The Quebec Mineral Exploration Association (QMEA) is a non-profit legal entity under Quebec law that processes personal information as part of its activities. This policy aims to ensure the protection of personal information and to frame how QMEA collects, uses, discloses, retains, and destroys or otherwise manages it. Additionally, it aims to inform any interested individual about how QMEA handles their personal information. It also addresses the processing of personal information collected by QMEA through technological means.
This policy applies to QMEA, including its directors, employees, consultants, volunteers, and any person otherwise providing services on behalf of QMEA. It also applies to QMEA’s website, as well as websites (coreplatform.ca, libres.aemq.org, exploabitibi.aemq.org, xplor.aemq.org et membre.aemq.org) controlled and maintained by QMEA. It encompasses all types of personal information managed by QMEA, whether concerning its clients, potential or current, consultants, employees, members, or any other individuals (such as visitors to its websites or others).
Personal Information: Refers to an individual and enables their direct or indirect identification. For example, it could include a person’s name, address, email address, phone number, gender, or banking information, as well as information about their health, ethnic origin, language, etc.
Sensitive Personal Information: Refers to any personal information that, due to its nature, especially medical, biometric, or otherwise intimate, or because of its use or disclosure, raises a high degree of reasonable privacy expectation.
Business Contact Information: Refers to personal information concerning a person’s role within a company, such as their name, title, and function, as well as their business postal address, email address, and phone number.
Privacy Incident: Refers to any unauthorized consultation, use, or disclosure of personal information under the law, or any loss or other breach of the protection of such information.
Privacy Officer: Ensures compliance with applicable legislation regarding the protection of personal information. The officer must approve policies and practices governing personal information governance. Specifically, this person is responsible for implementing this policy and ensuring it is known, understood, and enforced.
In general, a person’s business or professional contact information does not constitute personal information, for example, a person’s name, title, address, email address, or work phone number.
Specifically, under the Quebec Private Sector Personal Information Protection Act, as of September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to a person’s information related to their role in a company, such as their name, title, function, as well as their work address, email address, and phone number. These same paragraphs also do not apply to personal information that is public under the law, effective from the date of this policy.
During its activities, QMEA may collect various types of information for different purposes. The types of information that QMEA might collect, their use (or intended purpose), and how information is collected are outlined in Appendix A of this policy.
QMEA will also inform affected individuals, at the time of collecting personal information, of any other information collected, the purposes for which they are collected, and the means of collection, in addition to other required information as mandated by law.
QMEA applies the following general principles regarding the collection, use, and disclosure of personal information:
In certain situations, QMEA may also collect personal information from third parties without the consent of the individual concerned if it has a serious and legitimate interest to do so and a) if the collection is in the interest of the individual and it is not possible to collect it from them in a timely manner, or b) if this collection is necessary to ensure that the information is accurate.
Additionally, QMEA may collect personal information indirectly, including by:
This collection through third parties may be necessary to use certain services or programs, or to otherwise engage with QMEA. When required, QMEA will obtain the individual’s consent at the appropriate time.
Cookies are data files transmitted to a visitor’s computer by their web browser when they visit a website and can serve various purposes.
Websites controlled by QMEA use cookies for various purposes, including:
Websites controlled by QMEA use the following types of cookies:
Some cookies may be disabled by default, and visitors may choose to enable or disable these functions when accessing QMEA websites.
It is also possible to enable or disable the use of cookies by changing preferences in the settings of the browser used.
Some QMEA websites use Google Analytics to enable continuous improvement. Google Analytics allows analysis of how a visitor interacts with an QMEA website. Google Analytics uses cookies to generate statistical reports on visitor behavior on these websites and the content viewed.
Information from Google Analytics will never be shared by QMEA with third parties.
It is possible to install a browser add-on to disable Google Analytics.
QMEA also collects personal information through technological means such as web forms integrated into an QMEA-controlled website (e.g., its contact form, membership form to become a member, form to subscribe to the newsletter and seminars), online questionnaires on its platforms and applications, as well as other form platforms or tools (e.g., Microsoft Forms).
Unless a minimum retention period is required by applicable law or regulation, QMEA will only retain personal information for the time necessary to achieve the purposes for which it was collected.
Personal information used by QMEA to decide regarding an individual must be retained for a period of at least one year following the decision in question or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, for example, the circumstances of an end of employment.
At the end of the retention period or when personal information is no longer necessary, QMEA will ensure:
The destruction of information by QMEA must be done securely to ensure the protection of this information.
This section may be supplemented by any policy or procedure adopted by QMEA concerning the retention and destruction of personal information, if applicable. Please contact QMEA’s privacy officer (as indicated in this policy) for more information.
In general, QMEA is responsible for protecting the personal information it holds. QMEA’s privacy officer is the organization’s general manager. In the absence or inability to act of this officer, the organization’s administration supervisor will perform the functions of the privacy officer.
QMEA staff members with access to personal information or otherwise involved in its management must ensure its protection and comply with this policy.
The roles and responsibilities of QMEA employees throughout the lifecycle of personal information may be specified by any other QMEA policy in this regard, if applicable.
