Privacy Policy

groupe sutton – GO, Services Immobiliers inc. (hereinafter “groupe sutton – GO”) provides a secure Web environment for its Internet users.

groupe sutton – GO is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (hereinafter, the “Act”) and as such groupe sutton – GO strives to maintain the highest standards of confidentiality with respect to personal information provided to it by its customers, suppliers and other businesses in the course of its real estate brokerage activities, including but not limited to, through groupe sutton – GO’s website (the “Website”), its social networks, its advertisements and for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with its obligations under the Act.

What do we mean by “personal information”?

Personal information is information about a natural person that directly or indirectly allows that person to be identified. Writing, images, videos and sound recordings may contain personal information. In the course of its professional activities, groupe sutton – GO may collect personal information such as a person’s name, home address, date of birth, identification information, social insurance number, income information, marital status and so on.

The protection principles listed below apply to the collection, use and transmission of personal information that Internet users may provide in the course of using the Website.

1. Responsibility

groupe sutton – GO is responsible for protecting the personal information it holds in the course of its real estate brokerage activities. To this end, groupe sutton – GO has adopted a confidentiality policy, as well as policies and practices governing the governance of personal information, the purpose of which is to provide a framework for the collection, use, communication, retention and destruction of personal information.

2. Collection of personal information

groupe sutton – GO collects only the personal information required to carry out its real estate brokerage activities. For example, information may be collected for the purposes of carrying out a real estate transaction, maintaining files, monitoring professional practice by the Organisme d’autoréglementation du courtage immobilier du Québec (OACIQ) or any other purpose determined by groupe sutton – GO and made known to the person whose consent is being sought.

groupe sutton – GO invites its employees, team members or administrative assistants, as the case may be, to explain in simple and clear terms to the person concerned the reasons for collecting his or her personal information and to ensure that they understand.

For the purposes of collecting personal information, groupe sutton – GO encourages its employees, team members and administrative assistants, as the case may be, to use the standardized forms developed by the OACIQ.

groupe sutton – GO may also collect personal information verbally through correspondence with individuals involved in a transaction or through various documents submitted as part of a real estate transaction (identification, financial documents, powers of attorney, etc.).

3. Use and disclosure of personal information

Personal information is used and communicated for the purposes for which it was collected and with the consent of the person concerned. In certain cases provided for by law, personal information may be used for other purposes, for example, to detect and prevent fraud or to provide a service to the person concerned.

groupe sutton – GO may be required to disclose personal information to third parties, for example, suppliers, co-contractors, subcontractors, agents, insurers (such as the Fonds d’assurance responsabilité professionnelle du courtage immobilier du Québec [FARCIQ], the Fonds d’indemnisation du courtage immobilier du Québec [FICI]), professionals, financial or credit verification institutions, providers of electronic document management (EDM) systems and other regulators, or outside Québec.

groupe sutton – GO may, without the consent of the person concerned, communicate personal information to a third party if such communication is necessary for the execution of a mandate or a service or business contract. In such cases, groupe sutton – GO will draw up a written mandate or contract setting out the measures to be taken by its agent to ensure that the personal information entrusted to it is protected, that it is used only for the purposes of the mandate or contract, and that it is destroyed once the mandate or contract has ended. The co-contractor must also undertake to cooperate with groupe sutton – GO in the event of a breach of confidentiality of personal information.

Before communicating personal information outside Québec, groupe sutton – GO takes into account the sensitivity of the information, the purpose for which it is to be used and the protection measures that will be in place outside Québec. groupe sutton – GO will only communicate personal information outside Québec if its analysis demonstrates that it will benefit from adequate protection in the place where it is to be communicated.

4. Retention and Destruction of Personal Information

Once the purposes for which the personal information was collected or used have been fulfilled, groupe sutton – GO must destroy it, subject to the retention period stipulated by law. In this regard, groupe sutton – GO’s professional obligations require it to keep its files for at least six (6) years following their final closing.

5. Safety measures

When collecting, using, storing and destroying personal information, groupe sutton – GO applies the necessary security measures to protect the confidentiality of personal information. The personal data collected will be stored on servers and in electronic data management systems equipped with mechanisms and using recognized standards of protection to ensure the security of personal information that its customers, suppliers and other companies provide in the course of its real estate brokerage activities, including but not limited to, through the Web Site, its social networks, its advertisements and for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with its obligations under the Act.

