Protection of personal information
The Policy at a glance
Does this policy apply to you?
If you are a customer (individual), an Énergir employee, if you browse the Énergir or gas technology school websites or Énergir’s applications (collectively “Énergir’s Websites”) or if you are a natural person (individual) who does business with Énergir (such as a supplier or consultant), this Policy applies to you.
Types of personal information we collect:
Mainly:
- Information on your identity (last name, first name, marital status)
- Contact information (physical and electronic address, telephone number)
- Professional information (resume, employment status, employer name, references, etc.)
- Billing information for our services and financial information
- Information needed to meet our legal obligations (as an employer or to operate our business)
- Information needed to provide our services and conduct our business in (installed natural gas equipment, gas consumption profile, etc.)
- Information required to operate our gas network (safety, metering devices, etc.)
- Information related to recruitment and market analysis
- Information related to marketing and communication preferences
- Information on the use of Énergir’s Websites (IP addresses, logs, cookies, etc.)
- Any other personal information provided
Why we collect it
Mainly to :
- Provide you with our usual services, administer them and conduct our business
- Communicate with you
- Track relationships with our clients, analyze markets and promote our services
- Answer your questions
- Understand and improve your experience as a client or applicant to ensure that it is positive for you;
- Make Énergir’s Websites easier to use and make sure their content is relevant
- Provide information and content that is useful to you
- Recruit new talent and manage our staff (testing, pension forecasting analysis, etc.)
- Complete applications for private education teaching licences and hiring dispensations
- Deliver our training courses (use of our suppliers’ training sites, etc.)
Who handles your personal information
- Our employees and our certified natural gas partners to install your equipment
- Service providers including but not limited to:
- Survey firms
- Technology infrastructure companies: SAP, Oracle, Salesforce, SuccessFinder, Genesys
- Analytical services providers: SurveyMonkey
- Communications companies
- Consultants like Mintz, Microsoft
How we protect your personal information
We protect your personal information by technological, physical and administrative means.
You have the right to
- Request access to the personal information we hold about you
- Request changes to your personal information if it is inaccurate, incomplete, confusing or is not legally authorized to be collected, disclosed or stored (However, if the information is necessary to provide the requested service, we will not be able to provide that service.)
- Complain about how we handle your personal information.
- Request that we stop disseminating your personal information or de-index any hyperlinks connected to your name that provides access to your personal information if this causes you harm or contravenes the law (right to de-indexing)
- Request that Énergir provide you (or any other company you have specified) with computerized personal information about you in a commonly used digital format (right to portability)emander d’accéder aux renseignements personnels que nous détenons sur vous;
How to exercise your rights
You can communicate with us at the following address. I If it is a complaint about the processing of your personal information by Énergir, in addition to being able to communicate with us, you can contact the appropriate authority (Québec’s Commission d’accès à l’information and, if applicable, the Office of the Privacy Commissioner of Canada).
Cookies
- We use cookies.
- Our service providers also use cookies (which they control).
- You may enable or disable cookies that are not strictly necessary for the proper operation of Énergir’s Websites.
Governance measures we have put in place
We have appointed a privacy officer and set up a privacy program to ensure that your personal information is properly protected.
If you have any questions or concerns about how Énergir or the gas technology school protects your personal information,
please email Énergir’s privacy officer
If you are a customer (individual), an employee of Énergir, or a person browsing Énergir’s or the l’École de technologie gazière’s websites or Énergir’s applications, or if you are a natural person (individual) who has dealings with Énergir (for example, as a supplier or consultant), this Policy applies to you .
(“Énergir” or “we”) is a diversified company in the energy sector.
As such, whether it is to run our business, supply you with energy, provide you with our services and programs (energy efficiency program, etc.) or meet our legal obligations, we collect, use and disclose personal information on a daily basis. At each of these stages, respect for your personal information is important to us and we are concerned about how it is treated. We take confidentiality seriously and it is an essential part of our relationship.
This Policy sets out our commitments regarding the handling of your personal information. Its purpose is to:
- Help you understand our practices regarding the collection (what information we collect), use, disclosure, protection, retention and destruction of personal information.
