10. PRIVACY POLICY

 

10.1 PURPOSE

This document describes how Synopsis is responsible for the protection of the personal information we gather during our studies, from individuals as well as from businesses.

Synopsis places a high value on the protection of personal information. Personal information includes any information which allows the identification of a study participant, whether such information is in verbal, digital or written form.

 

10.3 POLICY

 

10.3.1 THE 10 PRINCIPLES

The policy is structured according to the ten principles relating to the equitable processing of personal information pursuant to the federal Personal Information Protection and Electronic Documents Act.

These principles are interdependent:

 

1.     accountability;

2.     identifying purposes for collecting personal information;

3.     consent;

4.     limiting collection;

5.     limiting use, disclosure and retention;

6.     accuracy;

7.     safeguards;

8.     openness;

9.     individual access;

10.   challenging compliance.

 

10.3.1.1 Accountability

Synopsis is responsible for personal information under its control. For this purpose, we adopted this policy and designated a person responsible for the protection of personal information.

The designated person is responsible for …

a)    Applying and enforcing Synopsis’s policy relating to the protection of personal information;

b)    training employees about this policy;

c)     managing inquiries and requests for information;

d)    processing complaints relating to the protection of personal information.

 

The person responsible for the protection of personal information can be reached…

       at the following email address: privacy@synopsis.marketing

       at the following mailing address: Synopsis – Privacy officer, 415 Le Moyne Street, Suite 402, Montréal, Québec, H2Y 1Y5.

 

10.3.1.2 Identifying purposes for collecting personal information

During its operations, Synopsis collects personal information from study participants for the purposes of carrying out such studies.

The purposes for which personal information is collected are identified before data collection in at least one of the following documents:

       the client’s request for service proposal;

       Synopsis’s service proposal;

       the project file;

       data collection tool(s) (such as questionnaires, discussion guides, interview guides and online community activity guides).

A complete list of specific information to be collected can be found in the data collection tools (e.g.: questionnaires, discussion guides, interview guides, online community activity guides).

 

10.3.1.3 Consent

       Participation in Synopsis's studies, regardless of the type of study (whether they are surveys, focus groups, individual interviews or online communities), is always on a voluntary basis.

       The participant’s consent is explicitly obtained by the interviewer upon collection of personal information during which there is human interaction or implicitly when the participant completes an online survey.

       Participants are made aware that the study is conducted by SYNOPSIS by the presence of its logo on the welcome page or it is mentioned in the introduction in the case of an interview.

       During the study, participants have every right to refuse to answer one or more specific questions. They can terminate their participation at any time.

       The data we gather is only presented to our clients in aggregate form. We never disclose any identifiable information relating to a participant without having previously obtained such participant’s explicit consent.

       When carrying out studies focused on minors, we gather personal information from such minors only once we’ve obtained the consent of a parent or legal guardian.

 

10.3.1.4 Limiting collection

       Synopsis only collects personal information which is necessary to the purposes identified in its studies.

       The personal information we collect is used solely for the purposes for which it was collected. We do not use such information for other studies or for our specific needs.

       We do not collect data as social insurance number, complete mailing address or transactional data, unless if it’s needed for a specific project AND explicit consent is given by the participant.

       Personal information will never be sold to any third parties.

 

10.3.1.5 Limiting use, disclosure and retention

       Synopsis pledges to use and communicate the personal information it collects only for the purposes for which it was collected. It retains such information only as long as is necessary to fulfill such purposes.

       Nominal lists provided by our clients are accessible only to company employees who need to have access to such information as part of their work.

       Consequently, when a project is completed, we delete personal information from company files or anonymize such information. For example:

o   nominal lists provided by clients are deleted;

o   respondents’ identifiable data (such as name, last name, phone number, home address, email address, etc.) is erased from project documents and deleted from databases; interview and focus group recordings as well as answers of everyone who participates in an online community are erased or deleted.

       When a client asks for telephone interview recordings, Synopsis provides recordings starting from the first question of the survey, excluding the introduction where the respondent’s name might be mentioned. The file does not include the respondent’s name or phone number, unless such respondent has given his/her explicit consent.

       When a client asks for focus group or individual interview recordings, the client must agree to safeguard such recording, refrain from disclosing it and destroy it after use. Explicit consent must be given by every participant from the group prior to sharing.

       When a client wishes to remotely attend a focus group or individual interview, the client must refrain from recording any discussions.

       For specific projects as a community, Synopsis needs to retain PII (such as name, last name, phone number, home address, email address, etc.) for a specific period (as long as the project exists). In this specific case, all data will be conserved, encrypted, in the master database only (SFTP) and will be conserved as long as the community is ongoing. It will be expunged once respondents opt out of participating in the community. 

 

10.3.1.6 Accuracy

Synopsis strives to collect the most accurate, complete and up-to-date personal information possible to meet the informational requirements related to its projects. For this purpose, Synopsis adopted several quality control measures. Such measures vary according to the data collection method used.

 

10.3.1.7 Safeguards

       Synopsis pledges to use all appropriate safeguard measures to protect the information with which is it entrusted.

       The personal information we gather is stored on different secure servers located in Canada.

       All company employees must subscribe to our policy relating to the security of information and agree to be bound by confidentiality obligations upon hiring, and formally reiterate such commitment every year thereafter. Our security policy sets forth the principles that must be rigorously followed by every employee. These rules address such matters as access and transportation of information, personal use of resources and confidentiality of company information.

       We require from our partners commitments regarding protection of personal information and security that are at least equal to the ones we follow. Subcontractors are bound by confidentiality agreements, whether or not they have access to sensitive information.

 

10.3.1.8 Openness

       An overview of Synopsis’s policy relating to the protection of personal information appears on their website, where one can access the complete policy.

       In addition, the company’s policy is available upon request to the person responsible for the protection of personal information, whose contact information is indicated at Section 1 of this document.

       When required, it is included in the company’s service proposals.

 

10.3.1.9 Individual access

       Upon request by a study participant, Synopsis notifies the participant with respect to the existence of his or her personal information, the use of such information and, as the case may be, the fact that the information was conveyed to third parties.

       Participants can consult the information that Synopsis keeps relating to them. They can challenge its accuracy and integrity as well as request that appropriate corrections be made. When corrections are requested relating to information provided by one of our clients, we refer the participant to our client or, with the participant’s permission, we relay the corrections directly to our client.

       The project manager answers participants’ requests for access to their personal information. We strive to answer such requests within five business days.

       When someone we contact to participate in one of our studies asks how we obtained his or her contact information, we answer honestly. Depending on the method of collection, such information can be conveyed by an interviewer, a recruiter or the project manager.

 

10.3.1.10 Challenging compliance

       Any individual can file a complaint in the event that Synopsis does not comply with the principles set forth in this policy.

       The complaint must be addressed to the person responsible for the protection of personal information, whose contact information is indicated at Section 1 of this document.

       This person shall see to it that the complaint is carefully and diligently examined and, if required, that necessary actions are taken in order to correct the situation and ensure that similar cases do not reoccur.

 

 

THE PRIVACY POLICY MUST BE AT THE CORE OF ANY DECISION MADE REGARDING THE ADOPTION OF NEW SYSTEMS AND SOFTWARES, AND THE LAUNCH OF NEW PROJECTS OR PRODUCTS.