This Policy applies to Employee and Candidate Personal Information that is collected or otherwise controlled by Novacap Management Inc., and its affiliates (hereinafter “Novacap”). Novacap values your privacy and is committed to protecting your Personal Information. This Policy outlines how we collect, use, disclose and protect your Personal Information and how you may exercise your rights, for example to access or correct it.
When does this Policy apply?
This Policy applies to Employee and Candidate Personal Information that is collected or otherwise controlled by Novacap, whether they are stored by Novacap or by a third party.
What does everything mean?
“Applicable Privacy Laws,” means any laws, regulations, recommendations or notices applicable to privacy matters, including, to the extent applicable, the Act respecting the protection of personal information in the private sector and the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as any other statute, regulation, recommendation or notice that replaces, supplements, amends, extends, re-enacts or codifies applicable privacy laws of Canada.
“Employee” means any person employed by Novacap, including any intern, student, consultant or officer, on a full-time or part-time, permanent or temporary basis.
“Candidate” means any individual who applies for employment at Novacap.
“Personal Information” means any information about an individual that directly or indirectly identifies that individual, such as a name, employee number, social insurance number (SIN), online tracking identifier such as an IP address, or one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that individual.
Why do we collect your Personal Information?
We will only collect, use and disclose Candidate and Employee Personal Information in accordance with Applicable Privacy Laws. For example, we will only use your Personal Information for purposes for which we have obtained your consent, or for other purposes that may be required or permitted by law. Please read on to understand the reasons why we collect your Personal Information.
To facilitate the hiring process
This includes:
- Verify candidate references.
- Conduct background and credit checks if needed.
- Administer job-related assessments.
- Perform pre-employment medical exams for relevant positions.
- Conduct interviews with candidates.
- With your consent, notify you of other job offers.
To communicate with you
This includes:
- Help communicate with candidates and employees.
- Assist employees in contacting family during emergencies.
- Aim to collect Personal Information directly from individuals, only using other sources when necessary.
- To administer monetary benefits related to employment
To administer monetary benefits related to employment
This includes:
- Record pay rates for base pay.
- Communicate with third parties for payroll, benefits, and legal requirements.
- Administer internal benefit plans and employment-related schemes.
To comply with our policies and legal obligations
This includes:
- Share Personal Information with service providers and government agencies as needed.
- Perform pre-employment assessments and comply with legal obligations.
To protect our interests
This includes: - Utilize monitoring and control measures for security, such as monitoring employee and candidate presence on
premises. - Automated systems like card access record entry/exit times of employees at Novacap’s premises.
To meet our business objectives
This includes:
- Gather candidate and employee demographic data for Equity, Diversity, and Inclusion (EDI) efforts.
- Monitor, evaluate, and promote employee safety and health.
- Administer disability benefits for accommodation decisions and workplace safety.
- Share medical information with relevant parties and conduct medical exams if needed.
- Share limited Personal Information (age, qualification and skills) of Employees to potential or current limited
partners in the context of fundraising or reporting. - Share Personal Information of Employees when necessary to financial institutions or other service providers of our
portfolio companies (including for know your customer purposes, verify the identity of their clients) or to regulatory
authorities to obtain regulatory approvals or governmental licenses/permits for these portfolio companies.
How do we obtain your consent?
If you choose to provide us with your Personal Information after reviewing this Policy, we will assume that you consent to the
collection, use and disclosure of your Personal Information.
If we want to use your Personal Information for a purpose not identified in this Policy or not required by law, we will ask for your
consent before using the information for the new purpose.
What Personal Information do we collect?
We may collect the following information:
- Name (Employees and candidates)
- Postal and email address (Employees and candidates)
- Telephone number (Employees and candidates)
- Date of Birth (Employees and candidates)
- Gender (Employees and candidates)
- Nationality or citizenship status (Immigration status) (Employees and candidates)
- Social Insurance Number (SIN) (Employees and candidates)
- Resume and references (Employees and candidates)
- Qualifications and skills (Employees and candidates)
- Performance Evaluation (Employees)
- Psychometric tests (Employees and candidates)
- Languages spoken (Employees and candidates)
- Work record (Employees)
- Legal documents related to employment (Employees)
- Medical status and documents (Employees)
- Educational documentation (licenses and certifications) (Employees and candidates)
- Background check results (Employees and candidates)
- Banking information (for payroll deposits) (Employees)
- Credit information (for credit inquiries) (Employees and candidates)
- Marital status (Employees)
- Name and date of birth of spouse and/or dependents (if applicable) (Employees)
- Employee’s photograph (Employees)
- Geolocation (Employees)
- Emergency contact information (Employees)
With whom do we disclose Personal Information?
