Notice of Information Respecting the Protection of Personal Information

1. Introduction of the Notice

 

The purpose of this Notice of Information respecting the protection of Personal Information (“Notice”) is to inform you of CDPQ Infra's practices with respect to the confidentiality and protection of your Personal Information, including how we collect, use and disclose your Personal Information. CDPQ Infra acts as a principal contractor for major public infrastructure projects.

This Notice pertains to this Site and all of our activities, unless we have provided you with a specific policy and/or guidelines for a particular product, service or activity. 

In this Notice, terms not defined in the body of the text are defined in Appendix 1.

By submitting your Personal Information to us, registering for or using this Site, or voluntarily interacting with us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Notice, as revised from time to time. Our Notice sets out our standards for the collection, use, disclosure and storage of your Personal Information. As such, CDPQ Infra is committed to protecting your privacy and safeguarding your Personal Information. 

This Notice is prepared in accordance with our policies and guidelines issued under Applicable Legislation. 

 

2. Your Consent

 

We collect, use and disclose your Personal Information with your consent or as permitted or required by law. The approach we use to obtain your consent depends on the circumstances and sensitivity of the information collected. Thus, subject to Applicable Legislation, your consent may be explicit or implied. If you choose to provide us with Personal Information, we will assume that you consent to the collection, use and disclosure of your Personal Information as set out in this Notice.

In general, we will ask for your consent at the time your Personal Information is collected. 
Once you have provided us with proof of identification, you may withdraw your consent to the collection, use or disclosure of your Personal Information at any time by contacting us as indicated in the Contact Us section below. 

If you provide us with Personal Information about another individual, it is your responsibility to obtain that individual's consent to allow us to collect, use and disclose their information as described in this Notice.
 

3. What Personal Information Do We Collect?

 

3.1. Information Collected

 

The Personal Information that we collect usually falls into one or more of the following categories:

Collection Methods	Type of Information	Information We May Collect
When you contact us by phone, email, chat, via a form (e.g., info@cdpqinfra.com) or any other means (including in person or via social networks)	Your contact information Your professional information Other	Name, address, phone number, email address Title, name of the company you work for Any other information you provide to us
When you sign up for CDPQ Infra’s mailing list	Your contact information	Phone number or email address
When you visit our Site	Information about your activity on the Site	Technical and feature-related information about your use of our Site (which may include your IP address, information about your device, browser and operating system, and the date and time of your visit) We also use cookies, as further explained below.
When you submit your application for a position through the Careers section of our Site.	Your contact information Your professional information Other	Name, email address Resume, cover letter Any other information you provide to us
When you fill out a contact form (to request information, make a complaint, when you use the reporting line or to report a technical issue)	Your contact information Your professional information Other	Name, address, phone number, email address Title, name of the company you work for Any other information you provide to us
Following recruitment	Your contact information Your professional information Other	Specific details dealt with in employment contracts
Marketing	Your contact information Your professional information Other	Name, email address Marketing list interests/assignments, registration of marketing authorizations or objections, Website data (including online account details and IP address) Company's name, address, phone number and job title

 

3.2. Use of Cookies

 

Our Site uses cookies. Cookies are files that are installed on your computer's hard drive or browser to collection information such as your language preference, browsing history, browser type and version. Their purpose is to optimize your experience on our Site. You can set your browser to refuse all cookies or to notify you when a cookie is sent. Instructions on how to do so are provided by each browser site.

For further information, please consult our Notice on the use of cookies.

 

3.3. Analytical Tools and Other Third-Party Technologies

 

We use analytical tools and other third-party technologies, such as Google Analytics. 

For further information, please consult our Notice on the use of cookies. 
 

4. For What Purpose Do We Use Your Personal Information and on What Legal Grounds? 

 

We may use your Personal Information and other information for the purposes set out below:

• To respond to your questions and inquiries
• To detect and prevent fraud
• To comply with our legal obligations, for example in the event of a complaint or injunction
• For any other purpose, with your consent
• For purposes permitted or required by Applicable Legislation

We do not use the collected information to advertise third-party products and services, or to engage in targeted CDPQ Infra advertising on third-party Websites or service offerings.

