons concerned – mandatory, unless the notice would be likely to hamper an investigation conducted by a person or body responsible under the law for the prevention, detection or repression of crime or statutory offences;
4.1.5.3 Any person or body that could reduce the risk – optional (communication of necessary information). The Privacy Officer must record the communication in a register;
4.1.5.4 Take other mitigation measures to reduce harm and prevent new incidents of the same nature from occurring;
4.1.5.5 Enter the confidentiality incident in the register;
4.1.5.6 Continuously revise the process.
4.2 Persons notified in the event of a confidentiality incident
4.2.1 Fibre Argenteuil’s Privacy Officer;
4.2.2 The Commission d’accès à l’information;
4.2.3 The persons concerned, unless the notice would be likely to hamper an investigation conducted by a person or body responsible under the law for the prevention, detection or repression of crime or statutory offences.
4.3 Timeframe for notification in the event of a confidentiality incident Any breach of personal information will be reported to Fibre Argenteuil’s Privacy Officer. Notification of a confidentiality incident will be made promptly and as soon as possible after becoming aware of the incident.

SECTION 3

Register of confidentiality incidents and notification process A register of confidentiality incidents must be maintained in order to document all events that affect or could affect the confidentiality and security of the personal information held by Fibre Argenteuil. Being an essential monitoring tool, the register must be as detailed as possible: in particular, it must include a description of the facts relating to each incident, the causes and consequences of the breach, as well as the corrective measures taken to remedy the situation so that it does not recur. This documentation is crucial: it is what enables a control authority, such as the Commission d’accès à l’Information (CAI), to verify Fibre Argenteuil’s compliance with the law.
In the event of a confidentiality incident involving personal information, the Fibre Argenteuil team promptly notifies the Privacy Officer and implements the following measures:

Validate and classify the types of personal information affected. Ensure that there is an exhaustive list of our database, file servers and documents that contain personal information;
Ensure that an appropriate and impartial investigation (including digital forensics if necessary) is initiated, conducted, documented and completed;
Identify vulnerabilities and the solutions to be implemented to correct them, and carry out tests to ensure that the corrective measures are effective;
Report findings to senior management;
Coordinate with the relevant authorities as needed;
Coordinate internal and external communications;
Ensure that the persons concerned are properly informed, if necessary.

The response team meets for every breach of personal information (actual or alleged). If the confidentiality incident in question involves a breach of personal information, the response team must be headed by the Team Leader.
When the confidentiality incident (actual or alleged) involves personal information that is processed on behalf of a third-party processor (data controller), Fibre Argenteuil’s
Privacy Officer must, as a subcontractor, report the incident to the data controller without undue delay.
The Privacy Officer will send a notice to the third-party data controller which shall include the following:

A description of the nature of the breach;
The categories of personal information affected;
Approximate number of people concerned;
Name and contact details of the Team Leader / Privacy Officer responsible for the data breach response;
Consequences of the breach of personal information;
Measures taken to rectify the breach of personal information;
Any information relating to the confidentiality incident.

When the confidentiality incident (actual or alleged) concerns personal information processed by Fibre Argenteuil and Fibre Argenteuil is acting as data controller, the following actions will be taken by the Privacy Officer:

Fibre Argenteuil will determine whether the confidentiality incident should be reported to the appropriate supervisory authority.
In order to establish the risk to the rights and freedoms of the persons concerned, the Privacy Officer will assess the risk of serious harm to the persons affected by the confidentiality incident.
If the confidentiality incident is not likely to result in a risk of serious harm being caused to the persons concerned, no notice is required. However, the confidentiality incident will be documented and recorded in Fibre Argenteuil’s register of confidentiality incidents.
The appropriate supervisory authority will be notified without undue delay if the confidentiality incident is likely to cause serious harm to the persons affected by the incident. The reasons for any delay should be communicated to the appropriate supervisory authority.

The register of confidentiality incidents records the following information:

Date or time period when Fibre Argenteuil became aware of the incident;
Date or time period when the incident occurred;
Description of the personal information that was compromised or the reasons why it is impossible to provide such a description;
Description of the circumstances of the incident;
Number of persons concerned by the incident or, if that is not known, the approximate number;
A description of the reasons that led Fibre Argenteuil to believe that the confidentiality incident could pose a risk of serious harm;
If the confidentiality incident presents a risk of serious harm, the transmission dates of the notices sent to the CAI and the persons whose personal information has been compromised and a mention of the obligation to give public notice;
A description of the measures taken following the confidentiality incident in order to reduce the risk of harm.

SECTION 4

If a client or employee feels that Fibre Argenteuil has not respected the principles set out in its policies, he or she may file a written complaint with the person accountable for compliance with the Privacy and Personal Information Protection Policy:
Denis Huberdeau, General Manager
Fibre Argenteuil Inc.
412 Rue Principale
Lachute (Québec) J8H 2E5
info@fibreargenteuil.ca
Fibre Argenteuil will investigate all complaints regarding compliance with its policies and will take appropriate action, including, if necessary, amending its policies or practices. In all cases, the person who submitted the complaint will be informed of the outcome of the complaint investigation.

If you are not satisfied with Fibre Argenteuil’s decision following a complaint, you may contact the Commission d’accès à l’information by phone at 1 888-528-7741 or by email at cai.communications@cai.gouv.qc.ca.