- Explain how and for what purposes we collect, use and disclose your personal information as a service provider or employer
- Explain how you can assert your privacy rights (including how you can access, update or correct your personal information)
By providing us with the requested personal information (via our website www.energir.com, our customer space, career space, supplier space, the École de technologie gazière website, by email, in person, by telephone or any other means that we make available to you) and, provided that we have notified you in advance of the purposes for which it will be used, in accordance with applicable law, you:
- Agree that we can use or disclose it for those purposes
- Agree that it will be treated in accordance with this Policy
We may also, in certain cases, obtain express consent from you for the use or disclosure of your personal information. For more details, refer to the question “When and how do we obtain your consent.”
Unless we notify you otherwise, we are “responsible for handling” your personal information; in other words, it is Énergir, alone or jointly, who determines how and for what purposes your personal information will be used or is likely to be used.
Personal information is information that concerns you as an individual and that, directly or indirectly, allows you to be identified.
This Policy applies to personal information we collect, regardless of how (for example, in person, by our representatives, by telephone or through our website www.energir.com, the website of our gas technology school, through our online portals such as our customer space or supplier space or our mobile apps) (collectively, “Énergir’s Websites”).
This Policy does not apply to third party websites that may be accessed by clicking on links on Énergir’s Websites, and we are not responsible for such third party websites. If you follow a link to a third-party website, it will have its own privacy policies, which you should review before submitting your personal information.
We have a privacy policy in place to protect the personal information we collect and hold in accordance with applicable privacy laws. For example, this policy sets out the rules Énergir must follow for each of the applicable personal information principles (including the principles of accountability, determining the purpose of collection, limiting collection, consent, transparency, etc.) and to enable the individuals concerned to assert their privacy rights (including their right to access or correct their personal information, withdraw consent, and make a complaint). It also establishes Énergir’s roles and responsibilities with respect to personal information.
To follow up on this policy, we have adopted the following guidelines and procedures:
| Description | |
| Guideline on managing incidents related to personal information | It establishes the procedure to follow in the event of an incident involving personal information. For example, how to report such an incident to Énergir’s privacy officer and how to conduct a serious risk of harm assessment to determine whether the incident should be reported to the appropriate authorities, to the persons concerned or to any other authority. |
| Procedure for the collection, use and disclosure of personal information | It sets out the rules we must follow to collect, use and disclose personal information in accordance with applicable legislation. It also describes the bases of valid consent. |
| Procedure for managing individual rights | It sets out how we manage requests to exercise privacy rights provided for in the applicable regulations (such as the right to access or correct your personal information). |
| Complaint handling procedure | It sets out the various actions that we must implement upon receipt of a complaint by a person about the collection, use, disclosure, detention or destruction of their personal information, all to process this complaint. |
| Procedure for privacy impact assessments | It sets out the roles and responsibilities related to privacy impact assessments, when they are required, and how they must be conducted. |
| Training program | Our training courses, which are mandatory for all our employees, are designed to make our employees aware of the importance of protecting personal information and teach them the rules about its collection right through to its destruction. In addition, some training courses target specific sectors according to their activities. |
| Document retention schedule | It sets out how long we must keep our records, including your personal information. |
| Destruction guide | It provides for the secure destruction of personal information on all media. |
We may collect different types of personal information in the course of our activities and the operation of our business. We only collect this information if we have a serious and legitimate interest in doing so.
We collect only the information we need for the purposes we have previously determined.
What types of personal information do we collect?
We have grouped the personal information we collect into categories presented in the table below. Each of these categories contains examples. We collect only personal information that is necessary.
