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Privacy Policy

Procedure for Retention, Destruction, and Anonymization of Personal Information

1. Overview

  • Objective: Protect privacy, comply with laws, prevent breaches, and maintain customer trust.

2. Purpose

  • Ensure the protection of personal information and compliance with legal obligations.

3. Scope

  • Covers the entire lifecycle of data (collection, processing, destruction) for all employees and stakeholders.

4. Definitions

  • Personal Information: Information that can identify an individual.

  • Retention: Secure storage for the required duration.

  • Destruction: Permanent deletion of data.

  • Anonymization: Modifying data so it cannot be identified.

5. Key Procedures

  1. Retention Periods: Based on category (employees: 7 years; members and clients: variable).

  2. Storage Methods: Secured using digital tools (OneDrive, Wix), restricted access.

  3. Data Destruction: Shredding (paper), secure deletion (digital), mandatory documentation.

  4. Anonymization: Ensure data cannot be re-identified if retained.

  5. Training: Regular awareness sessions for employees on best practices.

 

Procedure for Access Requests and Complaint Management

1. Access Requests

  • Submit in writing; identity verification required.

  • Respond within 30 days, with precise documentation.

2. Complaint Management

  • Record receipt, investigation, and resolution.

  • Transparent communication with complainants.

 

Procedure for De-Indexing and Deleting Personal Information

1. Definitions

  • De-indexing: Removing data from search engines.

  • Deletion: Permanent removal of data.

2. Process

  • Receive request, verify identity, evaluate data in question.

  • Communicate decisions and document actions taken.

 

Procedure for Managing Security Incidents

1. Types of Incidents

  • Ransomware, account hacking, loss or theft of devices.

2. Specific Interventions

  • Disconnect infected devices.

  • Notify appropriate authorities.

  • Reinitialize affected systems.

 

Legislation and Commitment

  • Compliance with applicable laws, including modifications to Law 25 in Quebec.

  • Regular updates to policies to reflect legal and organizational changes.

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