Privacy Policy of Harieka Consulting Group Inc.

Harieka Consulting Group Inc. (the “Company”) recognizes the importance that should be given to protecting personal information and an individual's right to privacy. This policy outlines the framework for the Company's policies and procedures regarding the collection, use, retention and disclosure of personal information regarding its clients, suppliers and others involved in the Company's operations. This Privacy Policy does not apply to the personal information of candidates or our employees, our officers and directors, or our contract staff, which are processed separately.

Our privacy policies and procedures apply only to personal information about identifiable individuals. They do not apply to commercial information. Personal information does not include the name, title, address, or business telephone number of an organization’s employee. For the purposes of this policy, the term “client” includes all current, former and prospective clients.

Personal Information that the Company may request:

  • Last name, first name and contact details;
  • Information that you have authorized us to collect from you or that we are otherwise authorized to collect under the law, including:
    • Mandate agreement;
    • For the purposes of staffing, coaching, succession plans, skills development, mobilization and well-being programs, organizational diagnostics, work environment surveys, harassment and grievance complaints, conflict management, mediation, team building, restructuring and organizational transformation, or change management:
      • Curriculum vitae, name, full address, telephone numbers (landline and cell phone), email, job title, hire date, salary, bonus program and commissions, vacation bank, retirement plan, sick leaves, personal need leaves, any other premium;
      • Psychometric tests, personality traits (type), potential assessment, objectives and performance assessment, recovery plan;
      • Registration forms, attendance certificates, educational background, employment history, age, gender, ethnic origin, disability;
      • Meeting notes, testimony notes, names of people concerned, names of witnesses, alleged or disputed facts;
      • Responses to questionnaires and surveys, reports, disciplinary measures, reason for departure,
      • Consumption habits, medical information, medical reports, insurance forms, expert reports, etc.

Method used to collect your Personal Information:

We only collect your personal information by fair and lawful means and only with your consent or where required or permitted by law. Where possible and appropriate, we collect your personal information directly from you or from individuals you have chosen to provide us with your personal information. Sometimes, we may collect information about you from other sources such as financial institutions, insurance companies, other parties involved in your transaction, government agencies or registries, employers (if we are acting on your behalf at your employer’s request), accountants or other professional advisors.

Purposes for which we use your Information:

  • To provide organizational development and related services;
  • To conduct conflict of interest searches in order to determine whether we can represent you;
  • To administer client accounts;
  • To manage our activities, including in the context of executing our contractual obligations and having professional orders verify our activities;
  • To detect and prevent negligence, fraud and theft;
  • To assess client satisfaction levels;
  • To understand and resolve potential disputes;
  • To support you in your development;
  • To provide you with information on our services and on developments in management practices, to invite you to take part in our activities and to generally communicate with you.

Communication of your Personal Information

The Company only communicates your personal information for purposes related to our delivery of services to you, or with your express consent, or if required or authorized by law. For example, we may disclose your information:

  • When necessary to deliver our organizational development services;
  • When necessary to collect overdue accounts;
  • When necessary to comply with a court order or regulatory provisions that affect us or to meet our insurance needs;
  • When communication is required with other relevant professionals as part of a transaction or dispute for which the Company is assisting you;
  • When we reasonably believe that the third party requesting your personal information is your agent.

In addition, we may disclose your personal information to third parties if we undergo a merger, restructuring or any similar transaction. We may disclose your personal information before and after such a transaction. However, if the transaction has taken place, we will require the third party to provide a comparable level of protection of your personal information. If the transaction has not taken place, we may, at your request, ask that all documents containing your personal information be securely destroyed or returned to us.

Consent

We may obtain your consent to collect, use and disclose your personal information either expressly, for the stated purposes, or implicitly, where the purposes are indicated by the relevant circumstances or follow logically from the other stated purposes. By providing us with personal information, you consent to the collection, use and communication of information relating to the delivery of our services, the management of our relationship with you, and the administration of our activities, to the extent permitted or required by law, in accordance with this Privacy Policy.

In accordance with the law, we ask for your consent before using your personal information for purposes other than those for which you originally consented. You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please note, however, that withdrawing consent may harm our ability to serve you and maintain our relationship.

Accuracy of your Information

Since your information may be used to provide you with consulting services, it must be accurate and up-to-date. Please let us know if any of your information changes so that we can make the necessary changes.

Security of your Personal Information

We have implemented policies and procedures to protect your personal information from loss, unauthorized access, alteration or disclosure. We have adopted technological safeguards, such as security software, passwords and firewalls to prevent unauthorized access to computers.

Please note that no method of transmitting or storing information is fully secure. Although we take the necessary steps to protect your personal information, it can still be lost, intercepted or misused. We may exchange e-versions of documents and emails with you using commercial software that is vulnerable to attack by viruses and other destructive electronic programs. We cannot guarantee that all communications and materials sent by email will be received or that such communications and materials will always be virus-free.

Storage of your Personal Information

The Company retains the personal information collected for as long as it is necessary to conduct its activities and achieve specified purposes, as long as it is reasonable to do so for client service purposes or for legal or commercial purposes. The retention period depends on the service and the nature of this information.

At the end of this period, the information will be destroyed, erased or made anonymous.

However, we make no commitment to retain the information collected for a specific period except where required by applicable laws or regulations.

Depending on the nature of the personal information, it may be stored at the offices of the Company, in various computer systems of the Company or its service providers, or in the storage facilities of the Company or its service providers.

In some cases, we may do business with external service providers who may store personal information outside of Québec. The Company takes reasonable steps to ensure that such external providers undertake to process personal information held by the Company in accordance with this policy and applicable laws.

The Company has entered into agreements with its service providers to ensure that:

  • The information is kept strictly confidential;
  • The information is not communicated to third parties without your prior authorization; and
  • Security measures are put in place to protect information against loss or theft, as well as against unauthorized consultation, communication, copying, or use or modification.

Information communicated to Service Providers

When we disclose your personal information to a third party to deliver administrative and other services, we take appropriate steps to ensure that the third party only uses your personal information in connection with the services we have mentioned. The nature of our activities sometimes requires us to use the services of administrative service providers who may be located in other provinces, in the United States or abroad. Consequently, your personal information may be transferred outside of Québec and, where applicable, will be subject to the legal requirements applicable in those provinces and foreign countries, including local requirements to communicate information to the courts, the police and to national security authorities.

If you would like more information about our policies and procedures regarding the sharing and processing of information outside of Canada, you can contact our Privacy Officer in one of the ways indicated below under “Questions or Concerns”.

Access to your Personal Information

You may request access to all of your personal information. You may also ask how we collected it, how we use it and to whom we disclosed it. Your request for access to your personal information must be made in writing and sent to our Privacy Officer. We will acknowledge receipt of your request in writing. We may ask you to provide us with information that will enable us to confirm your identity before providing you with the information you requested. Access to such information is generally provided free of charge, but if you request a copy or transmission of your information, we may charge a reasonable fee. We will inform you of the amount in advance and give you the opportunity to withdraw your request.

In some cases, we may be unable to provide you with access to your personal information, in whole or in part. If we are unable to do so or if the law does not permit us to do so, we will provide you with an explanation and indicate what other measures are available to you.

Modification of this Privacy Policy

We regularly review our privacy policies and procedures. Consequently, we may modify this Privacy Policy from time to time. The most recent version of our Privacy Policy will be posted on our website at www.harieka.com. Regardless of changes to our Privacy Policy, we will only use your personal information in accordance with the version of the Privacy Policy in effect at the time you provided your information or as otherwise required or permitted by law, unless you have expressly asked that we do otherwise.

Applicable Laws

The processing of personal information is governed by laws applicable in different jurisdictions. This Privacy Policy and all related operations are governed by the laws of the province of Québec and the applicable laws of Canada and must be interpreted in accordance with these laws.

Questions or Concerns

If you have any questions or concerns or would like more information about our personal information policies and procedures, or if you would like to access your personal information or change any consent regarding the use or disclosure of your personal information, please contact our Privacy Officer at the address below. We take all concerns about privacy seriously. We will review all concerns raised and seek to resolve them within a reasonable timeframe.

To the attention of: Annie Cloutier, Senior Partner, Privacy Officer
Telephone: 514-946-6305
Email: acloutier@harieka.com

This Privacy Policy is effective as of September 25, 2023.