Policy on the Management and Protection of Personal Information

1. Introduction

The purpose of the Act to modernize legislative provisions as regards the protection of personal information (LQ 2021, c 25) (Act) and the regulations adopted under it is to provide an appropriate framework for the access to documents and the protection of personal Information held by private organizations. In the pursuit of its mission, G4 Holding must collect, use, store, communicate and destroy personal Information.

This personal information is confidential, with the exception of information deemed public under the Act. G4 Holding is therefore responsible for protecting the confidentiality of this information and complying with its legal obligations in this regard, including obtaining the consent of the individuals concerned before disclosing the information to third parties. The Policy on the Management and Protection of Personal Information (Policy) aims to implement concrete measures to meet these requirements.

2. Mission statement

The purpose of this Policy is to oversee the collection, use, storage, disclosure and destruction of personal information and to implement measures to protect the confidentiality of such information in compliance with the Act and its regulations.

3. Scope of application

3.1 – Legal framework

With respect to protecting personal information, G4 Holding must comply with the Act, the Civil Code of Québec and the Québec Charter of Human Rights and Freedoms (RLRQ c. C-12).

3.2 – Subject

The Policy applies to the entire company. If managers have any doubts about the handling of personal information, they should consult the designated Access Officer.

4. Definitions

For the purposes of this Policy, the following terms have the meanings given to them in this section.

Document: information, produced or received by the Human Resources Department, which is delimited, structured and made comprehensible in the form of words, sounds or images and carried by a medium.

Managerial staff: any person hired to occupy a managerial position within G4 Holding’s organizational structure.

Executive staff: The president or vice-president, operations management and administration management at G4 Holding.

Personal information: any information concerning a natural person that allows them to be identified. The name of a natural person is not considered personal information, except when it is mentioned in combination with other information relating to that person, or when its mere mention would reveal personal information relating to that person. The fact that a signature appears at the bottom of a document does not render the information contained therein personal.

Access Officer: Person delegated as such by the President and Vice-President of G4 Holding. The Human Resources Department independently performs the duties of Information Access Officer and Privacy Officer under the Act.

5. Collection

We collect only the personal information we need from the general public, form our employees or from a third party authorized to disclose it. We cannot use your personal information for purposes other than those to which you have consented, nor disclose it to a third party without your consent. (see Section 6)

We may, however, collect, use or disclose your personal information without your consent where permitted or required by law.

We limit the collection, use and disclosure of your personal information to the purposes we have identified to you. Your personal information may only be accessed by certain authorized individuals, and then only for the purposes for which they have been assigned.

For example, we could occasionally share our employees’ personal information with customers in remote locations to meet our commitment to protecting their health and safety in the workplace. For example, data such as their date of birth, emergency contact and telephone number may be shared to provide essential information in the event of injury or disability. We are required to ensure that our service providers comply with applicable privacy laws and provide a level of protection comparable to our own.

You have the right to know, upon request, to whom your personal information has been communicated. Only in certain circumstances and in accordance with the law will we refuse to disclose this information. We keep accurate records of the individuals to whom your personal information has been disclosed and the circumstances that led to its disclosure.

5.1 – Sources of data collection
5.1.1 Website (career section)

When applying for a job, you must enter your contact details and attach your resume, if applicable, so that our team can contact you during the hiring process.

5.1.2 Registration documents upon hiring

When you are hired, G4 Holding requests certain personal and confidential information to manage your employment within the company. For this purpose, G4 Holding will ask you to complete a form detailing all the information required by law.

5.1.3 Pre-employment medical and dental examinations

In certain cases, our customer requires pre-employment medical examinations and verification of your employment record. This data is shared only with our customer’s nursing and human resources departments, who are bound by confidentiality agreements.

5.1.4 Working hours

Your phone number and emergency contact are indicated in the work schedule, which is available to our foremen and operations managers. This information is particularly useful in the event of medical emergencies or to have access to a 2nd contact to reach you.

