Privacy Policy

BRP MEGATECH APPLICANT PRIVACY NOTICE

Last update: May 17, 2023

1. INTRODUCTION

This Notice transparently describes why and how BRP Megatech Industries Inc., its subsidiaries and affiliates (collectively “Megatech”, “we”, “our”), as data controller, collects and uses your Personal Information, throughout the recruitment and hiring process at Megatech.

It also explains who we may share your Personal Information with and how long we typically keep it. This Notice is also intended to inform you of your rights under the various laws and regulations regarding the protection of Personal Information.

For the purposes of this Notice, “Personal Information” means any information that directly or indirectly identifies you.

2. SCOPE

This Notice applies to the Personal Information of individuals who participate in a Recruiting Activity at Megatech (collectively “Applicant”, “you”, “your”).

“Recruiting Activity” means any step in the process of applying for a job at Megatech, joining our talent community, or participating in any type of recruiting or hiring event or activity hosted by Megatech.

3. PRINCIPLES FOR PROCESSING PERSONAL INFORMATION

As part of Recruitment Activities, Megatech will ensure that the Personal Information we hold about you:

  • is handled lawfully, fairly and transparently
  • is collected and processed for the purposes specified only
  • is adequate, relevant and not excessive for the purposes for which it was collected and processed
  • is accurate and up-to-date
  • is not kept in a form that allows an Applicant to be identified for longer than necessary
  • is kept securely
  • is shared only with those who need to know the Personal Information to fulfill their obligations.

4. TYPE OF PERSONAL INFORMATION COLLECTED

The type of Personal Information that Megatech collects about you, whether or not by automated means, uses, shares and stores depends on the nature and context of the Recruiting Activity and the requirements of applicable law (e.g., employment law, tax, insurance).

Except for restrictions imposed by local law, relevant sectors of Megatech may process the following categories of Personal Information:

  • Contact information such as name, address, telephone number, personal email address and other contact information (including emergency contacts).
  • Identification and demographic information such as date and place of birth, marital status, nationality, gender, immigration status, languages spoken, signature, driver’s license, passport, social security number, identification card or other national identification documents, photographs, criminal records, etc. Gender, race and religion will only be collected when required by local law.
  • General employment information such as proof of your right to work, job title, work location, date of hire, union affiliations, performance history and succession planning, test and evaluation results, issues raised in a whistleblower case or to which you may be a party or witness, disciplinary records, and records of your attendance at work.
  • Education and training information such as academic and professional qualifications, licenses and professional certifications, skills assessments, experience, curriculum vitae and details of other training and development.
  • Financial information such as banking information, tax information, salaries, bonuses, benefits and other information required for payroll administration. Financial information also includes transaction details, expense information and investment details for your pension plan.
  • Workplace access information and information technology usage and content, such as emails sent and received, access to buildings and information systems, use of Megatech devices, systems and applications (including telemetry) when accessing and using Megatech buildings and corporate assets.
  • Video, voice and image information such as video, voice and image data taken in the course of your employment, for security purposes and for promotional, marketing or advertising purposes, subject to the requirements of local laws and Megatech’s internal policies (if any).

Megatech collects this Personal Information directly from Applicants, as well as from third parties such as references, criminal record or credit reference agencies, public sources, medical professionals and other professional advisory service providers. In most cases, Megatech will obtain your permission before seeking to obtain such information from these sources (this permission may be given directly by you or implied by your actions).

5. PURPOSES FOR PROCESSING PERSONAL INFORMATION

Megatech processes Personal Information collected to fulfill its role as an employer, to enable us to comply with a legal obligation, on the basis of legitimate interests or as otherwise permitted by law. Where there is no other legal basis for collecting and processing Candidate Personal Information, Megatech will require your consent. This consent, which you are not required to give, may be revoked at any time.

In the course of Recruiting activities, Megatech will process your Personal Information, particularly in the following situations:

  • Making decisions about your employment
  • Determining your terms and conditions of employment
  • Determining performance requirements, setting individual goals and conducting performance reviews
  • Assessing qualifications for a job or task, including career and promotion decisions
  • Review, modify or grant benefits, rewards and additional bonuses for Applicants
  • Define education, training or development requirements
  • Compile directories and perform data analysis
  • Perform profiling
  • Ensure the security of the computer network and information held by us
  • Ensure a safe and secure work environment
  • Save emails
  • Comply with applicable employment laws and regulations
  • Monitor compliance with Bombardier Recreational Products Inc.’s Code of Ethics and policies and collect evidence of wrongdoing for disciplinary action
  • Resolve disputes involving you, other applicants, workers, contractors, including workplace accidents
  • Handle denials of employment
  • Communicate with you about your employment
  • Implement an approval workflow in various systems.

