The city recognizes the importance of respecting privacy and of protecting the personal information in its possession. It takes the necessary measures to comply with all requirements of the Act respecting access to documents held by public bodies and the protection of personal information (CQLR, ch. A-2.1).

The confidentiality policy outlines the practices with regard to protecting the confidentiality of personal information collected by technological means, such as a Web site, an application or a related object.

The city undertakes to inform any person concerned by a confidentiality incident involving personal information in its possession and presenting a risk of serious harm.

Personal information

Personal information is any information that relates to a physical person and that allows that person to be identified. It is confidential. Unless otherwise agreed, personal information may not be disclosed without the consent of the person concerned.

Collection of personal information

The city may collect only that personal information which is required for the performance of its functions and for the delivery of services to the public. 

Consent to the collection of personal information must be manifest, free, and enlightened, and must be given for specific purposes.

City employees shall use personal information only for the purposes for which it was collected and shall take appropriate precautions.

If the city asks you to provide personal information, you will first be informed of the following:

• The intended use of the information
• The categories of employees who will have access to this information
• Whether the request is mandatory or optional
• The consequences of refusing the request
• The right to access and correct information as stipulated in the Act
• The measures put in place to ensure the confidentiality of information during transmission
• Where applicable, the name of the third party for whom the information is being collected, and the name of the third party collecting the information

If you voluntarily transmit personal or confidential information to the city, whether by e-mail, non-secure electronic form or any other technological means, the city will use only the information needed to respond to your message or to follow up on your request. 

Non-disclosure to third parties

The city does not rent, sell or exchange personal information (name, address, telephone number, e-mail address, etc.) or financial information (credit card numbers) that could be used to identify you. 

The city undertakes not to disclose such personal information unless it is requested under a legal obligation or a court order or in the context of the execution of a contract entrusted to a third party. When the city retains the services of an external company, it employs all appropriate means to ensure that your personal information is protected in accordance with the Act and that it is collected, used, retained and destroyed in a manner that respects this policy.

Data security

Your data may be stored outside the country. In this case, the city will do all it can to ensure a level of protection equivalent to that offered for data stored on Canadian soil and will ensure in particular that all applicable legal requirements are met, including those relating to the protection of data. 

The city applies high standards and uses strong security systems in the design, implementation and daily operation of the Platforms (Web sites and mobile applications) and the servers and networks underlying them. In addition, the city continues its efforts to detect and block intrusions into or aimed at its Platforms. The city has put in place various means to ensure that your personal information is protected against the risk of loss and theft, and the risks of unauthorized access, communication, reproduction, use, modification or destruction. These means include physical, administrative and technological security measures deemed reasonable given the degree of sensitivity, the quantity and the format of the personal information collected and the storage methods used.

However, no security measures are absolute or fully guaranteed. If you have reason to believe that your interaction with the city is no longer secure (for example, if you believe the security of the information you have provided has been compromised), contact us immediately at [email protected].

Storage

Once the purposes for which the personal information was collected have been achieved, the information is destroyed or made anonymous, subject to the city’s storage rules and the Archives Act (CQLR, chapter A-21.1). However, the city reserves the right to retain, for a reasonable period of time, certain personal information in order to comply with the Act, prevent fraud, collect fees due, settle a claim or related issues, or cooperate with an investigation.

Access to your personal information and right of correction

Under the Act, a person may request access to information concerning them and may have it corrected. 

A person also has the following rights:

• Withdraw consent at any time to the disclosure or use of personal information collected
• Request the deletion, destruction or removal of personal information under certain circumstances. There are some exceptions under which the city may refuse a deletion or destruction request, such as when the personal information is required to comply with the law or with a contractual agreement between the parties, or in relation to a claim
• Request the suspension of processing of certain personal information in particular to establish its accuracy or the reason for its processing
• Request the transfer of certain personal information to another party

Requests for access or correction, or any questions related to this policy, should be addressed, in writing, to the person in charge of access to information, Emmanuel Tani-Moore, at [email protected]. 

Digital services 

The city provides you with access to Platforms. You may have to provide personal information in order to use the digital services offered on the Platforms. 

This information is collected to:

• Spare you the need to identify yourself each time you request service
• Improve services
• Correctly respond to your questions, comments and suggestions

The information required to create a user account is retained by the city and its partners.

Access to the information will be restricted to personnel responsible for management of the Platforms or for delivery of the specific service requested. 

You have rights, as provided under the Act, of access and correction of personal information collected by technological means.

You agree and understand that you are responsible for the security and confidentiality of the password associated with your account. Consequently, you agree to be solely responsible to the city for all activities that take place in this account. If you become aware of or reasonably suspect an intrusion of any kind, including any theft, loss, disclosure or unauthorized use of your login information, you must immediately notify us.

