The Information and Communications Technology Council (ICTC) presents the etalentcanada.ca web site for our visitors’ personal use, including educational and informational purposes. You can view and download material on this site for your personal use. You must retain and observe all of the proprietary and copyright notices on ICTC materials. You are not permitted to use, repost, modify, publish or duplicate ICTC content for commercial or other public use without securing specific written authorization from ICTC.
1. Introduction
The Information and Communications Technology Council (“ICTC,” “we,” “us,” or “our”) is dedicated to protecting the privacy of our employees, program participants, research participants, users, and partners. Delivering successful programs and research requires trust, and we strive to earn the trust of those we work with.
This policy outlines our commitment to respecting the privacy of personal information of individual persons who engage with us, and helps you understand how we collect, use, store, disclose, and dispose of personal information, in compliance with relevant legislation.
ICTC may modify this Privacy Policy at any time, without prior notice. The most up-do-date version of this Privacy Policy can be found on ICTC’s website https://ictc-ctic.ca/legal/privacy-statement and https://etalentcanada.ca/legal.
2. Contact Details
For privacy-related questions concerns, complaints, or to contact our privacy officer, please email us at @email.
If you have concerns with how we handle your personal information, you have the right to contact the privacy commissioner or data protection regulator in your country. If you are located in Canada, please contact the Office of the Privacy Commission of Canada.
3. Application of This Policy
3.1. Activities, Operations, Services, and Channels
This policy applies to all ICTC’s activities and operations and to all channels through which we operate, including by phone, email, our website, in-person communications, and events.
3.2. Personal Information
This policy applies to personal information, including the personal information of prospective, current, and past program participants, research participants, users of ICTC’s website, services, tools, and products, and our staff.
Personal information is any information that can identify an individual. It may be factual or subjective, as well as recorded or not. For example, it may include details such as:
- Your name
- Contact information (including home and work address, phone number, and email address)
- Identification numbers (such as student number)
- Financial and transactional data (including bank account details, transaction history, order history, payment information, shipping details, invoice, and billing data)
- Demographic information (such as age, gender, occupation, education level, income level, racial or ethnic origin, and sexual orientation)
- Behavioral data (such as website usage patterns)
- Technical data (including IP address, device type, browser type, operating system, cookies, and tracking information)
- Communication data (including emails sent and received, and chat logs)
- Data shared with ICTC by third-party tools or partner organizations
- User-generated content (such as comments, reviews, posts, documents, and files)
Personal information does not include certain publicly available information nor business contact information (e.g., name, title, business address or telephone number of an employee of an organization, when used for business purposes). If an individual uses their personal contact information as business contact information, ICTC considers this business contact information, and as such, not subject to protection as personal information.
3.3. Third Party Sites
This policy applies only to ICTC’s communication channels, such as ICTC’s websites and network storage locations. Please review other organization’s policies when following links to external communication channels, such as websites.
4. Protecting Your Data
ICTC strives to adhere to the 10 fair information principles identified in the Personal Information and Electronic Documents Act (PIPEDA):
- Accountability
- Identifying Purposes
- Consent
- Limiting Collection
- Limiting Use, Disclosure, and Retention
- Accuracy
- Safeguards
- Openness
- Individual Access
- Challenging Compliance
All ICTC staff attend cybersecurity training when joining the company and attend formal training on an annual basis.
5. Obtaining Consent
5.1. Informed Consent
An individual’s consent is required for ICTC to collect, use, store, and disclose their personal information. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically, or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
Prior to providing consent, individuals will be informed of what personal information will be collected and why, including the specific purpose for data collection. Individuals will also be informed of how their personal information will be stored; whether it will be disclosed to third parties and if so which parties and why; and when their personal information will be deleted.
ICTC may collect, use, store, and disclose personal information without an individual’s knowledge or consent in specific circumstances authorized under the Personal Information Protection and Electronic Documents Act (PIPEDA). Unless authorized or required by law, ICTC will only collect, use, store, and disclose personal information with knowledge and consent.
5.2. Minors
Occasionally, we may collect the personal information of minors, as appropriate. For instance, participants in our kindergarten to grade 12 or WIL Digital programs will be required to provide personal information. In certain circumstances, we may request the consent of a parent or guardian of that minor or child to collect that information.
6. Collection of Personal Information
6.1. What Information we Collect
We collect personal information through various channels.
Most of the information we collect is collected when you interact directly with us. For example, when you apply to one of our programs; communicate or interact with us in person, over the phone, through video calls, or by email; sign up for special offers or communication lists; complete a survey; or attend one of our research interviews, focus groups, roundtables, or other events.
We also collect information about you from a variety of other sources, including:
- Automated data collection, tracking, and analytics through our website;
- References you have provided to us; and
- Post-secondary institutions you have authorized to share information with us.
We may collect personal information about you from third parties in line with their terms, conditions, and privacy policies. These sources may include commercially available providers, such as research organizations and mailing list companies; publicly accessible sources, like internet news sites and social media; as well as government agencies, registries, or public records.
We may combine information about you from third party sources (such as LinkedIn, ZoomInfo, and other data brokers) with information we hold about you to create a user profile.