If you do not provide certain Personal Information upon request, Megatech may not be able to properly perform Recruitment Activities.

We may use your Personal Information for purposes other than those for which it was collected if we believe that the purpose is consistent with the original purpose. If we need to use your Personal Information for an unrelated or new purpose, we will inform you, explain the legal basis for doing so and obtain your consent, if required by law.

6. SHARING OF PERSONAL INFORMATION 

In the course of Recruiting Activities, Megatech will share your Personal Information with those who have a legitimate need to access it, for example:

  • internally, with appropriate Bombardier Recreational Products Inc. and Megatech personnel who require such Personal Information in connection with Recruiting Activities. This includes, for example, Human Resources and Talent Management team members, IT staff.
  • for legal or regulatory purposes, where disclosure of Personal Information is required to comply with our legal or regulatory obligations.
  • with vendors (including benefit providers), who may process your Personal Information on behalf of Megatech. The processing of such Personal Information will remain under the control of Megatech and will be carried out in accordance with Megatech’s instructions and strict security requirements.
  • in other contexts, in connection with Recruiting Activities, for example to obtain pre-employment references, when you need access to digital platforms to enable you to apply for a job or register for a recruiting event, for sponsorships from governments or other organizations, or in the event of a possible sale or restructuring of Megatech. In cases such as these, Megatech will limit the Personal Information provided and will attempt to anonymize it, to the extent possible.

Megatech does not allow third parties with whom we share your Personal Information to use that information for their own purposes. We allow them to process your Personal Information only to the extent necessary to perform their services and in accordance with our instructions.

In addition, as an international company, it may be necessary for Megatech to transfer your Personal Information to a different region or country than where it was originally collected. Megatech will ensure that such transfers of Personal Information comply with all applicable privacy laws and regulations and that appropriate safeguards are in place. If you have any questions about the transfer of your Personal Information, you may contact Megatech’s Human Resources Department.

7. RETENTION OF APPLICANTS PERSONAL INFORMATION

Your Personal Information is retained only as long as necessary for the purposes for which it was obtained by Megatech, including to satisfy any legal, accounting or reporting requirements. If Personal Information is needed for more than one purpose, Megatech will retain it until the end date of the purpose with the longest duration; however, Megatech will cease all use of such Personal Information for purposes with earlier end dates as soon as those dates are reached.

8.PROTECTION OF APPLICANT PERSONAL INFORMATION

Megatech has appropriate security measures in place to ensure that your Personal Information is protected against loss and unauthorized access. This protection applies to Personal Information stored in both electronic and paper format. In addition, Megatech uses generally accepted information security techniques, such as firewalls and access control procedures, to protect Personal Information from loss and unauthorized access.

Megatech employees who, in the course of their duties, are authorized to have access to Applicants’ Personal Information must take appropriate steps to protect that Personal Information.

9. RIGHTS AND RESPONSIBILITIES OF APPLICANTS

All Megatech Applicants have the right:

  1. to request information about how their Personal Information was collected, how it is stored and for what legitimate business purposes;
  2. to be informed if their Personal Information is shared, of the identity of the recipient or categories of recipients;
  3. to request that their Personal Information be corrected or completed;
  4. to request access to their Personal Information;
  5. to request the deletion of their Personal Information if the legal basis for processing the Personal Information has ceased to apply or the legitimate business purpose has expired or ceased to be applicable for other reasons. In evaluating such a request, Megatech’s business and legal requirements for archiving shall be taken into account;
  6. to object to the processing of their Personal Information when they believe that their privacy rights should take precedence over Megatech’s legitimate business purpose.

It is important that the Personal Information Megatech holds about its Applicants be accurate, current and complete. It is your responsibility to ensure this. Changes can be made directly in your Applicant record or by contacting Megatech’s Human Resources Department.

10. DATA PROTECTION OFFICER

If you have any questions, complaints or allegations of a breach of Megatech’s requirements for the processing of your Personal Information or to exercise your rights, you may contact Megatech’s Privacy Officer at: privacyofficer@brp.com. You may also file a complaint with a supervisory authority at any time.