Privacy Policy

Last modified on March 11, 2025. Last verified on March 11, 2025.

Effective Date: September 1, 2023

1. Purpose and Scope

Productions Version 10 Inc. and its subsidiaries (V10 Media Inc.) (hereinafter referred to as "the Producer") are committed to handling the personal information of individuals working for it in compliance with the Act Respecting the Protection of Personal Information in the Private Sector. This Privacy Policy for Individuals Working for the Producer (hereinafter, "the Policy") informs individuals working for the Producer about its practices regarding the collection, use, and disclosure of their personal information, as well as their rights concerning their personal information.

This Policy applies to all individuals working for the Producer (hereinafter, "Designated Individuals").

2. Definition of “Personal Information”

In this Policy, "personal information" refers to any information concerning an individual that allows them to be identified, directly or indirectly.

3. Collection of Personal Information

The Producer collects personal information about Designated Individuals that is necessary for managing its working relationships with them. The Producer may collect the following personal information about Designated Individuals:

Identifiers and contact details, such as name, email and mailing addresses, phone number, government-issued IDs (such as Social Insurance Number, visa and passport details), work/residence permit.
Demographic information, such as date of birth, gender, citizenship, or medical information. In some cases, the Producer may collect demographic information related to an equity, diversity, and inclusion program on a voluntary basis (such as ethnic origin, sexual orientation, etc.).
Employment or professional information, such as job title and salary history, work schedule and employment status, work experience, education, licenses and other credentials, benefits and leave information, information related to disputes or issues that may arise, performance reports and evaluations, psychometric test results, disciplinary records, termination date, and reasons for termination (voluntary or involuntary, with details).
Financial information, such as banking institution and account number for payroll management and information necessary for issuing tax forms.
Emergency contact details, such as names, contact details, and the nature of their relationship with the Designated Individual.
Internet, network, and device usage information, such as IP addresses (if they allow employee identification) and device identifiers (e.g., when an employee connects to the Producer’s Wi-Fi network). The Producer may collect information on how Designated Individuals use their work email accounts, the internet, computers, phones, and other devices provided by the Producer, as well as personal devices used for work purposes. The Producer may also collect video footage and photos through closed-circuit video cameras.
Other information, such as those provided through the payroll management system.

4. Retention and Destruction of Personal Information

The Producer implements appropriate measures and control mechanisms to protect the personal information of Designated Individuals. These measures include restricting physical access to offices and records, preventing unauthorized access, disclosure, use, and mishandling of personal information in the Producer’s custody and control, storing archived documents with trusted third parties in secure facilities, using firewalls, passwords, and file encryption for online activities.

The Producer aims to prevent unauthorized access, loss, misuse, sharing, or modification of personal information in its possession. These security measures also apply when the Producer deletes or destroys the personal information of Designated Individuals.

The Producer seeks to retain its personal information within Quebec or, where not possible, within Canada. However, information stored on the servers of the Producer’s service providers may be located outside Canada and, as such, may be subject to the laws of those countries, including laws granting access to governmental authorities. Subject to these foreign laws, the Producer will use contractual measures to maintain protections ensuring that personal information is safeguarded at levels equivalent to those required in Quebec.

The Producer retains the personal information of Designated Individuals only for as long as reasonably necessary to fulfill the purposes for which it was collected or as permitted or required by the Act Respecting the Protection of Personal Information in the Private Sector. Once it is no longer needed, personal information is securely destroyed or anonymized in accordance with the law.

Reasonable retention periods for Designated Individuals’ personal information include:

Permanently for documents containing usage rights, copyrights, neighboring rights, or any other rights necessary for the exploitation of a work (e.g., author, director, performer contracts, etc.).
Seven (7) years after the end of the project for which the individual worked for the Producer for tax-related documents.
Three (3) years after the end of the project for which the individual worked for the Producer for all other personal information.

5. Use of Personal Information

The Producer uses the personal information of Designated Individuals for managing its working relationships and other legitimate purposes detailed in this Policy, as well as other purposes permitted by the Act Respecting the Protection of Personal Information in the Private Sector.

For example, the Producer may use personal information for the following purposes:

Managing personnel, including identity verification, tax and social security management, scheduling, attendance tracking, emergency contacts, and handling work-related requests.
Administering benefits, including determining eligibility for benefits and dependents.
Payroll processing, sick leave, and vacation management.
Performance evaluations, including assignments, training, salary, and promotions.
Health and safety measures to protect the physical and psychological well-being of Designated Individuals.
Internal business activities, such as disaster recovery planning, audits, internal investigations, and business process improvements.
Work visa applications.
Legal and regulatory compliance, including fraud prevention, investigations, performance failures, and contract breaches.

The Producer may only share personal information with other Designated Individuals as required for job performance. Those with access to personal information must take appropriate measures to protect it and may not share, copy, or use such information for purposes other than their job duties.

6. Disclosure of Personal Information

The Producer may disclose personal information to third parties for the purposes outlined in this Policy or as required by the Act Respecting the Protection of Personal Information in the Private Sector. For example, disclosure may occur to:

Government agencies requiring access (e.g., employment insurance claims, grant applications).
Service providers supporting business functions (e.g., payroll administration, IT services, legal and accounting firms).
Third parties conducting background checks.
Entities involved in business transactions (e.g., mergers, acquisitions).

7. Accuracy, Access, and Correction

Designated Individuals must provide accurate and complete personal information and promptly update any changes. They may request access to their personal information and request corrections if it is inaccurate or incomplete.

Requests for access or correction should be submitted in writing to their manager or supervisor. If dissatisfied with the response, they may escalate the request to the Privacy Officer.

8. Roles and Responsibilities

All Designated Individuals with access to personal information must maintain confidentiality. Vincent Martel, Partner (info@version10.ca), serves as the Privacy Officer and ensures compliance with the Act Respecting the Protection of Personal Information in the Private Sector.

9. Complaints and Questions

Concerns about personal information handling should first be addressed with a manager or supervisor. If unresolved, Designated Individuals may escalate their concerns to the Privacy Officer.

10. Policy Updates

The Producer regularly reviews its policies and procedures. Updates to this Policy can be found at: https://www.version10.ca. The Producer also provides periodic training on data protection and information security.