5.2 Restrictions on data collection

This principle must be interpreted with respect to the purpose of the private company or public organization. Personal information is necessary if the purpose is legitimate, important, urgent and real, and if the loss of privacy resulting from the collection, disclosure or storage of each item of information is proportionate to that purpose (i.e. is the collection of the information rationally connected to the purpose, is the loss of privacy minimized, and is the disclosure of the required information clearly more useful to the company than harmful to the individual concerned).

In the private sector, when in doubt, personal information is deemed unnecessary. And, subject to a few exceptions, a company cannot refuse to supply a good or service, or reject a job application, because the person making the request refuses to provide personal information.

The exceptions are :

• collection is necessary for the completion or fulfillment of the contract;
• collection is authorized by law;
• there are reasonable grounds to believe that such a request is not lawful.

5.3 Collection of personal information

Personal information is collected and protected in your employee file. It is stored and updated annually. Only authorized managers and the Human Resources and Payroll departments have access to it.

6. Usage

6.1 Limiting access

G4 Holding limits access to personal information to individuals who are authorized to receive it within the company, when such information is necessary for the performance of their duties;

G4 Holding limits the use of personal information: Unless an exception is provided for by law, the company must obtain the consent of the person concerned to use their information once the purpose of the case has been fulfilled.

6.1.1 Consent for use of personal information

Companies are required to protect the confidential nature of the information they hold by preventing it from being disclosed to another company or public organisation. However, there are two exceptions:

1- if you give your consent, G4 Holding may disclose the information to which your consent applies;

2- there are cases where consent is not required. These exceptions are set out in section 18 of the Private Sector Privacy Act.

7. Disclosure

Disclosure is the period during which personal information is communicated, for example in an electronic service delivery system, by e-mail, to customer service, via Web sites or to a third party.

At this stage, the company must comply with the following obligations:

1- Obtain the consent of the persons concerned to communicate their information to a third party (e.g.: insurer or service provider), unless an exception is provided for by law;

2- Comply with the legal requirements when communicating personal information without the consent of the person concerned;

3- Comply with specific requirements applicable to the disclosure of personal information outside Quebec.

8. Storage and destruction

8.1 Storage

Retention is the period of time during which a company keeps personal information in any form, regardless of whether or not the information is actively used.

At this stage, G4 Holding ensures compliance with the following obligations:

1- Ensure the quality of personal information by keeping it up to date and accurate when used to make a decision about an individual;

2- Take appropriate security measures to ensure personal information remains secure.

8.2 Destruction

The life cycle of personal information ends when it is destroyed. At this stage, G4 Holding is committed to securely destroying personal information as soon as the purpose for which it was collected has been fulfilled, subject to the time limit stipulated by law or by a retention schedule established by government regulation (e.g. for tax purposes).

9. Security

We have implemented and continue to develop rigorous security measures to ensure that your personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

These security measures include organizational measures such as the use of security clearances and restricting access to what is necessary; physical measures and technological measures such as the use of passwords and encryption (for example, frequent password changes and the use of firewalls).

9.1 Access and amendment

You have the right to know whether we hold personal information about you and to access that personal information. You also have the right to ask questions about how this information has been collected and used and to whom it has been disclosed.

We will provide you with such information within a reasonable period of time from the date we receive your written request.

Under certain circumstances, we may refuse to provide you with the requested information. Exceptions to your right of access include the fact that the information requested concerns other individuals, the information cannot be disclosed for legal, security or copyright reasons, the information was obtained as part of an investigation into a possible breach of contract or fraud, the information is prohibitively expensive to obtain, or the information is the subject of litigation or is confidential.

When we hold medical information about you, we may refuse to disclose it directly to you and request that it be disclosed to a health care professional designated by you.

You may verify the accuracy and completeness of your personal information and, if necessary, request that it be amended. Any request for amendment will be processed within a reasonable timeframe.

Requests to access or amend personal information may be sent to the address below:

Human Resources

G4 R&D

1275, rue Jules-Brisebois

Val-d’Or (Québec) J9P 6X3

E-mail: rh@g4drilling.com