QMEA is committed to implementing reasonable security measures to ensure the protection of the personal information it manages. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium, and sensitivity of the information.
Thus, this means that information that could be considered sensitive (see the definition provided in section 2) must be subject to more stringent security measures and must be better protected.
In particular, and in accordance with what was previously mentioned regarding limited access to personal information, QMEA must implement necessary measures to impose constraints on the rights of use of its information systems so that only employees who need access are authorized to access them.
To assert their access, rectification, or withdrawal of consent rights, the individual concerned must submit a written request to the QMEA’s privacy officer, at the email address indicated in the following section.
Subject to certain legal restrictions, individuals concerned may request access to their personal information held by QMEA and request its correction if it is inaccurate, incomplete, or ambiguous. They may also demand the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name allowing access to this information by technological means be dereferenced when the dissemination of this information violates the law or a court order. They may do the same, or demand that the hyperlink allowing access to this information be reindexed, when certain conditions provided by law are met.
QMEA’s privacy officer must respond in writing to these requests within 30 days of the date of receipt of the request. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In these cases, the response must indicate the remedies under the law and the deadline for exercising them. The officer must assist the requester in understanding the refusal if necessary.
Subject to applicable legal and contractual restrictions, individuals concerned may withdraw their consent to the communication or use of the information collected by QMEA.
They may also ask QMEA what personal information has been collected from them, the categories of persons at QMEA who have access to it, and its retention period.
Any person who wishes to make a complaint regarding the application of this policy or, more generally, regarding the protection of their personal information by QMEA must do so in writing by addressing the QMEA’s privacy officer at the email address indicated in the following section.
The individual must provide their name, contact information, including a telephone number, as well as the subject and reasons for their complaint, giving sufficient details for the complaint to be evaluated by QMEA. If the complaint is not sufficiently precise, the privacy officer may request any additional information he deems necessary to evaluate the complaint.
QMEA undertakes to handle any complaint received confidentially.
Within 30 days of receiving the complaint or upon receipt of any additional information deemed necessary and required by QMEA’s privacy officer to process it.
The officer will evaluate it and provide a reasoned written response via email to the complainant. This evaluation will aim to determine whether the processing of personal information by QMEA complies with this policy, any other policy and practice within the organization, and applicable laws or regulations.
If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons for the extension, the progress of the complaint processing, and the reasonable timeframe needed to provide a definitive response.
QMEA must maintain a separate file for each complaint received. Each file contains the complaint, the analysis and supporting documentation for its evaluation, as well as the response sent to the complainant.
It is also possible to file a complaint with the Commission d’accès à l’information du Québec or any other oversight body responsible for enforcing the law related to the subject of the complaint.
However, QMEA encourages anyone interested to first contact its privacy officer and wait for the completion of the processing by QMEA.
This policy is approved by QMEA’s privacy officer, whose business contact information is as follows:
Privacy Officer:
Alain Poirier
132 Avenue du Lac,
Bureau 203
Rouyn-Noranda, Quebec J9X 4N5
alainpoirier@QMEA.org
For any requests, questions, or comments regarding this policy, please contact the officer by email.
This policy is published on QMEA’s website, to which this policy applies regarding the personal information collected therein. This policy is also disseminated through any means capable of reaching the individuals concerned. QMEA must also do the same for any amendments to this policy, which must also be notified to inform the individuals concerned.
*Notes: Please note that the use of the masculine gender is intended to streamline this policy and make it easier to read.
| Version | Effective date | Changes since last version |
| 1.0 | September 27, 2023 | Initial version |
| 2.0 | December 8, 2023 | Modification et adjustment |
| 3.0 | March 22, 2024 | Modification et adjustment |
Below is a non-exhaustive list of the types of information that QMEA may collect, their use, or the intended purpose, as well as how the information is collected. This includes, but is not limited to, the following elements.
Please note that most of the personal information managed by QMEA pertains to employees, candidates, members, and consultants. For other categories of individuals listed in the table below, the provided information is, in most cases, professional or business-related (see section 2 on professional contacts). It should be noted that in most cases, QMEA also collects the professional title/position of individuals, the name of the organization, and/or the organization’s address (see section 2 on professional contacts).
| Relationship with QMEA, services |
Type of personal information | End of collection / uses | Method of collecting information (means) |
| The information, when necessary | Used for: | Can be collected: | |
| Employees and job applicants |
|
|
|
| Consultants |
|
|
|
| Members (individuals and organizations) |
|
|
|
Has QMEA assessed the security issues of its service providers?
Does Arkis, the protection it offers, include an alert system in case of a breach involving personal information?
Is the storage of information in cloud services done on servers in Quebec, Canada, or is there a possibility of it being stored abroad?
Is an email sent in error to the wrong person considered an incident under the law?
Shouldn’t QMEA obtain specific consent during the membership process?
How does it work for job applicants?
Which staff member should have access to (and be responsible for) confidential information?
How long will the information of job applicants not selected by the employer be retained by the employer?
How long will the information of former employees be retained by the employer after their departure?