As a religious congregation that collects personal information through technological means in Quebec, the Corporation des Syndics Apostoliques des Frères Mineurs ou Franciscains, the Corporation des Syndics Apostoliques des Frères Mineurs ou Franciscains de la Province Saint-Joseph du Canada and L’Oeuvre Franciscaine – Les Franciscains (collectively hereinafter the “Congregation,” also known as the “Franciscans of Canada”) must publish on its website a confidentiality policy that is written in simple and clear terms.
This confidentiality policy is part of a set of policies and practices governing the Congregation’s handling of personal information, detailed information about which is also published on its website.
The following are the main questions that this confidentiality policy answers, in relation to the following elements:
- Organization
- Who is accountable for the personal information collected?
- Categories
- What personal information is collected and according to what criteria?
- Consent, refusal, and withdrawal
- What forms of consent are required for the use and communication of the personal information collected?
- What should you do and what are the consequences if you refuse to provide personal information or the means to provide it?
- How can you withdraw your consent to the use or communication of the personal information collected?
- Purposes
- For what purposes is personal information collected?
- Means
- By what means is personal information collected?
- How are you informed in advance of the use of cookies, including, where applicable, functions that allow you to be identified, recognized, located, or profiled, and the means to activate these functions?
- Communication
- To which categories of third parties may it be necessary to communicate personal information collected for the specified purposes?
- Can personal information be communicated outside Quebec?
- Protection and security
- What measures are taken to ensure the confidentiality and security of personal information?
- Access and correction
- What are your rights of access and rectification with respect to the personal information collected about you, and how can you exercise them?
- Questions, requests, and complaints
- Who can you contact with any questions or requests regarding this confidentiality policy or any complaints regarding the protection of personal information under the responsibility of the Congregation?
- Effective date and amendments
- When did this confidentiality policy come into effect and when was it last amended?
1. PERSONAL INFORMATION UNDER THE CONGREGATION’S CONTROL
When the Congregation decides to collect personal information and establishes the purposes for which it is collected, used, or communicated (whether it collects, uses, or communicates it itself or has an agent or service provider do so on its behalf), that personal information is under the control of the Congregation.
If the Congregation acts as an agent and the communication of personal information to the Congregation is necessary for the performance of the mandate, such personal information is instead under the control of the principal.
2. COLLECTED PERSONAL INFORMATION
Collection for specified purposes: Privacy laws allow the Congregation to collect, for a serious and legitimate interest, personal information about another person that is relevant to the stated purpose of the file, provided that the purposes of the collection are determined before the collection takes place.
Thus, in the context of your relationship with the Congregation or when you use a digital platform, an application service, or any other virtual space controlled by the Congregation (website), you may be asked to provide certain personal information about yourself.
Categories of information from members, employees, or the public: Provided that it is necessary for the purposes determined prior to collection, the Congregation may collect personal information from its members, employees, or the public, including the following categories:
| CATEGORIES OF INFORMATION | EXAMPLES |
|---|---|
| Identification : | Full name, date of birth, sex at birth, portrait photo, government identification codes, family relationships, genealogy, height, weight, physical characteristics, etc. |
| Personal contact information: | Email address, residential or mailing address, telephone numbers, emergency contacts, residential history, etc. |
| Religious information: | Date of sacraments and ordination, role and activities within the Congregation, missionary projects, missions, pilgrimages, retreats, conferences, etc. |
| Education: | Degrees, institutions attended, fields of study, years of schooling, academic results, training, certificates, certifications, etc. |
| Financial situation: | Salary and other sources of income, credit history, bank details, billing and payment information, etc. |
| Behavior: | Participation in events and other activities, social media and website posts, etc. |
| Personal preferences: | Preferences regarding communication methods, charitable giving, donations made, donation tax receipts, pledges, newsletters, etc. |
| Technical information: | IP address, browser type and version, operating system, screen resolution, information about the device used, etc. |
| Web audience measurement: | Connection dates and times, pages visited, actions taken on a website or other interactions with online content, etc. |
| Demographics: | Age, ethnicity, nationality, language(s), membership in an identifiable group, etc. |
| Sensitive information: | Information that gives rise to a high degree of reasonable expectation of privacy, particularly because of its medical, biometric, or otherwise intimate, or due to the context of its use or communication, including criminal and/or disciplinary records, police reports, etc. |
Limitation: The Congregation will only collect your personal information that is necessary for its legitimate and specified purposes for which it is collected, and will not use or communicate this personal information for any other purpose, unless you give your additional consent or the Congregation is authorized or required to do so by applicable law.
