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Personal Information Governance Policy

Effective date: October 10, 2026 · Labontech inc. (RestoManager)

1. Purpose and scope

This policy describes how Labontech inc. protects personal information throughout its life cycle, from collection to destruction. It meets section 3.2 of Québec's Act respecting the protection of personal information in the private sector.

It applies to:

It complements our Privacy Policy, which explains to users what information we collect and what their rights are.

2. Person in charge of the protection of personal information

As the law provides, the person with the highest authority at Labontech acts as the person in charge of the protection of personal information. They have delegated part of this function in writing to two team members, who assist them and act in their absence.

The person in charge:

To contact the person in charge: confidentialite@restomanager.ca

3. Roles and responsibilities

Everyone who handles personal information has a defined role, from collection to destruction.

Who Responsibilities
Person in charge Approves policies, decides on notices after an incident, keeps the incident register, approves privacy impact assessments.
Designated members Handle requests and complaints day to day, coordinate the response to incidents, act for the person in charge in their absence.
Whole team Accesses only the information needed for their work, reports any suspected incident without delay, completes training, honours their confidentiality commitment.
Development team Builds protection in by design, sets privacy settings to the highest level by default, applies retention periods in the software.
Service providers Process information only on our instructions and under their contract, protect it, notify us of any incident.
Employer customers Decide what information they collect about their employees, tell them they use RestoManager, answer their requests with our help.

4. Collection, use and disclosure

We collect only the information needed for the stated purposes, and we do not sell it.

5. Retention and destruction

We keep information for as long as its purposes or the law require, then destroy or anonymize it. The exact periods are in section 10 of our Privacy Policy.

6. Security and access management

Access to personal information is limited to people who need it for their work, and it is logged.

7. Privacy impact assessments

We assess privacy risks before starting a project or a disclosure that involves personal information.

When. We carry out an assessment:

How. The assessment is proportionate to the sensitivity of the information, its purpose, quantity, distribution and medium. It looks at whether the information is needed, the risks and the measures to reduce them. For a disclosure outside Québec, it also considers the legal framework of the destination and the contractual safeguards.

Who. The project team drafts the assessment at the start. The person in charge approves it and may require measures. We keep it and update it when the project changes.

8. Confidentiality incidents

A confidentiality incident is unauthorized access to, use of or disclosure of personal information, or its loss. We handle it in five steps.

  1. Report. Any team member who suspects an incident reports it immediately to the person in charge.
  2. Contain. We promptly take reasonable measures to reduce the risk of harm and prevent a similar incident.
  3. Assess. We assess whether there is a risk of serious harm, based on the sensitivity of the information, the possible consequences of its use and the likelihood it will be used for harmful purposes.
  4. Notify. If there is a risk of serious harm, we promptly notify the Commission d'accès à l'information and the people concerned in writing. When the incident involves a customer's information, we notify the customer without delay, and no later than 72 hours after becoming aware of it, and help them make their own notices.
  5. Record. We record every incident in the incident register, even without a risk of serious harm. We keep the register up to date and keep each entry for at least 5 years after we became aware of the incident.

9. Complaints and requests

Anyone may exercise their rights or make a complaint by writing to confidentialite@restomanager.ca, or by leaving a message at +1 581-706-5568. The service is free, in French or English.

Request Acknowledgement Written response
Access, correction or other right On receipt Within 30 days
Complaint about how information is handled Within 5 business days Within 30 days

10. Training and awareness

Every team member is trained before getting access to personal information, then every year.

Training covers:

We also give a refresher after an incident or a significant change in our practices.

11. Review and contact

We review this policy every year and after any significant change: a new law, a new service provider, a new feature or an incident. The person in charge approves each version, and the effective date is shown at the top of the page.

For any question about this policy: