Privacy policy

Policy on the protection of the Producer’s personal information

Entry into force: September 12, 2023.

1. Object and scope

Groupe Pixcom inc. and each of its subsidiaries, direct and indirect, present and future, including Productions Pixcom inc., Pixcom International inc., Productions Pixcom II inc., 10165697 Canada inc., Productions NB II inc. and 13567451 Canada inc. (hereafter collectively and individually referred to as the “Producer”) commits to treating the personal information of persons working for it in accordance with the Act respecting the protection of personal information in the private sector. The present Policy on the protection of personal information of persons working for the Producer (hereafter referred to as the “Policy”) is intended to inform physical persons working for the Producer or with whom the Producer has relationships of its practices with respect to the collection, use, communication and conservation of their personal information, as well as their rights with respect to their personal information.

While the term “Producer” is defined as including several companies collectively, each of these companies individually is the sole party responsible for its obligations under the terms of this Policy, without shared or other responsibility with the other companies included in this definition.

The present Policy applies to all physical persons working for the Producer or with whom the Producer has contractual or other relationships (hereafter referred to collectively as “Designated persons“ and individually as “Designated person“).

All references in this Policy to the “Act respecting the protection of personal information in the private sector” are references to the Act respecting the protection of personal information in the private sector, RLRQ c. P 39.1, as amended from time to time.

2. Definition of “personal information”

In the present Policy, the term “personal information” refers to all information relating to a physical person and that would allow, directly or indirectly, for that person to be identified.

3. Collection of personal information

The Producer collects personal information about Designated persons that is necessary for managing working relationships with them and also to: (i) respect legal or regulatory requirements and the contractual rights and obligations of the Designated persons and the Producer; (ii) manage programs or systems related to Designated persons; and (iii) obtain aid, grants and tax credits. The Producer can collect the following personal information with respect to Designated persons:

Identifying information and coordinates, such as their name, picture, email and postal addresses, phone number, government identification (such as their social insurance number and information relating to their visa and passport), work/residence permit or audio or video content.
Demographic information, such as their date of birth, gender, citizenship or medical information. In certain cases, the Producer may collect demographic information in connection with an equity, diversity and inclusion program, on a voluntary basis (such as ethnicity, sexual orientation, etc.).
Professional information or information related to the position or service contract, such as the title and remuneration history, work schedule and professional status, professional experience, studies, permits, professional affiliations and other titles, information on benefits and days off, information relating to any problems or disputes that may arise, reports and performance evaluations, psychometric test results, disciplinary files, the end of employment date and reasons for ending employment (voluntary or involuntary and details), surveys and all elements pertaining to protecting health and safety at work.
Financial information, such as that provided by persons working for the Producer for payroll purposes (financial institution and bank account number) and information required for issuing tax forms.
Information related to their emergency contacts, such as their names, coordinates and the nature of their relationship with them.
Information that the Producer collects on the use of the Internet, its networks, its devices and its premises, such as their IP address (if it identifies the Designated person) and device identification (for example, if the Designated person connects to the Producer’s Wi-Fi network). The Producer can collect information on Designated persons’ use of their work email account, Internet, computers, telephones and other devices belonging to the Producer that they have access to through their work, and of their personal device used for their work. The Producer can also collect video and photographic images by means of closed-circuit video cameras.
Other information, such as that provided by means of the payroll system.

4. Conservation and destruction of personal information

The Producer implements appropriate measures and control mechanisms to protect personal information belonging to Designated persons. These measures include restricting physical access to the Producer’s offices and files, restricting unauthorized access, communication, use and mishandling of personal information that the Producer possesses and controls, the storage of archived documents with trusted third parties, in secured locations and the use of firewalls and passwords.

The Producer’s goal is to prevent any unauthorized access, any loss, any unrightful use, any sharing or any modification of personal information in its possession. The Producer also uses these protection measures when it deletes or destroys the personal information of Designated persons.

The Producer endeavours to ensure that personal information is kept in Quebec or, when that is not possible, in Canada. However, it is possible that information is stored on servers belonging to the Producer’s service providers located outside Canada and subject to the laws of that country, including any laws allowing government authorities access. Subject to these foreign laws, the Producer shall, to the best of its ability and according to commercial use that it is reasonable in the circumstances, use contractual or other reasonable measures, given the technological context in force at the time, to maintain protections for the personal information that are at least equivalent to those that apply in Quebec.

The Producer conserves Designated persons’ personal information only for a reasonable duration needed for the purposes for which it was collected, or as permitted or required by the Act respecting the protection of personal information in the private sector. Once it is no longer needed, the personal information is destroyed in a secure or anonymized way, in accordance with the Act respecting the protection of personal information in the private sector.

The following durations of conservation of Designated persons’ personal information are considered reasonably necessary:

In perpetuity for documents containing rights of use, copyrights, ancillary rights or any other rights needed to certify the Producer’s rights to a work or that are necessary or useful in exploiting a work (for example, contracts with authors, directors, performers, etc.) or any waiver of moral rights related to a work.
Seven (7) years after the end of the work project, the service contract, the task or the file that the Designated person was working on for the Producer, for tax information and documents.
Three (3) years after the end of the work project, service contract, task or file that the Designated person was working on for the Producer, for all other personal information.
All durations additional to those indicated above: (i) in the event of litigation or the threat of litigation, as long as the litigation or threat of litigation has not been definitively settled or been subject of a final judgement without appeal; or (ii) if required by law or court order.

5. Use of personal information

The Producer uses the personal information of Designated persons to manage its working relationships, contractual relationships and other legitimate purposes that are detailed in the present Policy, as well as other purposes permitted by the Act respecting the protection of personal information in the private sector.

For example, The Producer may use the personal information of Designated persons for the following purposes:

To manage personnel, including to verify the identity of persons working for the Producer, manage taxes and social security, plan schedules and track attendance and hours worked, set up emergency contact information and handle requests made by Designated persons with respect to their work or delivery of services.
To manage benefits, including to determine the eligibility of persons working for the Producer and their dependants and beneficiaries.
To manage compensation, sick pay and holidays.
To evaluate performance, including to make decisions about assignments, training, remuneration and promotions.
To take necessary measures to protect the health and ensure the physical and psychological integrity of Designated persons.
To manage internal business activities, such as the implementation of disaster recovery plans and procedures, of continuity of activities or other emergency plans and procedures; conducting tests, audits and internal investigations; the creation of statistics and analytical tools for legitimate commercial ends (such as the improvement of commercial processes and human resources management on the part of the Producer).
To prepare and manage work permit applications.
To respect legal and regulatory obligations, meet security requirements, and for the management of fraud or other crimes, including internal investigations, the failure to complete tasks and the violation of a work or service contract, including by monitoring the use of the Producer’s information technology systems.

In addition to the purposes described above, the Producer can also collect personal information from Designated persons for any other purpose, with their consent, when that consent is required by the Act respecting the protection of personal information in the private sector.

The Producer can only make Designated persons’ personal information available to persons working for it to the extent needed in the execution of their work or their services. Persons working for the Producer who have access to the personal information of Designated persons must ensure that they take appropriate measures and control mechanisms to protect it. Persons working for the Producer may not share, copy or use the personal information of Designated persons for purposes other than executing their duties or other functions.

6. Communication of personal information

The Producer can also communicate the personal information of Designated persons to third parties detailed in the present Policy and in other policies or notices of the Producer, or as required or allowed by the Act respecting the protection of personal information in the private sector.

For example, the Producer can communicate the personal information of Designated persons to the following categories of third party:

Governmental organizations who need to access it or who require it (for example, to respond to applications related to employment insurance, as part of a grant or program application, etc.).
Service providers of the Producer when it is necessary or useful for the execution of a service contract that it has given to these providers. These services can include: auditing, information technology, payroll administration, human resources administration, office supplies and benefits administration, or professional service firms such as legal or accounting firms that provide professional services to the Producer. The Producer may communicate the personal information of Designated persons to service
providers located outside Quebec. The Producer will sign a written contract with any such provider located outside Quebec that includes the protections required to ensure the protection of Designated persons’ personal information in accordance with the Act respecting the protection of personal information in the private sector.
To third parties as part of verifying references or background or when it is contractually required by a client of the Producer or by the Producer before hiring a Designated person as an employee or the conclusion of a service contract with a Designated person.
To third parties as part of a planned or completed commercial transaction (for example, the purchase/sale of a company or shares, a merger or a financing operation) to which the Producer is a party, but only to the extent that the personal information is needed for such a transaction, in which case the Producer will conform to the applicable legal requirements during the use of the personal information.
To third parties to allow the production or exploitation of a work or to enable any potential exploitation of the work.

In addition, the Producer will cooperate with organizations responsible for the application of the Act respecting the protection of personal information in the private sector and comply with any court order or any law requiring the communication of personal information, without additional notice or consent from Designated persons.

7. Accuracy, access and corrections

Designated persons must provide the Producer with accurate and complete personal information and must promptly update the personal information kept by the Producer after any changes to that information.

Designated persons may, in writing, request information on their personal information kept by the Producer, as well as access to that information, and may request that their personal information be modified if it is inaccurate or incomplete, subject to various exceptions contained in the Act respecting the protection of personal information in the private sector (notably when access must be denied to protect other persons and to protect privileged or confidential information of the Producer’s).

Designated persons may also request additional information on the treatment of their personal information by the Producer, notably with respect to the categories of persons who have access to their personal information at the Producer, as well as the applicable period of retention of their information.

Designated persons may address requests for access or to correct personal information in writing to their manager or supervisor. Designated persons who are not satisfied with the result of the request addressed to their manager or supervisor may submit a formal access request directly to the Privacy officer.

8. Roles and responsibilities of members of personnel throughout the life cycle of personal information

All Designated persons who obtain personal information as part of the execution of their duties or their service contract are responsible for maintaining its confidentiality as established by the present Policy.

Véronique Voyer, Vice President, Legal and Business Affairs (vvoyer@pixcom.com) acts as the Producer’s Privacy officer and is responsible for ensuring that the Act respecting the protection of personal information in the private sector is respected.

9. Complaints and questions

Designated persons who believe that their personal information has been handled in violation of the present Policy may raise the issue with their manager or supervisor. Designated persons who are not satisfied with the result of their complaint or their question can contact the Privacy officer.

Any confidentiality incident involving personal information must be immediately reported to the Privacy officer. A confidentiality incident includes the following situations:

Unlawful access to personal information.
Unlawful use of personal information.
Unlawful communication of personal information.
The loss of personal information or any other breach in protection of such information.

10. Changes made to the present Policy

The Producer regularly revises its policies and procedures, and may revise the present Policy from time to time. The present Policy, as revised from time to time, can be consulted on the Producer’s website (www.pixcom.com).

In addition, the Producer from time to time offers training to Designated persons in the protection and security of personal information.

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