Privacy and Governance Policy
Espace M
Last updated: April 27, 2026
Privacy Officer (RPRP): Marc-André Cloutier
1. Scope of the Policy
This policy applies to all personal information collected and processed by Espace M, including that of our clients, our clients’ own customers (third-party data), as well as our employees and candidates.
2. Our Technology Ecosystem (Enterprise Security)
To ensure compliance with Law 25, Espace M prioritizes “Enterprise-grade” tools where data is contractually protected against being used to train public AI models:
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Google Workspace (Enterprise): Including Gmail, Drive, Meet, and Gemini.
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Advertising Platforms: Meta, TikTok, Google Marketing Platform (GMP), Amazon Advertising. We ensure that data sharing (e.g., audience lists, pixels) respects the consents obtained by our clients.
3. Personal Information of Employees and Candidates
We collect the data necessary for human resources management:
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Recruitment: Resumes (CVs), cover letters, and test results.
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Hiring: Social Insurance Numbers (SIN), void cheques, benefits files, and performance evaluations.
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Access: This data is stored in secure environments (Google Workspace Enterprise) and is accessible only to authorized personnel (HR and Management).
4. Use of Data and Consent
We use data solely for:
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Providing marketing services and fulfilling client contracts.
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Managing the employment relationship.
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Optimizing advertising campaigns via partner platforms.
5. Transfers Outside of Quebec and Subcontracting
In the course of our business activities, personal information may be transferred to platforms whose servers are located outside of Quebec (e.g., the United States).
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Assessment: Before using any new tool (e.g., an AI or SaaS software), the Privacy Officer conducts a Privacy Impact Assessment (PIA) to verify that the provider offers adequate protection.
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Contracts: We require Data Processing Agreements (DPA) with all our subcontractors.
6. Data Lifecycle: Retention and Destruction
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Retention: Data is kept for the period required by legal obligations (e.g., 7 years for tax/payroll records) or for the duration of the contract.
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Destruction: Once the retention period has expired, information is securely destroyed or anonymized.
7. Privacy Incident Management
Espace M maintains an official incident register.
Any employee who identifies a potential leak or unauthorized use (e.g., uploading sensitive data to an unapproved AI or sending an invoice to the wrong client) is obligated to inform the Privacy Officer immediately.
We commit to informing the relevant authorities and the affected individuals in the event of a risk of serious injury.
8. Your Rights
In accordance with Law 25, you have the right to access, rectify, withdraw consent for, and request the portability of your data. For any requests, please contact:
Marc-André Cloutier
marc-andre@espace-m.ca
(514) 730-8719