The categories of personal information we collect depends on how you interact with our various programs, projects, websites, online tools, and other initiatives, each of which require ICTC to collect different types of personal information. The information we may collect includes:
- Your name
- Contact information (including home and work address, phone number, and email address)
- National identification numbers (such as student number)
- Financial and transactional data (including bank account details, transaction history, order history, payment information, shipping details, invoice, and billing data)
- Demographic information (such as age, gender, occupation, education level, income level, racial or ethnic origin, and sexual orientation)
- Education information (including level of education, institutions attended, and academic programs or majors)
- Behavioral data (such as website usage patterns)
- Technical data (including IP address, device type, browser type, operating system, cookies, and tracking information)
- Communication data (including emails sent and received, and chat logs)
- Data shared with ICTC by third-party tools or partner organizations
- User-generated content (such as comments, reviews, posts, documents, and files)
6.2. Limited Collection
The collection of personal information by ICTC is limited to that which is relevant and necessary to our programs, projects, initiatives, websites, and online tools. Information will be collected by fair and lawful means.
7. Use of Personal Information
Unless you consent or it is required by law, personal information will only be used or disclosed for the purposes for which it was collected. We may use your personal information:
- for the purposes communicated to you at the time of collection or in your agreement(s) with us;
- to communicate with you through various channels, including telephone, email, text, post, or through our applications using the contact information you provide;
- to assess and determine your eligibility for programs, products, and services you apply to;
- to provide you with the programs, products, and services you request, including educational and training programs or skill assessment;
- to help us understand the interests of our current and prospective stakeholders;
- to enable and promote interactions on our community platforms;
- to analyze user behaviour on our websites and online platforms;
- to report to our funders on progress and key metrics;
- to prevent and detect fraud;
- to meet legal and regulatory requirements; and
- reporting to funders on progress and key metrics, including audits conducted by funders.
We may use your personal information for marketing purposes with your consent, such as to communicate to you about what programs, products, and services ICTC provides. We will only send you information about our programs, products, and services according to the choices you have specified. You can opt out of marketing communications at any time by clicking “unsubscribe” in emails or by contacting us directly.
8. Disclosure of Personal Information
8.1. ICTC Employees
Under certain circumstances, your personal information, including some or all the categories of importation set out under 4.1. What Information We Collect, will be accessed by ICTC employees who have a legitimate business purpose for using it. Unauthorized access, use, and disclosure of information by ICTC employees is strictly prohibited. All employees are required to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures.
Access to personal information is restricted to authorized personnel only. Where possible, ICTC manages secure access using passwords and multi-factor authentication (MFA).
8.2. Outside Service Providers
We may share personal information with service providers we use to perform specialized services on our behalf including data processing, data analytics, data storage, marketing, and operational activities. These outside service providers have access to personal information needed to perform their functions, but may not use it for other purposes.
8.3. Other Third Parties
ICTC may share your personal information with partners with your consent, such as for marketing purposes. We will only share the information that you consent to us sharing. We will only share this information with the partners you consent to. You have the right to opt out of us sharing your personal information with our partners.
ICTC may also share your personal information as required by law:
- to comply with laws, regulations, subpoena, or court order;
- to respond to valid and authorized information requests from domestic and international authorities;
- to facilitate legal audits, or audits by our funders;
- to prevent and detect fraud; and
- to protect the personal safety of employees, program participants, research participants, or other third parties on ICTC property.
8.4. Jurisdictions to Which We Transfer Your Information
Your personal information may be transmitted, stored, or processed in regions outside your current location, where may will be subject to the laws of those jurisdictions and may be disclosed accordingly. We will implement measures, such as contractual clauses or other safeguards, to protect your personal information. The countries where your information may be transferred, stored, or processed include, but are not limited to:
- Canada
- United States of America
9. Security and Storage of Personal Information
9.1. Security of Personal Information
We operate our systems with your security and privacy in mind.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you.
It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications. We recommend using a unique password for your ICTC account that is not used for other online accounts. Be sure to sign off at the end of your session when using a shared computer.
9.2. Data Storage
ICTC uses various methods, including local and cloud storage, to store personal information. Storage environments are equipped with passwords, two-factor authentication, encryption, and access controls.
9.3. Geographic Location of Data Storage
We sometime store and process information outside of Canada. Where required by law or contractual obligation, ICTC will store all personal information on servers located in the assigned Country.
10. Retention of Personal Information
We keep personal information for as long as required to comply with business, legal, and regulatory record keeping requirements. When it is no longer needed, our policies mandate that the information be securely purged or destroyed.
11. Access to Personal Information
You may have the right to request access to your personal information if governed under Canada’s Personal Information and Electronic Documents Act or the European Union’s General Data Protection Regulation. Should you want to request access to your personal information, please reach out to @email.
12. Accuracy and Rectification
ICTC strives to ensure personal information is accurate, complete, and up to date as possible to properly satisfy the purposes for which it is used. You may have the right to rectify your personal information if governed under Canada’s Personal Information and Electronic Documents Act.
Should you want to request rectification of your personal information, please reach out to @email.
13. Deletion or Erasure of Personal Information
You may have the right to request erasure of your personal information if governed under the Québec’s Private Sector Act or the European Union’s General Data Protection Regulation. Should you want to request erasure of your personal information, please reach out to @email.