Privacy incident

A confidentiality incident is any access, use or disclosure of personal information that is not authorized by the Act, or the loss of personal information or any other breach of the protection of personal information.

groupe sutton – GO has put in place a protocol for managing a confidentiality incident, which identifies the people who assist the Privacy Officer and sets out the concrete actions to be taken in the event of an incident. This protocol sets out the responsibilities expected at each stage of incident management, including the measures to be taken to ensure data security.

6. Roles and responsibilities

A. groupe sutton – GO its staff, team members or any administrative assistant, as the case may be

Ensures confidentiality of information through good information management practices. In particular, it provides guidelines, training and instructions to staff members regarding the collection, use, storage, modification, consultation, communication and permitted destruction of personal information.
Deploys appropriate safeguards to reduce the risk of confidentiality incidents, e.g. computer security, updating personal information policies, training staff, etc.
Has standardized methods for filing documents containing personal information.
Has standardized methods for retaining documents containing personal information, particularly with regard to digitization procedures.
Manages physical and computer access to personal information, based in particular on its sensitivity.
Securely destroys personal information. In particular, it gives directives or instructions to staff members concerning the secure destruction method, destruction deadlines, etc.

B. Privacy Officer

In accordance with the Act, groupe sutton – GO has appointed a Privacy Officer.

In particular, he or she ensures that these policies are respected and that they comply with applicable regulations. The name and contact details of this person are given in the “Complaints” section.

The Privacy Officer is responsible for managing incidents of confidentiality and, in this context, takes the actions provided for in the Act.

The Privacy Officer handles requests for access to and correction of personal information. He also handles complaints about Groupe Sutton – GO’s handling of personal information.

The Privacy Officer is consulted as part of a privacy impact assessment for any project involving the acquisition, development or redesign of an information system or the electronic delivery of services involving the collection, use, disclosure, retention or destruction of personal information. It may suggest measures to ensure the protection of personal information in the context of such a project.

C. Staff, team members or administrative assistants

A staff member, team member or any administrative assistant of groupe sutton – GO may view personal information only to the extent that it is essential to the performance of his or her duties or mandate.

The staff member, team member or any administrative assistant of groupe sutton – GO :

Ensures the integrity and confidentiality of personal information held by groupe sutton – GO.
Complies with all groupe sutton – GO policies and directives on access, collection, use, disclosure and destruction of personal information and on information security, and complies with the instructions presented to him or her.
Respects the security measures in place at his/her workstation and on all equipment containing personal information.
Uses only the equipment and software authorized by groupe sutton – GO.
Ensures, when required, the secure destruction of personal information in accordance with instructions received. Immediately report to his/her superior any act of which he/she is aware that may constitute an actual or suspected breach of security rules relating to personal information.

7. Right of access, withdrawal and rectification

An individual (or his/her authorized representative) may request access to his/her personal information held by groupe sutton – GO. An individual may withdraw consent to the collection, use and disclosure of his or her personal information at any time. This withdrawal is recorded in writing.

An individual may request the correction of personal information in a file concerning him or her that he or she believes to be inaccurate, incomplete or equivocal.

An individual may request that personal data held by groupe sutton – GO be transferred electronically to a third party.

groupe sutton – GO may refuse a request for access or rectification in the cases provided for by law (https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1).

8. Complaints

A person who considers himself/herself aggrieved may file a complaint regarding the processing of his/her personal information by groupe sutton – GO. This complaint will be treated with diligence within a maximum of 30 days by the Privacy Officer and a written response will be sent to you.

9. Short message service

By providing your telephone number, you agree to receive SMS messages from the sutton-GO group (informative or promotional messages). The frequency of messages may vary.

Your personal information will not be shared with third parties for marketing purposes.

You can unsubscribe at any time by replying STOP.
For more information, reply INFOS (or contact us directly).

Courier and data charges may apply, depending on your provider.

To make a request for access, rectification of your personal information or any other request to which you are entitled, as well as to submit a complaint regarding the processing of personal information, please contact :

JP Chartrand
Privacy Officer
groupe sutton – GO inc.
1822 rue Sherbrooke Ouest suite 100
Montréal, Qc H3H 1E4
514-499-1881
renseignementspersonnels@sutton.com