More precisely, we collect Personal Information for the following purposes:

Purpose	This Includes, Without Limitation:	Applicable legal basis
Fully utilize, maintain, improve and deliver all Site functionalities	Provide the information you request  Respond to comments and questions Assist Site users Monitor and improve our Site Analyze users’ needs and activities to enhance the user experience	Execution of a contract Legitimate CDPQ Infra interest
Respond to requests	Respond to information requests and other inquiries	Execution of a contract
Facilitate the hiring process	Verify references provided by a candidate  Interviews with potential job candidates  Screening assessments reasonably required for the performance of the job	Execution of a contract
Administer compensation plans and, as applicable, benefit plans, pension plans and other retirement benefits, termination benefits and other monetary benefits related to employment	Work hours, pay rate or salary, in order to determine base salary  Communication with third parties, including payroll consultants, benefits consultants, actuaries, pension trustees, fiduciaries and/or various government departments, as required by legal and regulatory requirements  Internal management of benefits plans	Legal obligation
Manage, develop and maintain the workforce and its well-being within the organization to assist CDPQ Infra in achieving its business objectives	Collection of demographic data to ensure the success of various equity, diversity and inclusion (EDI) strategies and programs   CDPQ Infra may share this Personal Information with third parties who support CDPQ Infra, such as in the development of training programs.	Employee's consent

 

5. How Do We Share Your Personal Information?

 

We may share your information with our service providers. In such instances, we take steps to ensure that the rules set out in this Notice are followed, and we require service providers to maintain the confidentiality and security of your Personal Information. 

We also require them to only use your Personal Information in accordance with its intended purpose. When our service providers no longer need your Personal Information for such limited purposes, we require them to destroy it. 

Under certain circumstances, we may authorize our service providers to retain information for legally permitted purposes or in aggregated, anonymous or statistical form that does not identify you. 

We do not allow service providers to disclose your Personal Information to unauthorized parties or use it for direct marketing purposes. 

For more information about our service providers, please contact us as indicated in the Contact Us section below.

Listed below are categories of third-party service providers that may process your Personal Information:

• Other members of our Group and our designated representatives. Members of our Group may use such information for statistical analysis and producing reports.
• Service providers who help manage our computer or back-office systems, or who provide platforms and portals for administration.
• Our Québec regulators and other enforcement agencies under Canadian, U.S., European and international law.
• Fraud prevention agencies and organizations.
• Our advisors (who may be legal representatives to you, us, or a third-party applicant) and other professional services firms (including our auditors).
• Marketing execution, webinar and customer satisfaction service providers acting on our behalf who facilitate online events, provide marketing communications, and gather feedback on our service levels from our customers.
• For information only, a list of contractors is available on request.

We may also use and disclose your Personal Information when we believe such use or disclosure is authorized, necessary or appropriate: 

• under Applicable Legislation, including laws outside your country of residence, to comply with any legal procedure or respond to requests from public and government authorities, including public and government authorities outside your country of residence; 
• to protect our activities and those of members of the Group; 
• to protect our rights, privacy, security or property and/or those of members of the Group, yourself or others; 
• to enable us to pursue available recourses and limit the damages we may suffer; and 
• in the event of a restructuring, merger, sale, joint venture, assignment, transfer or other disposal of all or part of our business, brands, affiliates, subsidiaries or other assets.
   

 

6. Retention of Personal Information

 

We will only use, disclose or retain your Personal Information for as long as necessary to fulfill the intended purpose of its collection and as permitted or required by law. 

For further information regarding the retention period of your Personal Information, please contact us as indicated in the Contact Us section below.

7. Information Security

 

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information and other information from loss, theft, unauthorized access, disclosure, duplication, use or modification. 

We have taken measures to ensure that the only employees authorized to access your Personal Information are those who have a “need to know” or whose duties reasonably require access to such information.

Despite the measures described above, no method of transmission or storage of information is 100% secure or error-free; therefore, we unfortunately cannot guarantee absolute security. 

If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the information you have provided to us has been compromised), please contact us immediately as indicated in the Contact Us section below.

 

8. Your Rights

 

You have various rights with respect to your Personal Information. These rights may vary depending on your geographic location and the Applicable Legislation governing the processing of your Personal Information. This section provides you with an overview of these rights and how they may be exercised. We will take the necessary steps to ensure that your Personal Information is accurate, complete and up to date. We will not systematically update your Personal Information unless such a process is necessary. 

 

8.1.    Right of Access 

 

We expect you to provide us with updates to your Personal Information from time to time, as necessary. 