Please note that if you provide us with personal information about others (such as your family members), you must ensure that you have duly notified them that you are giving us their information and that you have obtained their consent to such disclosure of their information.
| Category | Exemples |
| 1. Identifying information | • First and last name • Date of birth: • Current and previous mailing address • Email address • Phone number • Student ID number |
| 2. Authentication information | • Date of birth: • Previous mailing address • Personal password |
| 3. Information on your communications with us | • Recordings of phone calls, for example with our customer service representatives • Notes on our communications with you • Written communications with you, including emails • Comments on and responses to our surveys • Video recordings by security cameras at our business locations and facilities |
| 4. Information required to supply you with energy | • Information required to connect your service address to our network (including your identifying information described above but also information to adapt our facilities to your energy needs (plans, estimate of your consumption, type of equipment, make, model, power and usage, meter number, etc.) • Your consumption (monthly) and contractual data (including hourly flow, meter on or not, etc.) • Information needed to bill you for our services, collect and monitor your payments, and where applicable carry out required collection measures (including your billing address, bank account, payment data and credit bureau) • Information to identify you in our customer space (user names and encrypted password) • Information needed to operate our network (including your meter number, and active or inactive status of your meter) |
| 5. Information required to offer you our various programs | • Information that allows us to determine your eligibility for our energy efficiency programs, for example, (including type of appliance purchased, make, model, price, installation price) |
| 6. Information for marketing purposes (prospecting etc.) | • Information about your interest in gas and your identifying information so that we can contact you again (last name, first name, telephone number, email address) • Information about your natural gas equipment (make, model, year) so we can contact you at the end of your equipment’s useful life • Information on your level of satisfaction and expectations regarding our services |
| 7. Information about your use of Énergir’s Websites | • Information collected through cookies or similar tracking technologies (including interaction with our advertisements and content on Énergir’s Websites) • Browsing preferences (language) • Browsing path and history • Your IP address • Information about your computer, phone or tablet, operating system or browser |
| 8. Information on your preferences and communication choices | • Your choices and preferences on how we should communicate with you • Information about our services • Your choice of language of communication |
| 9. Market analysis information | • Risk of you using another form of energy • Possible equipment changes |
| 10. Recruitment information | • Resume • Credit or criminal history, if required • Information on your professional affiliations • Other recruitment information (such as your teaching certificate number) |
| 11. Information required for personnel management | • Mailing address • Banking information • Social insurance number • Information needed for managing group insurance |
¹ Telephone calls with some of our representatives can be recorded and monitored to ensure the quality of our services. In such a case, a message will alert you to this recording during this call.
We primarily collect your personal information directly from you. However, we may collect information from a third party if you have consented to it or if we have the legal authority to do so.
Your personal information is generally collected by our employees. However, we may assign this task to a third party (for example, our certified natural gas partners, a service provider such as a survey firm or our consultants, or a credit bureau). In such cases, we ask them to indicate to you that they are collecting your personal information on behalf of Énergir.
How and when do we collect your personal information?
We may collect your personal information through various means, including in person by our representatives, by telephone, by completed forms or surveys, or by Énergir’s Websites. The collection of your personal information by the various means mentioned may occur at various times, including:
- As part of natural gas distribution to your home (meter readings, technicians’ visits to your home to work on your or our equipment, etc.)
- When you contact our Customer Service Department, sales representatives or certified natural gas partners about installing your equipment
- When you visit your customer space or the Énergir Websites, including via cookies
- Through the programs you participate in (such as energy efficiency program and subsidies for dual-energy)
- When you take training sessions on topics such as natural gas and geothermal energy
- Through surveys or when you sign up for our online communications
- When you visit our facilities
- When you participate in training programs such as at our gas technology school
Do we collect personal information using technology that includes features for identifying, locating or profiling you?
When using Énergir’s Websites, we can identify and locate you through your IP address and the use of cookies. Before collecting this information, we will inform you of the means available to activate the functions to identify, locate or perform profiling. For more information, please refer to our Cookies Policy.
When and how do we obtain your consent to collect and use your personal information?
As provided for by law, your consent may be presumed or expressed.
We will have your presumed consent when you provide us with the requested personal information (via our website www.energir.com, customer space, career space, supplier space, the gas technology school website, by email, in person, by phone or by any other means that we make available to you) after we have informed you beforehand, in a transparent, simple and clear manner, of the following information:
- The purposes for which your personal information is collected, that is, the objective of using or disclosing the personal information requested
- The means by which your information is collected
- Your access and rectification rights provided for by law
- Your right to withdraw your consent to the disclosure or use of your collected information. (We will explain the consequences of refusing or withdrawing your consent.)
