1    Identification

Title: Guidelines for the Protection of Personal Information and the Destruction of Records

Person in charge: Secretary General

These Guidelines apply to: the entire Polytechnique community

Approval stages:

• Adopted by the Assemblée de direction on February 20, 2007 (ADD-465-263)
• Minor amendments made on November 25, 2008

2    Scope

These Guidelines cover all records and information held by Polytechnique Montréal.

3    Legal framework

Act Respecting Access to Documents Held by Public Bodies and the Protection of Personal Information), R.S.Q., Chapter A-2.1

 (Act to Protect Persons with Regard to Activities Involving Firearms and Amending the Act Respecting Safety in Sports), S.Q., Chapter 30.

4    Definitions

• Personal information: Any information concerning an individual and allowing that individual to be identified (e.g., address, phone number, notes, social insurance number, medical history and social status).
• Confidential document: Document containing personal information.

5    Confidential personal information

All personal information is confidential unless the individual whom the information concerns consents to its disclosure or when its communication is authorized by the Act. Information that is considered public as defined by the Act is not confidential.

5.1    Access to personal information

Only Polytechnique staff members who require personal information to carry out their duties may have access to such information.

5.2    Protection of personal information

All Polytechnique staff members must take reasonable measures to ensure the protection of personal information that is collected, used, communicated or held by Polytechnique Montréal.

5.3    Communication of personal information without consent

Personal information may be communicated without the consent of the person concerned in order to prevent an act of violence, including suicide, if there is reasonable cause to believe there is an imminent threat of death or serious injury to an identifiable person or group of people.

In such instances, only necessary information may be communicated to the person or people exposed to this danger, or to their representative or any other person who might be able to provide them with assistance.

Only the Chief Executive Officer and functional directors are authorized to communicate personal information in accordance with this provision. Once the communication has been made, all related information must be noted in writing and transmitted without delay to the General Secretary, who will record it in a specific registry held for this purpose.

5.4    Communication of personal information without consent (firearm)

A professor, professional or other person working at Polytechnique Montréal who has reasonable grounds to believe that a person is in possession of a firearm on Polytechnique premises, or who discovers that a firearm is present on the premises, must contact the police without delay.1
Similarly, professors or directors who have reasonable grounds to believe that a person, on Polytechnique premises, is displaying behaviour likely to compromise their own safety or that of another person through the use of a firearm, must report this behaviour to the police1 and provide them with the necessary information to facilitate their intervention.

When doctors, psychologists, guidance counsellors, educational psychologists, nurses, social workers or marriage and family therapists, in the course of their work, have reasonable grounds to believe that a person is displaying behaviour likely to compromise their own safety or that of others through the use of a firearm, they are authorized to report said behaviour to the police1 and provide the police with the necessary information to facilitate their intervention, including information protected by professional privilege or any other legal provision.

5.5    Request for access to records and personal information

All requests for access to records and personal information are received and reviewed according to the applicable law by the person in charge of access to records and protection of personal information appointed by Polytechnique management.

6    Destruction of confidential records

The Archives office is in charge of destroying confidential records within the time periods stipulated in the Calendrier de conservation des documents de l'École Polytechnique (Polytechnique Montréal records retention schedule).

This responsibility is shared. Employees at their own workstations are responsible for ensuring the protection of the confidential records they process. They must not discard records containing confidential information on hard copy or in electronic format (diskette, USB key, CD-ROM, magnetic tape, etc.) without first making sure that the content cannot be reconstructed.
If only a small volume of records need to be destroyed, they can be handled by an administrative unit with the appropriate resources (e.g., a shredder).

Units with a large volume of records in hard copy must place these documents in locked bins identified for this purpose. These bins are collected by Archives, which oversees the safe destruction of their contents.

Records in electronic format can be sent separately to Archives, which will ensure that they are destroyed in an appropriate manner.

All units that need to occasionally destroy a large volume of confidential records can send them to Archives, which will oversee their destruction.

7    Minor amendments

Any minor amendments to these Guidelines may be made by the General Secretary, who will inform the Assemblée de direction of them.

8    Effective date

These Guidelines are effective from the time they are adopted by the Assemblée de direction.