CDPQ Infra acknowledges that, in accordance with Applicable Legislation, you have the right to receive confirmation regarding the Processing of your Personal Information retained by CDPQ Infra and to access it (i.e., to examine it and get a copy) without delay. 

 

8.2.    Right to rectification

 

CDPQ Infra acknowledges that, in accordance with Applicable Legislation, you have the right to have any Personal Information held by CDPQ Infra that is inaccurate or misleading corrected without delay, and, in any event, within one (1) month of CDPQ Infra’s receipt of the request to correct inaccurate or misleading Personal Information.

CDPQ Infra further acknowledges that, given the purpose of Processing, you have the right to have your incomplete Personal Information completed, including by providing a supplementary statement.

 

8.3.    Withdrawing Your Consent

 

In accordance with Applicable Legislation, you have the right to withdraw your consent to the Processing of your Personal Information at any time when such Processing is based on consent.

CDPQ Infra will honour an individual’s request to withdraw their consent, unless it is demonstrated that there are compelling legitimate grounds for the Processing that prevail over the interests, rights and freedoms of the individual or that the Processing is necessary for the establishment, exercise or defence of CDPQ Infra’s legal claims.

 

8.4.    Right to Personal Information Portability

 

Depending on the Applicable Legislation, you may have the right to receive your Personal Information provided to CDPQ Infra in a structured and commonly used format when the Processing is based on direct consent or contract, and when the Processing is carried out by automated processes.

 

8.5.    Right to Object to the Processing of Your Personal     Information

 

Depending on the Applicable Legislation, you may have the right to object at any time, on grounds pertaining to your particular situation, to the Processing of your Personal Information based on the public interest or legitimate interest of the data controller, including profiling.

CDPQ Infra will honour the request unless it is demonstrated that there are compelling legitimate grounds for the Processing that prevail over the interests, rights and freedoms of the data subject or that the Processing is necessary for the establishment, exercise or defence of CDPQ Infra’s legal claims. 

 

8.6.    Right to Restriction

 

Depending on the Applicable Legislation, you may have the right to restrict the Processing of your Personal Information under certain circumstances. This means that the data subject may restrict how CDPQ Infra uses their Personal Information when one of the following applies: 

• the accuracy of the Personal Information held by CDPQ Infra is contested; 
• the Processing of the Personal Information is unlawful and the data subject prefers restriction of its Processing to its erasure; 
• the Personal Information is no longer required for the purpose for which it was collected, but is required by CDPQ Infra to establish, exercise or defend its legal claims;  
• the data subject objects to the Processing of the Personal Information pending verification of whether the legitimate grounds concerned by the data controller override those of the data subject. 

 

8.7.    Right in the Event of the Use of an Automated Decision System

 

In some cases, you may request information about how any automated decision system is used and the impact it may have on you. 

 

8.8.    How to submit an application

 

To exercise your rights, you must submit a written request to the Privacy Officer and attach appropriate proof of identity, such as an employee identification card or a copy of a driver's licence or passport, which will be used solely for the purpose of such request.

The person making the request is encouraged to fill out the request form according to the template developed by CDPQ Infra. CDPQ Infra will respond as soon as possible, but within a maximum of one (1) month from receipt of all relevant information.

For more information about your rights and how to exercise them, please contact the Privacy Officer at [email protected].

You may also file a complaint with the authority responsible for data protection. 
 

9. International and Interprovincial Transfer

 

Your Personal Information is currently stored in Canada and the United States. For legitimate legal or commercial purposes, we may need to transfer or authorize access to your Personal Information to parties based abroad. 

Moreover, where applicable, it may be stored and processed in any country in which we or our Group have facilities or where we contract with service providers. In the latter case, your Personal Information may be transferred to countries other than your country of residence, which may have laws that differ from those of your country. 

If such information is located outside your country of residence, it is subject to the laws of that country and may be disclosed to the governments, courts or law enforcement or regulatory agencies of that other country in accordance with its laws. Nonetheless, our practices with respect to your Personal Information will at all times be governed by this Notice and, where applicable, we will comply with the requirements under Applicable Legislation regarding the transfer of the Personal Information of data subjects to a third country, such as the conclusion of standard contractual clauses.

 

10. Third Parties’ Websites and Services

 

This Notice does not apply to websites, products or services provided by third parties.  We are not liable for such third parties’ privacy practices and encourage you to review their privacy policies before using their websites, products or services.