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Preamble

The Act respecting the protection of personal information in the private sector 1 (hereinafter referred to as “Law 25”) updates the protection of personal information framework, including the Act respecting access to documents held by public bodies and the protection of personal information2 (hereinafter referred to as the “Access Act”) and the Act respecting the protection of personal information in the private sector3 (hereinafter referred to as the “Private Sector Act”).

In compliance with regulatory obligations, the National Circus School (NCS) must adopt a privacy policy to ensure the confidentiality of personal information collected through its website and any other digital platform it operates (e.g. Omnivox, Microsoft 365, Forms, Teams, Outlook, etc.).

The NCS recognizes the importance of preserving the confidentiality and sensitivity of the personal information of all its staff and students. It implements reasonable measures to prevent accidental loss, unauthorized access, use, modification and unauthorized disclosure of such information.

Definitions

Personal information: Personal information refers to any information relating to an identified or identifiable individual. This includes details such as name, address, telephone number, email address, government identifier, financial information, or any other specific characteristics that allow an individual to be identified.

Personal information disclosure register: A document set up by the School to track and record instances where personal information is received, shared, communicated or used for other purposes originally intended.

Website: A website is a set of interconnected web pages accessible via the Internet and any other digital platform operated by the School. It may contain various types of information (text, images, videos, hyperlinks, etc.). They are often used to provide information, services, products or to facilitate online communication.

Protection granted by the General Data Protection Regulation

The General Data Protection Regulation (GDPR) applies to anyone processing personal data (commonly referred to as personal information in Quebec law) of individuals within the territory of the European Economic Area (EEA) when the processing activities are intended to offer goods or services. In the context of recruiting students residing in an EEA country, colleges are subject to the GDPR if they promote their programs by targeting individuals residing in the EEA and, corollary, collect, process or retain personal information about these individuals.

 

Website designer and editor

The website was created and edited by:

The NCS
8181, Avenue de cirque, Montreal (QC), H1Z 4N9
Telephone number : 514 982-0859

The website is hosted by:

The NCS
8181, Avenue de cirque, Montreal (QC), H1Z 4N9
Telephone number: 514 982-0859

The Privacy Officer is:

Éric Langlois, Executive Director
Email : [email protected]


Protection of personal information

The NCS is committed to respecting the privacy of individuals using its website and any other digital platform it operates.

By accessing and using any of the digital platforms operated by the NCS, the user acknowledges having read and understood the legal notices and general conditions of use.

During website consultation, visitors may be asked to voluntarily provide certain personal information, such as name, email address or postal address. This information is required to access certain sections (or services) of the site.

Individuals are free not to provide this information. However, the sections requiring this information will not be accessible to you.

In accordance with the Data Privacy and Protection Act4 of January 6, 1978, all individuals have the right to access, rectify, modify and delete any personal information they have provided us.


Information on the collection of personal information

Any individual has the right to withdraw his or her consent to personal information collection at any time, without affecting the lawfulness of processing based on consent given prior to withdrawal.

Any individual has the right to file a complaint with a control authority, i.e. the Commission d’accès à l’information du Québec.

The NCS will keep the data for no longer than is necessary for the purposes for which they are processed. This period depends on the nature of each service and the information collected.

Collection of personal information

The NCS only collects personal information that is necessary for the exercise of its functions or the implementation of a program under its management.

The personal information held by the NCS is only collected after the individual has been informed of the collection purpose and has voluntarily submitted information, either via a form, on the website or by email.

Use of personal information

The NCS uses personal information regarding its student clientele, staff members and other third parties to carry out its mission and duties. It will not use personal information for purposes other than those identified at the time of collection, except with the express consent of the individual or as required by the Act respecting access to documents held by public bodies and the protection of personal information or the Act respecting the protection of personal information in the private sector.

Disclosure of personal information

Disclosure without consent

The NCS may disclose certain personal information in its possession to comply with a court order, law or legal process, including responding to any governmental or regulatory request, in accordance with applicable law, or if it believes that disclosure is necessary or appropriate to protect the rights, property or safety of the NCS or others.

The NCS may communicate certain personal information in its possession to a member of the School’s staff who is qualified to receive it and when this information is necessary for the performance of his or her duties.

The NCS may transfer the personal information it collects to service providers and other supporting third parties. These third parties are contractually obliged to keep personal information confidential, to use it only for the purposes for which it is disclosed by the NCS, and to treat personal information in accordance with the standards set out in this Policy and in compliance with the law.

The NCS may disclose certain personal information for the purposes of study, research or the production of statistics, subject to the conditions set out in the Access Act and the Privacy Act, which include a privacy impact assessment and the transmission of the agreement to the Commission d’accès à l’information thirty (30) days prior to its coming into effect5.

In certain circumstances, the Privacy Officer must record the disclosure in the Personal information disclosure register.

 

Disclosure with consent

The NCS may disclose certain personal information it holds to a third party if it has obtained the valid consent to do so from the person concerned.

Protection of personal information

The NCS has implemented appropriate and reasonable physical, organizational, contractual and technological security measures to protect personal information against loss or theft, and against access, disclosure, copying, use or modification not authorized by law or contrary to its Privacy Policy.

The NCS has taken precautionary measures to ensure that only those staff members who absolutely must have access to personal information in the course of their duties are authorized to access it.

Individuals working for or on behalf of the NCS must:

  • Make reasonable efforts to minimize the risk of unintentional disclosure of personal information;
  • Take precautionary measures to ensure that personal information is not monitored, overheard, accessed or lost when working on premises other than the School’s offices;
  • Take reasonable measures to protect personal information when moving from one location to another.

Third-party vendors with access to personal information in the custody or control of the NCS are made aware of this Policy and other applicable policies and processes to ensure the security and protection of personal information. All third-party vendors must agree in writing to comply with all applicable policies, processes and laws.

Request for access to, or modification of, personal information

Any individual may submit a request for access to personal information held by the NCS. Any person may also request that this information be corrected. Such requests may be made by contacting the Privacy Officer at the following email address: [email protected].

External sites

The NCS website contains links to external sites. The NCS is not responsible for the content of these sites or their privacy practices and encourages you to read their privacy policies.

Policy communication and updates

The Privacy Officer ensures that the Policy is published and updated on the NCS website.

Responsibility for policy implementation and review

The Privacy Officer is responsible for the implementation and review of this Policy. If you have any questions about this Policy, or if you wish to file a complaint, you may contact the Privacy Officer at [email protected].

Effective date

This Policy comes into effect on the day it is adopted, i.e. January 23, 2024.

1 Act respecting the protection of personal information in the private sector, L.Q. 2021, c. 25
2 Act respecting access to documents held by public bodies and the protection of personal information, RLRQ, c. A-2.1
3 Act respecting the protection of personal information in the private sector, RLRQ, c. P-39.1
4 Law no. 78-17 of January 6, 1978 on data processing, data files and individual liberties (Data Privacy and Protection Act)
5 Act respecting the protection of personal information in the private sector, L.Q. 2021, c. 25, 67.2.1 to 67.2.3

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