Geolocation

In the event that the geolocation function is activated on your browser when using the Platforms, the city uses your location only to improve the ergonomics of the Platforms.

The city does not track your movements when you use the Platforms. You may disable the geolocation feature on your device at any time, by consulting the manufacturer’s instructions. Deactivating geolocation may prevent you from accessing certain functionalities of the Platforms, however.

Cookies

Cookies are used to facilitate and optimize your navigation on the Platforms. Cookies are small text files that are downloaded and saved in the memory of the device you use to view Web pages. Cookies used by the city do not enable the collection of your personal information. 

Most Web browsers accept cookies by default. You may change your browser’s security parameters at any time to block the use of cookies or erase those already stored on your device. This action does not prevent you from accessing the Platforms, but could have an impact on their performance during your visit.

Statistics

The city uses Google Analytics analysis tools on its Platforms. These tools collect, analyze, measure and present data on visits to the Platforms, with the goal of understanding and optimizing Internet usage.

The city retains this type of information to compile statistics about:

• The number of visitors 
• The most frequently used pages 
• The technology used by its Platforms’ clientele
• Referring Web sites 
• Users’ countries of origin 

Data collected by Google Analytics are transmitted outside Canada to Google servers and may be processed in any countries where Google operates servers. These data may be subject to the legislation of such countries. For further information, refer to the Google Analytics Terms of Service.

Links to other sites

The Platforms contain hyperlinks that provide quick access to Web sites belonging to third parties and managed by them. The city puts these hyperlinks at the disposal of users of its Platforms for purposes of convenience and does not exercise any form of control over the content of the sites to which these hyperlinks lead. 

When you click these hyperlinks, you are directed away from the city’s Web site, and the information exchanged is no longer subject to the city’s confidentiality policy, but to that of the Web site visited. The city makes no declaration, gives no approval and accepts no liability in respect of the content or use of such sites. The information presented on these sites may not be available in French or in English.

Mobile application 

You acknowledge, consent and agree that the city can access, keep and disclose information and content in your account if required by law or if the city has bona fide reason to believe that protection or disclosure is necessary to: 

• Comply with the legal process. 
• Ensure compliance with the present Terms of Use. 
• Respond to your customer service requests. 
• Protect the rights, property or personal safety of the city, its users and the public. 

Requests submitted 

By submitting requests, you acknowledge and agree that: 

• Your requests do not contain confidential or exclusive information. 
• The city has no obligation to confidentiality with respect to requests, whether express or implicit. 
• The city has the right to use or disclose (or not to use or disclose) requests for any reason whatsoever. 
• Information in your request automatically becomes the property of the city, without any obligation on its behalf. 
• Under no circumstances are you entitled to any type of refund or reimbursement whatsoever from the city. 

Feedback tool

The city uses an external application to collect your comments on the Montréal.ca site in order to improve its content and functionalities.

This app collects only data about your device: model, IP address, browser type and version, and the language used.

Minors

No function of the Platforms specifically seeks information from minors nor seeks to determine if the visitor is a minor. Personal information submitted on the Platforms by minors will be treated in the same manner as that submitted by adults.

The city strongly believes that parental supervision is an important factor in the use of the Internet by minors. Consequently, the city asks parents to guide their minor children when they are invited to provide personal information online. The city also requests that minors obtain the authorization of their parents before providing information online.

Web browsing, HTTPS and encryption protocols

When you navigate the Web with your browser, it determines whether communications are adequately protected and displays a padlock symbol on the page to confirm that the communication session is secure. Caution: This does not apply to the mobile application.

The city uses the most secure encryption protocols available on its Platforms. All confidential data travelling between your communication device and the city’s Platforms are protected by effective cryptographic means, thereby ensuring the confidentiality of your information.

Processing complaints relating to the protection of personal information

A person who considers that their personal information has been handled inappropriately, or who believes that the Act has not been respected, may file a complaint.

The complaint may relate to the collection, storage, use, communication or destruction of personal information.

It will be processed confidentially. Personal information is protected, meaning it is accessible only to those people authorized to consult it in the performance of their duties. 

Complaints must be submitted in writing to: 

Emmanuel Tani-Moore, city clerk
City clerk’s office
275 Rue Notre-Dame Est
Montréal, Québec 
H2Y 1C6

Complaints can be addressed to [email protected] or sent in writing to the Commission d’accès à l’information - Direction de la surveillance.

Entry into force 

This policy entered into force on June 21, 2023.

Update

August 29, 2023