- If applicable, the name of the third party for whom the information is collected
- If applicable, the name of the third parties or categories of third parties to whom it is necessary to disclose the information for the purposes indicated to you, except as provided for by law
- If applicable, the possibility that the information may be disclosed outside Québec
If you provide us with your personal information after receiving these explanations, in accordance with the law applicable to Énergir, you are presumed to have consented to the use and disclosure of your personal information provided to us for the purposes described above.
However, in the following situations, we will seek your express consent (an active and positive gesture on your part, such as a check box), in writing or verbally, where provided for by law:
- When we wish to collect personal information from a third party, except as provided for by law
- When we wish to use your personal information for purposes other than those for which it was originally collected (and for which we already have presumed consent from you as explained above), except as provided for by law
For more information on these exceptions, please refer to the section “How do we use your personal information?”
- When we use technological means to identify you, locate you or profile you, such as the use of cookies
For more information on cookies, please refer to section 14 How do we use cookies and similar technology?
- When we wish to disclose personal information to a third party who requests access to it, except as permitted by law
Do I have to give you my personal information?
When we request your personal information, we indicate to you, unless it is implicit to the context, whether or not the information is necessary to perform the services requested and what are the consequences of refusing or withdrawing consent.
For example, it is essential that you provide us with your identifying and contact information so that we can create your customer account and supply you with natural gas. However, you are completely free to participate in our surveys or sign up for our digital communications.
Managing our gas network
- Providing and administering our usual services and conducting our business
- Notifying you of meter changes or work or incidents on our gas system
- Contacting you when we need to perform work on our equipment requiring your presence
- Raising awareness on the security of our network
- Maintaining the safety and reliability of our gas system and natural gas supply and accurately forecasting our customers’ natural gas demand
Maintaining our business relationship with you
- Managing and promoting the programs for which we are responsible (including energy efficiency and subsidy programs)
- Contacting you
- Answering your questions
- Ensuring the continued effectiveness and quality of our business processes
- Tracking customer relations (satisfaction surveys, sales statistics) and promoting our current or new services (marketing campaigns)
- Enforcing our rights, including ensuring that we are paid, through debt collection agencies or other legal means
- Creating your gas technology school learner record
Offering you services that meet your expectations
- Informing you about our programs and offers, especially those that will allow you to reduce your energy consumption and greenhouse gas emissions if you wish
- Providing you with information and content that is useful to you
- Knowing our customers and understanding and ensuring your customer experience is positive
- Facilitating the use of Énergir’s Websites and ensuring that their content is relevant and presented in the most efficient manner for you and your devices (office, mobile or other)
Gathering statistics
- Gathering statistics and performing analyses to get to know our customers better, improve customer satisfaction and service quality and design new offers and services
Meeting our legal and regulatory obligations
Recruiting and managing our personnel
- Recruiting new talent, processing your applications for the positions we offer (applicant assessment, background checks (previous employment, credit score, etc.)
- Managing our staff
However, we may wish to use your personal information for purposes other than those listed above. In such cases, we will inform you of the new purpose and seek your prior consent. For more information on consent, you can refer to “Learn more: When do we obtain your consent to collect and use your personal information?”
Notwithstanding the above, it is important for you to know that the law allows us to use your personal information without your consent in certain situations, including when it is used:
• There is a relevant and direct link to the purpose for which consent was collected
• Is clearly to your benefit
• Is required for the prevention and detection of fraud or for the assessment and enhancement of security and protection measures
• Is required for supplying or delivering natural gas or a service you have requested
So, for example, we could use your gas consumption to determine whether you are eligible for a program that would allow you to save money, because that’s obviously to your benefit.
What steps do we take to ensure that your personal information is accurate, complete and up-to-date before using it?
When we use your personal information, we make sure we use your most recent information based on the information you have provided to us.
You have an important role to play in ensuring that your information is accurate and up-to-date. To that end, we have provided ways for you to update or correct your personal information.
To update your information as a:
- customer, contact our Customer Service Department or consult your customer space
- job applicant, go to our job posting platform or contact our talent acquisition advisor responsible for your application file.
- employee, go to the HR Portal or contact the Human Resources Service Centre.
- learner at our gas technology school, contact the school’s customer service department.
