Privacy Notice

Current version: May 22, 2024
Effective as of: May 22, 2024

Overview

McGill University (“McGill”, also referred to as the “University”, “we”, “us” or “our”) prioritizes appropriate handling of the Personal Information (as defined below) entrusted to us. This Notice, including Annex A, is adopted pursuant to McGill’s Policy on the Governance of Personal Information (“Governance of PI Policy”). It may be supplemented by additional information made available through publicly available guidelines, or through the use of separate consents where required.

McGill is subject to the Act respecting Access to documents held by public bodies and the Protection of Personal Information, chapter A-2.1 (the "Access Act"), as well as our Governance of PI Policy and associated guidelines and procedures adopted pursuant to the Access Act. McGill seeks to limit the amount of Personal Information we collect to what is necessary, and limits access to such Personal Information, as required by law.

This Notice sets out how McGill collects, uses, processes, communicates, transfers, retains, and disposes of (collectively referred to as “processing” or “process”) your Personal Information. In this Notice, the word “you” refers to any individual whose personal information is processed by McGill. “Personal Information” means information concerning a natural person which directly or indirectly allows the person to be identified.

McGill collects Personal Information in a variety of contexts and from various stakeholder groups. You will find more specific information about how we process your Personal Information—depending on your relationship to McGill (e.g., student, staff, alumni, donor)—in Annex A to this Notice. Please see Section 3 below for general information on how we process Personal Information, and Annex A for audience specific notices.

This Notice also informs you of your rights regarding your Personal Information processed by McGill. Please refer to Section 5 of this Notice to learn more about your rights.

While this Notice and Annex A cover the most common circumstances where McGill processes your Personal Information, there will be instances that require additional privacy notices, disclosures, or consents.

1. When does this Notice apply?

This Notice applies when you communicate Personal Information to us in any manner, such as when submitting a form via email, our website, systems or portals, in person or by telephone. This Notice also applies when we receive Personal Information about you from third parties who are authorized to share your Personal Information with us; for example, when another educational institution provides McGill with information to support a student application.

Please note that this Notice is not exhaustive and does not describe all the ways that McGill may process your Personal Information. Before we process any Personal Information in a manner or for purposes not described in this Notice, we will provide you with supplemental notices and/or consent forms regarding such processing.

By providing us with Personal Information after you have had an opportunity to review this Notice (and its Annex A), you consent to the processing of your Personal Information in accordance with this Notice.

2. How to contact McGill staff who can assist you with Personal Information matters

We will promptly treat questions, comments, requests, and complaints regarding the implementation of this Notice. When you contact us, proof of your identity will be required so we can ensure we are responding to an authorized person.

For information about how a specific unit processes your Personal Information, please see section 2.1 below. For general comments, questions, or complaints about how McGill processes your Personal Information, please see section 2.2. For requests to access or correct your Personal Information pursuant to the Access Act, please see section 2.3.

2.1. Unit-Specific Requests, Questions Comments

Please first contact the McGill unit involved in processing your Personal Information if you have questions or comments about a specific unit’s privacy practices or if you wish to exercise your individual rights within a specific unit. For example:

2.2. General Requests, Questions, Comments

If you did not find a suitable unit-specific contact (see above), please contact McGill’s privacy.secretariat [at] mcgill.ca (Access and Privacy Office) if you have questions or comments about the University’s privacy practices or if you wish to make a complaint. See Section 5.4 for information about formal complaints.

McGill’s Access and Privacy Office

by e-mail: privacy.secretariat [at] mcgill.ca

by mail:

Privacy Officer
James Administration Building, Room 313
845 Sherbrooke Street West
Montreal, Quebec H3A 0G4

by phone: 514-398-4719

2.3. Requests for access to, or correction of your Personal Information

You have the right to request access to your Personal Information held by McGill. You may also request that your information be corrected if it is erroneous, incomplete, or equivocal (see sections 5 below for more information about your rights). Such requests must be addressed to the University Secretariat.

McGill Secretariat

by e-mail: accesstodocuments.secretariat [at] mcgill.ca

by mail:

Secretary-General
James Administration Building, Room 313
845 Sherbrooke Street West
Montreal, Quebec H3A 0G4

by phone: 514-398-1568

3. How do we process your Personal Information?

In order to fulfill its various missions, McGill collects several types of Personal Information. We take steps to ensure that the Personal Information we collect about you is limited only to what is necessary to achieve a defined, specific, and limited purpose.

The Personal Information that we collect and use depends on the context of our interactions with you (e.g., whether you are a student, prospective student, employee etc.). You will find further audience-specific information about how we process your Personal Information in Annex A, including the typical categories of Personal Information that we collect, an overview of the purposes for which McGill processes such information, and how we share your Personal Information with third parties, if applicable.

We have established procedures to provide security measures for access to physical and electronic records containing the Personal Information that is under our control. For example, only staff members with a need-to-know will have access to your Personal Information.

Your Personal Information will be retained in accordance with our business and legal obligations and only as long as reasonably necessary to fulfill those obligations, subject to the time limits set out in the McGill University Records Retention Schedule (MURRS).