Exceptions:You should be aware that personal information which by law is public or concerning the performance of duties within an enterprise by an individual, as well as the collection, retention, use, or disclosure of journalistic, historical or genealogical material collected, held, used or communicated for the legitimate information of the public, is excluded from the application of laws protecting privacy or certain parts of laws protecting privacy.
3. CONSENT, REFUSAL, AND WITHDRAWAL
Consent by operation of law: Generally, privacy laws ensure that when you provide the Congregation with personal information about yourself, you consent to its use and communication to third parties for the purposes for which the information is collected, provided that you are informed at the time of collection (and subsequently upon request) of certain matters, including: (1) the purposes in question, (2) the means by which the information is collected, (3) the rights of access and correction provided for by law, (4) your right to withdraw your consent to the communication or use of the information collected; (5) the name of the third party for whom the information is being collected, if applicable, and (6) the possibility that the information may be communicated outside Quebec.
Consent for other purposes: When personal information is to be used within the Congregation for purposes other than those for which it was collected, additional consent from you as the individual concerned is generally required. When sensitive personal information is involved (information that gives rise to a high degree of reasonable expectation of privacy), this consent must be expressly given.
Refusal: If you refuse to provide personal information or to have it collected by a particular means, or to have it used or communicated for a purpose mentioned at the time of collection, please notify our person in charge of the protection of personal information. Of course, the Congregation can only comply with certain requests if you provide the personal information required to process those requests. As a result, the Congregation may be unable to respond to a request you make or carry out a mandate you entrust to it if you refuse to provide this information.
Withdrawal of consent: You may withdraw your consent to the use or communication of personal information collected about you, subject to restrictions provided for by law or contract and reasonable notice. If you wish to withdraw your consent, please notify our person in charge of the protection of personal information.
4. PURPOSES OF COLLECTION
We collect personal information for the purposes listed below.
- The purposes for collecting information from its members generally relate to establishing and maintaining a record of the member’s commitment and status within the Congregation and their history prior to joining the Congregation.
- The purposes for collecting information from employees generally relate to the hiring, evaluation, and compensation of employees and the management of the employment relationship between employees and the Congregation.
- The purposes for collecting information from the public generally relate to communications between the Congregation and individuals in the public, prayer intentions, donations, and the interest or participation of individuals in activities or projects related to the Congregation.
More generally, the Congregation collects personal information for the following purposes:
- Administration, audits, and enforcement:
- administering the Congregation’s business;
- opening and maintaining files and processing requests;
- soliciting and evaluating applications for job openings, including verifying references, credentials, and background checks;
- managing billing and processing payments.
- Communication and publication:
- communicate with our members, staff, suppliers, relevant members of the public, or stakeholders;
- responding to questions addressed to us;
- distributing or transmitting notices, announcements, publications, invitations, correspondence, and other mail.
- Compliance and prevention:
- complying with our legal and regulatory obligations;
- prevent and detect fraud-related risks.
- Quality control and improvements:
- improve our website, including through web analytics;
- processing and resolving reservations, dissatisfaction, and complaints.
- Protection, security, and defense:
- protecting your rights;
- protecting the property or security of the Congregation or ensuring its defense.
- Internal management and profiling:
- acquiring, developing, redesigning, or managing our own information systems;
- managing knowledge and expertise among staff;
- use and communicate your information for the purposes and to the third parties or categories of third parties identified prior to the use of technology that includes features that identify you, locate you, or profile you, in accordance with your privacy settings applicable to that technology (e.g., a widget that manages cookies).
- enforce the terms of use of the website.