If you believe that we are using personal information about you that is inaccurate, incomplete or ambiguous (i.e., subject to multiple interpretations), you may exercise your rights described under “What rights do you have over your personal information?
Only our employees who need access to your information to perform their duties have access to it.
However, we may also need to entrust your personal information to third parties so they can perform certain tasks or functions for us. We also share your personal information with third parties when you request us or consent to do so.
However, there may be instances where, by law, we may disclose your personal information to third parties without your consent, as mentioned under “Learn more: When and how do we obtain your consent to collect and use your personal information?”
When we entrust your personal information to service providers so that they can perform the services provided, we ensure that written contracts with them clearly state our requirements as to the measures they must take to protect your information as we would ourselves. Among other things, we ensure that our suppliers use your personal information only to provide the services we have retained.
Communicating with our service providers
As part of our business, we sometimes have to entrust your personal information to third parties to perform certain tasks or functions for us. As a result, we may legally disclose your personal information to third parties without your consent, for example:
• Service providers that process the personal information on our behalf, including for application development, Internet sites, data hosting including cloud services, maintenance and other services
• Information technology service and product providers
• Service providers for the management of Énergir’s employee and retiree benefits (pension, group insurance) or personnel management (recruitment, career development);
• to payment service providers
• Collection service providers and credit bureaus
• Our external legal advisors
• Our certified natural gas partners that install your equipment
• Our training services providers
These third parties could therefore have access to your personal information or process it as part of the services they deliver. We limit the information we provide to these service providers or third parties only to the information that is necessary to enable them to perform their services, and the contracts we have with those service providers require them to keep that information confidential.
Other legally authorized communications
We may disclose, in accordance with the law, your personal information without your consent to certain bodies, including:
• Regulatory authorities, government departments and agencies that request it from us by virtue of powers granted to them by law or when this information is necessary for the enforcement of a law
• Police services if such information is necessary for an investigation or the subject of a search warrant or production order
• A court that orders us to do so
More concretely, we may disclose your personal information if we are required to do so by law or believe in good faith that such disclosure is necessary to comply with applicable law in response to a court order or a government search warrant, or otherwise to cooperate with such government authorities and law enforcement agencies.
Do we share personal information outside the province of Québec?
Yes, particularly to our hosting service providers. However, before doing so, we ensure that your personal information is protected as it is here in Quebec. Government departments and agencies in these countries (as may be the case in Quebec) may access your information in accordance with their local laws.
We retain your personal information for as long as we fulfill the purposes for which we collected it. Then we keep them for the extra period of time under the conservation rules that we have adopted. This additional time is provided for in accordance with certain legislative or regulatory requirements or to produce this information as evidence in the event that we are party to a claim or suit.
Please contact us for more information on how long we keep your personal information. See “How to contact us?
We may store and process your personal information at our various facilities in Quebec and in countries where we engage third-party service providers (for example, elsewhere in Canada or the United States). So, you accept the transfer of information to places other than Quebec, where privacy rules may be different from those in Quebec. When information is located outside Quebec, it is subject to the laws of the country in which it is located, and may be disclosed to governments, to the courts or law enforcement or regulatory agencies of the country in question in accordance with their laws.
However, this Policy governs our practices regarding your personal information at all times.
Because your trust is important to us, we implement generally recognized and accepted security standards to protect your personal information throughout the period that we are responsible for it (from collection to destruction).
When we decide on the measures to be applied, we ensure that they are reasonable in light of factors such as the sensitivity of the personal information in question, how it is used, its quantity and the medium on which it is kept.
The security measures we take against accidental loss, modification, disclosure or unauthorized access, misuse, accidental or unlawful destruction, or any other form of illegal handling of personal information in our possession fall into three categories :
• Technological security measures (such as the use of VPN, firewalls, logging of Énergir employees’ actions affecting your personal information, staff access to the information on a need-to-know basis only)
• Physical security measures (such as access cards to our facilities, cameras, locked premises and storage areas)
• Organizational security measures (e.g., authentication procedures when communicating with us or when using our online portals such as your customer space, cyber and privacy training and awareness, internal policies on governance, information security and responding to privacy breaches, and security incident detection and management procedures that may affect your personal information)
We periodically review these security measures to ensure that they are properly enforced and still fully effective and appropriate, given the evolution of our systems and available technologies.
