Privacy, Retention, and Destruction of Personal Information Policy
Last updated: July 31, 2026
Person Responsible for the Protection of Personal Information: the President of the Company
1. Purpose
This policy confirms compliance with the rules governing the retention period and secure destruction procedures for personal information collected by Alpha Translation and Interpretation Inc. in the course of its activities involving clients, suppliers, and employees.
2. General Principles
Retention Limitation
The Company retains personal information only for the period necessary to fulfill the purposes for which it was collected, or as required by applicable legal or tax obligations.
Secure Destruction
Once the intended purposes have been fulfilled or the legal retention period has expired, documents containing personal information are permanently and irreversibly destroyed.
Collection of Personal Information
Whether consisting of contact details or other information relating to an individual client or an independent freelance contractor, such information is retained solely for the Company's use.
Our freelancers are invited to complete an authorization form permitting the retention and disclosure of personal information. They may withdraw their consent at any time.
Any disclosure of personal information to a freelancer for the purpose of carrying out a project is governed by a written contract that includes, among other things:
- A description of the security measures to be implemented;
- A requirement to destroy the data immediately upon completion of the assignment;
- An obligation to inform us immediately of any data breach or information leak.
Privacy Incident Register
Maintaining this register is a direct legal requirement under Law 25. Any event considered to be a privacy incident must be reported to our Privacy Officer. The affected individual(s) will be notified. If it is determined that there is a risk of serious harm, the Commission d'accès à l'information du Québec (CAI) will also be informed. Records will be retained for a minimum period of five (5) years from the date the incident was discovered.
3. Personal Information Retention Schedule
| Document Category | Information Concerned | Retention Period | Reason / Obligation |
|---|---|---|---|
| Original client documents (e.g., birth certificates, civil records, contracts) | Names, addresses, confidential information contained in documents | Maximum 30 days following delivery | Privacy protection / Reduction of data breach risks |
| Translation deliverables and translation memories | Translated content, terminology | 6 years after file closure | Tax requirements / Protection of rights and commercial dispute defense |
| Freelancer files and directories | Résumés, contact information, rates, internal notes, assignment history | As long as the freelancer remains active (+2 years after inactivity, unless deletion is requested by the freelancer) | Talent database management / Consent requirements under Law 25 |
| Financial documents and invoices | Names, addresses, banking information, voided cheque specimens | 6 years following the end of the fiscal year | Revenu Québec / Canada Revenue Agency requirements |
4. Procedure for Destruction of Electronic Documents
For all personal information stored digitally (emails, attachments, files saved on workstations, or cloud services):
Deletion of Emails and Attachments
- Permanently delete the message from the inbox or sent items;
- Immediately empty the Trash/Deleted Items folder in the email application.
Deletion from Local Workstations and Servers
- Delete the file from working folders;
- Empty the operating system recycle bin (Windows/Mac).
Cloud Storage and Backup Cleanup
- Delete the file from the cloud service recycle bin (OneDrive, Google Drive, etc.).
5. Procedure for Destruction of Paper Documents (Where Applicable)
Employees are encouraged not to print documents containing personal information. At the client's request, a paper copy of a certified translation may be provided.
Where printing is necessary, destruction shall be carried out by cross-cut shredding (minimum DIN 66399 P-4 standard) or through a specialized external service provider that issues a Certificate of Destruction.
Additional Information About This Policy
The person responsible for enforcing Law 25 - New Provisions Protecting the Privacy of Quebecers is also responsible for ensuring compliance with this policy. Any questions, comments, or complaints regarding non-compliance with this policy may be directed to:
The President of Alpha Translation and Interpretation Inc.
Phone:
514-424-4642
111-750 Chemin Ste-Foy
Québec, Québec G1S 4P1
Email:
administration@alpha-interpretation.com
