for personal data collected digitally by the Conseil des arts de Montréal
The Conseil des arts de Montréal (hereinafter “CAM”) is subject to the Act respecting Access to documents held by public bodies and the Protection of personal information (CQLR, chapter A-2.1) (hereinafter the “Act”). CAM is committed to protecting users’ privacy and personal information and is taking all necessary measures to comply with the Act’s requirements.
CAM may collect personal information digitally, such as through a website, application, or related apparatus.
This policy describes the practices CAM uses to keep digitally collected personal data in strictest confidence. This document describes the type of personal information collected, the purpose for which it is collected, potential modes of disclosure, methods of retention, and protection measures.
CAM is committed to promptly informing all persons concerned in the event of a breach of confidentiality involving personal information that could pose a real risk of significant harm.
1. Personal information
Personal information is information about a natural person that allows them to be identified. This information is confidential. Unless otherwise specified, this information cannot be disclosed without the consent of the person concerned.
2. Collection of personal information
CAM may only collect the personal information it requires for the exercise of its functions and to deliver services to citizens.
Personal information is only collected from persons concerned after such persons grant clear, free, and informed consent for specific purposes.
All CAM personnel shall limit their use of personal information to the purposes for which it is intended and handle it with utmost caution at all times.
CAM shall not disclose any personal or confidential information. In accordance with the Act, if CAM requests personal information, the person concerned shall receive prior notification about the following:
- how the information will be used;
- categories of persons with access to the information;
- whether the request is mandatory or optional;
- what would follow a refusal to respond to the request;
- the right of access and right of correction, as covered by the Act;
- measures taken to safeguard the confidentiality of information at the moment of transmission;
- the name of any third party that collects information, and the name of any fourth party that collects it on their behalf, if applicable.
When personal or confidential information is voluntarily submitted by email, unsecured electronic form, or any other digital means, we only use the information we need to reply to your message or follow up on your request.
3. Non-disclosure to third parties
CAM shall not rent, sell, or exchange any nominative information (e.g., name, address, telephone number, email address, etc.) or financial information (e.g., credit card number) that could be used to identify you.
CAM shall not disclose personal information except when legally obligated to do so, upon request by court order, or to fulfill a contract with a third party. When retaining the services of an external provider, CAM shall take all necessary measures to ensure that your personal information is protected in accordance with the Act that applies to CAM, and that it is collected, used, retained, and destroyed in accordance with the present policy, to which CAM is subject.
4. Data security
CAM takes all necessary measures to ensure that your personal data is not accessible to any third party other than authorized personnel, insofar as the data is needed for the exercise of CAM’s functions. Your data may be stored in another country. In this case, CAM shall take measures to guarantee a level of protection that is equal to protections for data stored on Canadian soil, and to ensure compliance with all applicable legal requirements, including those concerning data protection.
CAM adheres to high standards and uses high-performance security systems in the design, implementation, and daily operations of the Platforms and their servers and networks. CAM’s efforts to detect and block intrusions on or towards its Platforms are ongoing. CAM has implemented various safeguards to protect your personal information against risks of loss or theft, and risks of unauthorized access, disclosure, reproduction, use, modification, or destruction. These include the physical, organizational, and technological security measures deemed reasonable by CAM with regard to the sensitivity, amount, and format of the personal information collected, as well as storage methods.
However, no method of protection can be absolutely guaranteed. If you have reason to believe your interactions with us are no longer secure, or if you believe the security of the information provided has been compromised, please contact us immediately at the following email address: renseignements-personnels-CAM@montreal.ca
Once the purposes for which the personal information was collected have been fulfilled, the information shall be destroyed or anonymized, as subject to CAM’s retention rules and the Archives Act (CQLR, chapter A-21.1). CAM nevertheless reserves the right to retain certain types of personal information for a reasonable amount of time in order to comply with the Act, avoid fraud, collect outstanding fees, resolve a claim or related matter, or to cooperate with an investigation.
6. Your personal information: right of access and right of correction
Under the Act, persons can request access to personal information that concerns them and endeavour to correct it.