We may disclose your Personal Information to third parties or service providers for the reasons explained above or as otherwise set out in this Policy. We will not sell or rent Personal Information to third parties or trade Personal Information with third parties. However, we may disclose Personal Information where permitted or required by law, or as set out below:
Services providers
These service providers are only given necessary information and are bound by contracts to use it solely for the intended services. We take steps to protect your Personal Information by establishing agreements and privacy measures with these providers. Categories of service providers include payroll management, insurance, access control, IT support, audits, HR software, and website management. We may also disclose some Personal Information to service providers of our portfolio companies for Employees who are directors or officers of these portfolio companies. For more details about our service providers, please contact us using the provided instructions.
As permitted or required by law
We may disclose Personal Information when required to do so by law, regulation, court order, subpoena, valid demand or search warrant, or in response to a government investigation or other lawful request. We may also disclose such Information to its accountants, auditors, agents and attorneys to enforce or protect our legal rights. In addition, we may disclose certain Personal Information when we reasonably believe that it is necessary to do so to protect the rights, safety or property of Novacap. We may also disclose some Personal Information to obtain regulatory approvals or licenses for our portfolio companies.
To perform an agreement and other legal grounds
To the extent applicable and necessary, we may disclose Personal Information to enter into an agreement, or for any other recognized purpose that we may have for disclosing information. For example, we may disclose Personal Information to third parties or advisors in connection with business transactions, including an acquisition or merger, sale, or transfer of business or assets, or bankruptcy proceeding.
What do we expect from you as an Employee?
We will make reasonable efforts to ensure that the Personal Information we collect, use or disclose about our Employees is accurate and as complete as possible. To the extent that you provide us with information on which we intend to rely, we assume that such information is accurate and up to date. If any of your Employee Personal Information changes during the course of your employment with us, we also expect you to notify us of such changes so that your employment record can be updated.
How long do we keep your Personal Information?
We’ll retain your Personal Information as long as necessary to fulfill our business and legal obligations, or as required by law. For decisions directly affecting candidates or employees, we’ll keep the information for a reasonable period and at least one year after the decision. Otherwise, we’ll destroy or anonymize records containing Personal Information when it’s no longer needed for its original purpose or other business/legal reasons.
Where do we keep your Personal Information?
- We primarily store candidate or employee Personal Information in Canada.
- However, it may be processed in other countries if needed, especially when using third-party service providers. If
processed outside your country of residence, it’s subject to that country’s laws and may be disclosed accordingly. - Nevertheless, our practices regarding your Personal Information are always governed by this Policy and applicable
privacy laws.
What rights do you have regarding your Personal Information?
- We’ll strive to maintain your Personal Information accurately, completely, and up to date.
- Routine updates won’t occur unless necessary, but we may request updates from you when needed.
- If you want to access or correct your Personal Information, we may ask for identification for verification, and your
identifying information will solely be used for this purpose.
Right of access and rectification and Right to consent withdrawal
Depending on privacy laws applicable to you, you may have one or more rights described below regarding your Personal Information:
- You have the right to access and obtain a copy of your Personal Information.
- You can request corrections, updates, or limitations to the processing of your Personal Information.
- Reasonable correction requests will be honored; if deemed unreasonable, a note will be added.
- You can also inquire about how your Personal Information was collected, used, and accessed within Novacap,
including storage duration and access details. - You can withdraw consent for the disclosure or use of your Personal Information (note: be informed that this
may affect certain aspects of your employment/recruitment, such as but not limited to payroll processing and
other matters for candidates during a hiring process). - You might also have the right to request that your Personal Information no longer be shared, where applicable.
To exercise your rights, please send a written request, with proof of your identity, to our Privacy Officer at the contact information
provided in the Section “How do you contact us”.
How can you contact us?
Please direct any requests, questions or comments regarding this Policy to Legal Affairs at the contact information provided.
Novacap Legal Affairs
700-3400 rue de l’Éclipse
Brossard (Quebec) J4Z 0P3
[email protected]
Once your request has been sent, we will provide you with a written response no later than 30 days from the date of receipt of your request at the contact information indicated above. In some specific cases, we may refuse to provide you with the Personal Information requested or we may redact (black out) certain information from the records that we provide you with.
How do we protect your Personal Information?
- We implement security procedures for both physical and electronic records containing Personal Information.
- Only authorized personnel with confidentiality obligations have access.
- Electronic data is protected by our zero trust security framework, accessible only to necessary personnel.
- If you suspect a security issue, please contact the Privacy Officer at [email protected] .
Who will assess compliance with this Policy?
Novacap’s Privacy Officer will independently assess allegations of violations of the Privacy Policy by reviewing practices and procedures and determine whether follow-up corrective action is required, including disciplinary action up to and including termination of employment.
Policy Update
This Policy is current as of the “revision” date which appears at the bottom of this Policy. We may modify this Policy from time to time. When we make changes to this Policy, they become immediately effective when made available to you through Novacap Sharepoint or/and the ComplianceAlpha platform.