However, it is important to note that no method of transmission over the Internet or any means of electronic storage is 100% secure. We cannot therefore ensure or guarantee the absolute security of your personal information that you provide to us. and you do so at your own risk. We also cannot guarantee that such information will not be accessed, obtained, disclosed, altered or destroyed as a result of a breach of our physical, technical or administrative safeguards.
Do you have a role to play in protection your personal information?
Of course!
Choosing a strong password to manage your access to the secure areas we provide (for example, your customer space) is an essential step in preventing intrusions into your account. The same applies to ensuring that your password is known only to you.
What is a strong password? It is a password that is complex enough that a malicious person cannot guess it from information on social networks or online (such as your name, your children’s names, date of birth, etc.).
Thus, we recommend that you create a password with a minimum of 8 characters consisting of lower case and upper case letters and at least one number and with no reference to yourself (do not use your name, date of birth, etc.). You should also change it regularly and make sure it differs from the passwords you use from third parties.
What do you do if you believe that your personal information we hold has been compromised?
Please contact us if you have reason to believe that your personal information has been compromised. See “How to Contact Us?
In certain circumstances and in accordance with applicable privacy laws, you have the following rights:
Access to your personal information - the right to ask Énergir to confirm whether it has any personal information about you and to provide you with a copy of that information. At your request, computerized personal information will be provided to you in the form of a written and intelligible transcript.
In the case of an access request, we will require that you identify yourself to ensure that the request is indeed from you. You may also be charged a reasonable fee for the transcription, copying or transmission of this information.
Rectification – You have the right to require correction of (1) any personal information that we hold that is inaccurate, incomplete or ambiguous (i.e., subject to multiple interpretations), or (2) any information that is not legally authorized for collection, disclosure or retention. In the case of a request for rectification, we will require that you identify yourself to ensure that the request is indeed from you.
Withdrawal of consent: Once we have obtained your consent to the handling of your personal information, you have the right to withdraw your consent to the disclosure or use of your personal information collected. However, we may have the right to continue to process information under the law.
Complaint: You have the right to file a complaint with the Commission d’accès à l’information du Québec, or other competent privacy supervisory authority, regarding the application of a legislative provision respecting the access or correction of personal information.
Decision based exclusively on automated processing: If we need to make such a decision, we will let you know, at the latest when we inform you. We will also inform you of:
1) the personal information used to make the decision
2) the reasons, as well as the main factors and criteria that led to the decision
3) your right to have the personal information used to make the decision corrected
Automated decisions - You have the right to challenge any automated decision when such a decision has significant legal or similar impact, and the right to request that it be reconsidered.
Right to de-index: You have the right to request Énergir to stop disseminating your personal information or to de-index any hyperlinks attached to your name that provide access to your personal information if doing so causes you harm or contravenes the law.
Please contact us to exercise any of these rights. See the section “How to Contact Us?
For detailed information about the cookies we use, please refer to our Cookies Policy, which is part of this Privacy Policy.
To ask questions or make comments about this Policy or about personal information, personal information collected from you, the categories of people who have access to that information at Énergir, the length of time your information is retained, how to exercise your rights, file a complaint or obtain information about our policies and practices regarding our service providers outside Canada, please contact our privacy officer in one of two ways:
- By email at [email protected]
- By regular mail at the following address:
Privacy Officer
Executive Director Legal Affairs
Énergir
1717 rue du Havre
Montréal, QC H2K 2X3
We reserve the right, at our sole discretion, to amend this policy at any time, in whole or in part, in accordance with applicable privacy regulations.
These changes will come into effect as of the publication of the new policy or as of a specified future date. This publication will serve as notification of the changes to you. We encourage you to visit this page regularly to review the changes and stay informed about the handling of your personal information.
Your use of Énergir’s Websites once these amendments come into force will constitute recognition and acceptance of the new policy. If you are not satisfied with the new policy, please discontinue all use of these sites.
This policy came into effect on September 2023.