In addition, persons have the right to:
- withdraw, at any time, their consent to disclose or use the personal information collected;
- request the deletion, destruction, or withdrawal of personal information, under certain circumstances. Certain exceptions exist under the terms of which we may refuse a request to delete or destroy personal information, such as when such personal information is required for legal compliance, to comply with a contractual agreement between the parties, or because it is pertinent to claims;
- request a pause in the processing of certain types of personal information, for example to confirm its accuracy or the reason for processing;
- request the transfer of certain types of personal information to another party.
Written requests for access, correction, or any questions regarding this policy must be sent to the person in charge of protecting personal information using the following email address: renseignements-personnels-CAM@montreal.ca or by completing the online retrait du consentement [withdrawal of consent] form (currently available in French only).
7. Digital Services
CAM websites and mobile applications (hereinafter the “Platforms”) are available to the public. Digital services offered on the Platforms may require users to provide personal information.
The information required to create a user account is retained by CAM and its partners.
This information is collected to:
- relieve you from identifying yourself again for every service request;
- improve services;
- correctly respond to your questions, comments, and suggestions.
Only personnel tasked with Platform management or the delivery of a particular aspect of a requested service may access the information. The requested information is mandatory for the purposes of creating an account. Users can only access the benefits associated with a user account by providing this information.
In accordance with the Act, users have the right to access and the right of correction for digitally collected personal information that concerns them.
You agree and understand that you are responsible for maintaining the security and confidentiality of your account password on CAM Platforms. You accordingly accept sole responsibility to CAM for all activities performed through this account. If you learn about or have reason to suspect any form of intrusion, including theft, loss, disclosure, or unauthorized use of your login information, you are obligated to report it to us immediately.
If your browser’s geolocation function is on when you access the Platforms, CAM shall use your position for the sole purpose of improving the Platforms’ usability.
CAM shall not track your movements when you use the Platforms. You can disable the geolocation feature on your device at any time by consulting the manufacturer’s instructions. However, disabling the geolocation feature may block access to certain Platform functionalities.
Cookies are used to facilitate and optimize navigation on the Platforms. Cookies are small text files that are downloaded and stored in the memory of the device you use to access web pages. The cookies CAM uses do not collect personal information about you. Most internet browsers accept cookies by default. You can change your browser’s privacy settings at any time to block cookies or delete existing cookies. Doing so does not prevent access to Platforms but may affect performance during your visit.
CAM uses analysis tools (Google Analytics) on its Platforms. These tools collect, analyze, measure, and submit data about visits to help CAM better understand and optimize online usage.
CAM retains the data to track information such as:
- number of visits
- pages most often visited
- Platform users’ preferred technology
- referral traffic
- users’ country of origin
Data collected by Google Analytics is transmitted outside Canada to Google’s servers and may be processed in any country where Google’s servers are operated. Data may be subject to the laws of that country. For more information on this analytics tool, please see Google Analytics Terms of Service.
e) Links to other sites
8. Feedback tool
CAM may use an external application to obtain feedback about the website for the purpose of improving its content and functionality.
This application shall only collect data about your device: the model, IP address, type of browser and version, and language preference.
The Platforms have no element specifically intended to solicit information from minors or to determine whether a user is a minor. Personal information submitted on the Platforms by minors shall be handled in the same way as information submitted by adults.
CAM firmly believes that internet usage by minors should be closely supervised by parents. CAM therefore requests that when personal information is requested online, parents offer minor children guidance. CAM also requests that minors obtain permission from parents before providing information online.
10. Web browsers, HTTPS, and encryption
Internet browsers detect adequately protected communication, displaying a PADLOCK symbol on the page to confirm that the communication session is secure. Please note that this does not apply to the mobile app.
CAM’s Platforms are covered by the most secure encryption protocols available. All confidential data sent from your communication device to CAM’s Platforms are protected by effective cryptographic techniques to ensure that your information remains strictly confidential.
11. Privacy complaint process
Persons who believe their personal information was processed inappropriately or that noncompliance with the Act has occurred may accordingly file a complaint.
Privacy complaints may address issues surrounding the collection, retention, use, disclosure, or destruction of personal information.
The complaint is handled in strictest confidence. Personal information remains protected.It is only accessible to those authorized to view it in the performance of their duties.
A complaint can be sent to the following email address: renseignements-personnels-CAM@montreal.ca
A written complaint may also be sent to the Commission d’accès à l’information – Direction de la surveillance