Personal Information Protection Policy – Employees

Personal Information Protection Policy – Employees

Last updated: July 29, 2026

This policy supplements Congebec’s Privacy Policy and applies to the personal information we collect and use in the context of your employment relationship. It describes the information collected for that purpose, the purposes of that collection and the particularities specific to employment. For consent, protection measures, disclosure, retention, your rights and recourse, the Privacy Policy applies, subject to the particularities described below.

1. Collection and Use of Personal Information

In the context of your employment, we collect the following personal information, which you provide to us or which is created during your employment. Your business contact details (title, company address, work telephone number and work email address) do not constitute personal information protected by this policy.

Required information. We limit our collection to what is required for the purposes of your employment, in particular:

  • Your personal details: for example, first and last name, gender, date of birth, address, email address, telephone numbers, language of correspondence and emergency contact;
  • Your banking information: for example, your financial institution and your banking details; and
  • Your identification numbers: for example, proof of citizenship, social insurance number and health insurance number.

Information created during your employment. Certain information is created throughout your employment:

  • Your terms of employment: for example, salary, years of service, benefits;
  • Your employment status: for example, schedule, full-time or part-time, permanent or temporary;
  • Your evaluations: for example, performance reports, disciplinary or suspension letters;
  • Your image: for example, captured by surveillance cameras or in photographs taken for internal communications;
  • Your medical data: for example, if you are ill and provide a doctor’s note; and
  • Your financial data relating to the group savings plan: for example, your asset allocation in your portfolio.

Company tools. The tools we provide for your employment (smartphones, tablets, computers and others) belong to Congebec. No personal information other than that provided and protected in accordance with this policy should be stored on them. If you store photos, emails or any other personal information that is not required for the purposes of your employment, we will not be able to ensure its protection; we strongly recommend that you remove it.

2. Purposes for Which We Collect Your Personal Information

We need your personal information for the following purposes:

  • Pay you;
  • Withhold taxes;
  • Provide you with benefits, group insurance, retirement plans and employee assistance programs, and liaise in this regard with our financial and legal advisors;
  • Provide general communications to employees;
  • Send you individual communications;
  • Evaluate you, promote you or change your status;
  • Ensure health and safety at work.

We also use this information to generate statistics and compile information about our workforce. For these statistical purposes, your information is not individually identifiable but forms part of an aggregate composed of data from all our employees or subgroups.

3. Your Consent — Particularities Specific to Employment

Consent is governed by the Privacy Policy. The following particularities apply to your employment:

  • When you are hired, you complete a hiring form; by signing it, you consent to the initial collection and the subsequent collection of your personal information throughout your employment, as well as to its use and disclosure as described.
  • In the event of a workplace accident, we may be required to disclose surveillance camera footage and medical information to the CNESST.
  • Withdrawing your consent may have consequences specific to employment. For example, if you do not allow us to use your banking information, we will no longer be able to pay your salary, and certain benefits may cease.
4. Disclosure to Third Parties — Particularities Specific to Employment

In addition to the cases provided for in the Privacy Policy, your personal information may be disclosed, in the context of your employment:

Service providers. In particular our payroll and workforce management provider, our group insurer and retirement plan administrator, our employee assistance program provider, the operator of our anonymous reporting line, as well as telephone or computer equipment providers, to whom we transmit your name and address to deliver the tool to you. Upon contract renewal, certain information may be disclosed to potential providers for bidding purposes, under a non-disclosure agreement.

Government bodies. In particular the body responsible for health and safety in your province, the Revenue Department (provincial or federal) and the Department of Health.

Financial and legal advisors. In limited contexts, for example: sale of all or part of the business, other financial transactions, audit of financial statements, management of investments in group savings plans, litigation and employment contracts.

Unions. Where you are covered by a collective agreement, the law may require us to disclose certain information to the union concerned or to regulatory authorities.

5. Recourse and Reporting — Particularities Specific to Employment

The recourses provided for in the Privacy Policy apply. In addition:

  • For anonymous handling of your complaint, you may use the Alias reporting line: aliassolution.com/contact/fr/congebec.
  • Employees of Congebec (Transport) inc. may also file a complaint with the Office of the Privacy Commissioner of Canada.