- Purposes determined at a later date:
- any other purposes to which you have consented, either expressly, implicitly, or by operation of law.
In addition, privacy laws generally allow the Congregation, without your consent, to use personal information for purposes other than those for which it was collected, particularly when its use is:
- for purposes consistent with those for which it was collected;
- clearly to your benefit;
- necessary for the prevention and detection of fraud or the evaluation and improvement of security and safety measures; or
- necessary for study, research, or statistical purposes, and the personal information is de-identified.
5. METHODS OF COLLECTION
Personal information relevant to the Congregation will be collected by various technological or other means, such as forms, conversations (by telephone or in person), correspondence, or any other means of communication through which you contact us. More specifically, personal information may be collected by the following means, among others:
- Voicemail
- Chat
- Documents (on paper or other media), including technological documents
- Video and/or audio recording
- Electronic form
- Online books and registers
- Social media messaging
- Electronic notifications
- Portals
- Authentication service
- Electronic signatures
- Cloud file storage
- Fax
- Cookies and other technologies that include features that identify, recognize, or locate you, or that profile you
- Text messages
Cookies: Certain personal information may be collected using technology that includes features that identify, locate, or profile visitors to the Congregation’s website, including cookies (commonly known ascookies). Before such technology is used in relation to you, the Congregation will inform you, via a widget or other appropriate means, of the use of this technology and the means available to activate the functions that identify, locate, or profile a visitor. (A cookie is a piece of information that, when visiting a website or using a mobile application, is transmitted between a server and a web browser or device.)
6. COMMUNICATION OF PERSONAL INFORMATION
Limitation on communication: In principle, no one may communicate to a third party the personal information they hold about you, unless you consent to it or the applicable privacy laws provide for it.
Categories of recipients: If necessary, the Congregation may, without your consent, communicate personal information to certain third parties, including those belonging to any of the categories of persons listed below, to the extent that such communication is necessary, in the performance of their duties, to achieve the purposes for which they received the information:
- service providers and/or agents, including an organization or individual if such communication is necessary for the performance of a mandate or the execution of a service or business contract that the Congregation entrusts in writing to that organization or individual (e.g., our service providers for hosting our website, cloud storage of files, or outsourcing of data processing), indicating in the mandate or contract the measures that the agent or contractor must take to ensure the protection of the confidentiality of the personal information communicated, so that this information is used only in the exercise of their mandate or the performance of their contract and so that they do not retain it after its expiration;
- government authorities and law enforcement agencies, when required by applicable laws. For greater clarity, we may communicate personal information and other information if we are required to do so by law, if we believe in good faith that such communication is necessary to comply with applicable laws, in response to a court order, subpoena, government search warrant, or otherwise to such government authorities and law enforcement agencies;
- the Congregation’s insurers;
- spouse or close relative of a deceased person, if knowledge of this information is likely to assist the requester in the grieving process and the deceased individual has not documented in writing their refusal to grant this right of access; and
- any other entity or person, when the law allows or requires us to communicate personal information without your consent.
Communication outside Quebec: Your personal information may be communicated outside Quebec, where legal regimes applicable to the protection of personal information differ from those in Quebec. Such communication outside Quebec is possible, in particular, when the Congregation entrusts a person or organization outside Quebec with the task of collecting, using, disclosing, or retaining such personal information on its behalf. However, before disclosing personal information outside Quebec, the Congregation conducts a privacy impact assessment to ensure that it will be adequately protected. Nevertheless, pursuant to a legal order issued in Quebec or outside Quebec, your personal information may be made available to government authorities or law enforcement agencies in that jurisdiction, since no contract or other means can override the laws of a government administration, whether domestic or foreign.
Communication to the Congregation: Generally, privacy laws do not allow a person who operates a business to communicate personal information about you to third parties without your consent, except in certain circumstances (e.g., to their attorney, agent, or service provider under certain conditions, or to other categories of persons provided for by privacy laws applicable to the situation). If, as a business operator, you communicate personal information about an individual other than yourself to the Congregation (or its service providers and agents), you may only do so with the consent of the individual concerned or if the law allows you to do so without the consent of the individual concerned.
