Privacy Policy

Protection of personal information

L'AGENCE is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (hereinafter the “Act”). As such, it strives to maintain the highest standards of confidentiality regarding the personal information of its customers, suppliers and other businesses.

This includes information gathered in the course of its real estate brokerage activities, notably through :

• The AGENCY's website (the “Website”)
• Its social networks
• its advertising
• Customer Relationship Management (CRM) systems
• Electronic Document Management (EDM) systems

All this is done in accordance with the obligations of the Law.

What is “personal information”?

Personal information is any information concerning a natural person that enables that person to be identified, directly or indirectly.

This may include :

• First and last name
• Home address
• Date of birth
• Social insurance number
• Identification details
• Income information
• Marital status

The following protection principles apply to the collection, use and transmission of personal information provided via the Website.

1. Responsibility

The AGENCY is responsible for protecting the personal information it holds in the course of its real estate brokerage activities.

To ensure this, it has implemented:

• A privacy policy
• Policies and practices governing personal information management

These policies regulate the collection, use, disclosure, retention, and destruction of personal data.

2. Collection of Personal Information

The AGENCY collects only the information strictly necessary for its operations, including:

• Facilitating real estate transactions
• Managing client files
• Ensuring professional oversight by the Organisme d’autoréglementation du courtage immobilier du Québec (OACIQ)

Groupe Sutton Synergie Inc. (hereinafter "the AGENCY") provides a secure web environment for its users.

It encourages its staff and collaborators to clearly explain to clients why their personal data is being collected, ensuring complete transparency.

The AGENCY prioritizes the use of standardized forms developed by the OACIQ for data collection.

Additionally, it may collect personal information:

• Verbally, during discussions with individuals involved in a transaction
• Through various submitted documents, such as:
  • Identification documents
  • Financial records
  • Powers of attorney

3. Use and Disclosure of Personal Information

Personal information is used and disclosed only for the purposes for which it was collected and with the individual's consent. In some cases provided by law, personal information may be used for other purposes, such as detecting and preventing fraud or providing services to the individual concerned.

The AGENCY may be required to disclose personal information to third parties, including but not limited to:

• Suppliers
• Contractors
• Subcontractors
• Agents
• Insurers (such as the Quebec Real Estate Brokerage Professional Liability Insurance Fund [FARCIQ] and the Quebec Real Estate Brokerage Indemnity Fund [FICI])
• Professionals
• Financial institutions and credit verification agencies
• Electronic Document Management (EDM) system providers
• Other regulators, including those outside Quebec

The AGENCY may, without the individual’s consent, disclose personal information to a third party if such disclosure is necessary for the execution of a mandate or service contract. In such cases, the AGENCY establishes a written mandate or contract specifying the security measures the third party must implement to protect the personal information entrusted to them. The contract also stipulates that this data must only be used for the specified mandate or contract and must be destroyed afterward. The third party must also cooperate with the AGENCY in case of any confidentiality breaches.

Before disclosing personal information outside Quebec, the AGENCY considers the sensitivity of the data, its intended purpose, and the level of protection it will receive in the foreign jurisdiction. The AGENCY will only disclose personal information outside Quebec if its analysis confirms that adequate protection measures are in place.

4. Retention and destruction of personal information

Once the purposes for which the personal information was collected or used have been fulfilled, the AGENCY must destroy it, subject to the retention period stipulated by law. In this regard, the AGENCY's professional obligations require it to keep its files for at least six (6) years following their final closing.

5. Security measures

When collecting, using, storing and destroying personal information, AGENCY applies the necessary security measures to protect the confidentiality of personal information. The personal data collected will be stored on servers and in electronic data management systems equipped with mechanisms and using recognized standards of protection to ensure the security of personal information provided to the AGENCY by its customers, suppliers and other companies in connection with its real estate brokerage activities, including but not limited to, through the Website, its social networks, its advertisements and for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with its obligations under the Act.

Confidentiality incident

A privacy incident is any access, use or disclosure of personal information that is not authorized by the Act, or the loss of personal information or any other breach of the protection of personal information.

The AGENCY or BROKER has established a protocol for managing a confidentiality incident, which identifies the persons who assist the Privacy Officer and sets out the concrete actions to be taken in the event of an incident. This protocol sets out the responsibilities expected at each stage of incident management, including the measures to be taken to ensure data security.

6. Roles and Responsibilities

A. The AGENCY, its Staff, Members, Team, or Any Administrative Assistant

• Ensures the confidentiality of information through good information management practices.
• Deploys appropriate protection measures to reduce the risk of confidentiality incidents.
• Implements standardized methods for organizing and retaining documents containing personal information.
• Manages physical and digital access to personal information based on its sensitivity.
• Carries out the secure destruction of personal information.

B. Personal Information Protection Officer

In accordance with the law, the AGENCY has appointed a Personal Information Protection Officer. This individual ensures that the policies in place are followed and comply with applicable regulations.

The Personal Information Protection Officer:

• Manages confidentiality incidents.
• Processes requests for access and correction of personal information.
• Is consulted when conducting privacy impact assessments for any project involving the collection, use, disclosure, retention, or destruction of personal information.

C. Staff Members, Team Members, or Any Administrative Assistant

A staff member, team member, or any administrative assistant of the AGENCY may only access personal information when it is strictly necessary for the execution of their duties or mandate.

The staff member, team member, or administrative assistant of the AGENCY:

• Ensures the integrity and confidentiality of personal information held by the AGENCY.
• Complies with all AGENCY policies and guidelines regarding the management of personal information.
• Uses only the equipment and software authorized by the AGENCY.
• Immediately reports to their superior any act that may constitute a real or suspected breach of personal information security rules.

7. Right of Access, Withdrawal, and Correction

An individual (or their authorized representative) may request access to their personal information held by the AGENCY. An individual may withdraw their consent at any time for the collection, use, and disclosure of their personal information, and this withdrawal will be recorded in writing.

An individual may request the correction of any personal information in their file that they believe is inaccurate, incomplete, or ambiguous. They may also request that the AGENCY transfer their personal data electronically to a third party.

The AGENCY may refuse an access or correction request in cases provided for by law (https://www.legisquebec.gouv.qc.ca).

8. Complaints

Any individual who believes they have been harmed may file a complaint regarding the handling of their personal information by the AGENCY. This complaint will be handled promptly within a maximum of 30 days by the Personal Information Protection Officer, and a written response will be provided.

To make a request for access, correction of your personal information, or any other request you are entitled to, as well as to submit a complaint regarding the handling of personal information, please contact:

Yvon Cousineau
Groupe Sutton Synergie Inc.
472 Rue Notre-Dame Bureau 300, Repentigny, QC J6A 2T5
(450) 585-0999
ycousineau@sutton.com ↗