7. PROTECTION AND SECURITY MEASURES
Reasonable measures: The Congregation takes physical, organizational, and technical security measures to ensure the protection of personal information that is collected, used, communicated, retained, or destroyed, which are reasonable considering, in particular, the sensitivity of the information, the purpose for which it is used, the amount of information, the method of storage, its distribution, format, and medium.
Scope of measures: Security measures protect personal information against, among other things, loss or theft, as well as unauthorized access, communication, copying, use, or modification, and include reasonable measures to authenticate your identity as the individual to whom the information relates.
Description of measures: We implement, among other things, the measures briefly described below.
- Physical measures
- We restrict access to our offices to authorized persons and control this access through individualized access keys.
- We lock filing cabinets when the sensitivity of the personal information they contain warrants it.
- Organizational measures
- Staff training and awareness: We ensure that Congregation staff who have access to your personal information undergo training to acquire and maintain vigilance and appropriate behavior with regard to privacy and the protection of personal information.
- Minimization: We limit the personal information we collect to what is necessary to fulfill the predetermined purposes for which the information is collected.
- Governance policies and practices: We have established and implemented policies and practices governing the Congregation’s governance with respect to personal information and ensuring the protection of such information.
- Technical measures
- Data encryption: We use encryption technologies for both data in transit and data at rest to render it unusable by anyone who does not have the necessary cryptographic key to decrypt it.
- Firewalls: We implement firewall systems to filter data flows between our internal network and external networks.
- Intrusion detection systems and tests: We monitor and block unauthorized access to our networks and information systems.
- Regular backups: We perform regular data backups to enable recovery in the event of loss or damage.
- Updates and patch management: We keep our software and systems up to date with the latest security patches to protect against known vulnerabilities.
- Two-factor authentication: To verify and validate the identity of authorized users, we require a control process where they must regularly provide two elements from two separate authentication factors.
8. ACCESS AND CORRECTION
Right of access: When the Congregation holds personal information about you, it will, at your request, confirm its existence and provide you with access to that information by allowing you to obtain a copy. At your request, any computerized personal information will be provided in the form of a written and intelligible transcript. Unless this raises serious practical difficulties, computerized personal information collected from you, and not created or inferred from personal information about you, will be provided to you, at your request, in a structured and commonly used technological format. This information shall also be communicated, at your request, to any person or organization authorized by law to collect such information. Where the applicant is a person with a disability, reasonable accommodation measures shall be taken, upon request, to enable him or her to exercise the right of access provided for in this section.
Right of rectification: In addition to the rights provided for in the first paragraph of section 40 ofthe Civil Code of Québec, you may, if the personal information concerning you is inaccurate, incomplete, or ambiguous, or if its collection, communication, or retention is not authorized by law, require the Congregation to rectify it.
9. QUESTIONS, REQUESTS, AND COMPLAINTS
Handling of questions, requests, or complaints: Any questions or requests regarding this confidentiality policy or any complaints regarding the protection of personal information under the Congregation’s control may be submitted, in accordance with the established handling process, to the Congregation’s controller, to whom the role of person in charge of the protection of personal information has been delegated. His contact information is published in this section of the Congregation’s website, among the detailed information about the policies and practices governing the Congregation’s handling of personal information.
10. EFFECTIVE DATE AND AMENDMENTS
Effective date: This confidentiality policy is effective as of the date indicated below.
Amendments: Any amendments to this confidentiality policy will be subject to a notice of amendment published on the Congregation’s website and disseminated by any means appropriate to reach the individuals concerned.
Notice of change: Unless circumstances warrant a shorter period, any change shall take effect only after a period of 15 days from the date of publication of a notice to that effect. This notice shall indicate:
- the date of its publication;
- the general purpose of the changes to the confidentiality policy, which may be specified in the section devoted to the confidentiality policy on the Congregation’s website;
- the date on which the changes take effect;
- the reasons why the policy must be amended within this shorter period if the notice mentions a period shorter than 15 days.
Effective date of this version: October 10, 2025.
Previous version effective since November 22, 2021.