If your Personal Information is processed or stored outside of Québec, our practices regarding your Personal Information will at all times be governed by this Notice, its Annex A and applicable privacy laws. Please note that the privacy laws in other jurisdictions may differ from Québec privacy laws and may not offer the same level of protection as privacy laws in your jurisdiction. When information is stored or processed outside Québec, it may be subject to the laws of, and accessible by, legal authorities in those other jurisdictions. We implement contractual clauses with service providers to ensure your Personal Information is protected.

4. How and when does McGill communicate your Personal Information to third parties?

In compliance with the Access Act, McGill is permitted to disclose your Personal Information to third parties, where the information is necessary for the third party to carry out a mandate or meet contractual obligations. We will only communicate your Personal Information to a third party under a contract obliging the third party to treat the information in a secure and confidential manner.

McGill may share relevant Personal Information with third-party service providers performing services on our behalf, such as providers of IT services, marketing services, and data hosting services.

McGill may also disclose your Personal Information to courts, law enforcement, or other government agencies in order to comply with legal and regulatory requests, applicable laws, or contracts; or to respond to a court order, McGill administrative or judicial processes.

When communicating Personal Information to a third party, McGill will only disclose the Personal Information necessary to achieve the relevant purpose of such disclosure. Refer to Annex A for audience-specific information about disclosures to third parties.

For categories of Personal Information not treated under this Notice or its Annex A, we may use supplemental notices to inform you and obtain your consent.

5. What are your rights?

You have various rights when it comes to your Personal Information, as detailed below. Please see Section 2 regarding how to contact us to exercise a right.

5.1. Access

Subject to certain exceptions under the Access Act, we will give you access to the Personal Information we hold about you.

Students may access certain Personal Information via Minerva (or Athena, for non-credit courses and activities). Students can also access certain Personal Information related to IT Services offered to them on the following website: https://www.mcgill.ca/it/students. Students seeking access to the contents of their student files may contact Enrolment Services and/or their home department or faculty.

Staff members may access their Personal Information via the Workday platform. Staff members requesting the contents of their personnel files may contact Human Resources. Academic Staff members may also contact the Academic Personnel Office.

Finally, any person may submit a formal access request under the Access Act to the University Secretariat.

5.2. Rectification

You have the right to request that we correct any Personal Information held about you that you believe is incorrect, inaccurate or incomplete.

Finally, you may submit a formal request under the Access Act for the correction of your Personal Information to the University Secretariat.

5.3. Refusal or Withdrawal of Consent

You may refuse to provide certain Personal Information, or refuse consent to the processing of your Personal Information, by clearly indicating your refusal at the time of collection. Depending on the context, your refusal may be communicated by omission (e.g., by refusing to complete or sign a form), or affirmatively (e.g., by verbally refusing consent, or by selecting certain options limiting the use of your Personal Information at the time of collection).

You may also withdraw your consent to the Processing or disclosure of your Personal Information by contacting the appropriate Unit, as set out in Section 2 above, or by other processes that may be identified at the time of collection (e.g., students may complete and submit an Opposition Form to Enrolment Services). Proof of your identity will be required to withdraw consent.

In some cases, refusal to provide Personal Information or consent to our processing of your Personal Information may mean that we will be unable to provide you with services and may result in a reduction in the quality of certain services offered (e.g., certain Personal Information is required to determine whether a student qualifies for awards or bursaries). We will help identify any consequences or limitations that may result from the refusal or withdrawal of your consent, where applicable.

We are required to maintain records that include elements of your Personal Information for regulatory compliance and administrative purposes (e.g., payroll, disciplinary or enrolment information).

5.4. Complaint

You have the right to ask questions, make comments and file a complaint. The process to receive and respond to complaints or inquiries regarding our processing of your Personal Information and our compliance with this Notice and applicable privacy laws is described in our Governance of PI Policy.

If you are unable to resolve an issue, comment or concern by communicating with the specific Unit involved in the processing of your Personal Information, you may lodge a formal complaint with McGill’s Access and Privacy Office using the procedure and form for this purpose and the contact information in Section 2. All complaints will be investigated by McGill’s Access and Privacy Office, which will determine whether the processing of your Personal Information complies with our policies, procedures, guidelines and applicable laws. McGill’s Access and Privacy Office will make every reasonable effort to resolve your complaint. You will be informed of any progress or outcome of the investigation. Depending on the nature of your complaint, it may be necessary to verify your identity.

You may also file a complaint with the Commission d’accès à l’information du Québec by using the appropriate form available on the following website: https://www.cai.gouv.qc.ca/english. However, we encourage you to first contact privacy.secretariat [at] mcgill.ca (McGill’s Access and Privacy Office).

5.5. How to Exercise Your Rights

To exercise any of the rights outlined above, please contact McGill’s Access and Privacy Office as indicated in Section 2 of this Notice. McGill will only consider written requests. Your request must include a proof of your identity and provide sufficient details to help us validate your request.

6. Security Measures

We follow industry security standards to protect the Personal Information we collect and receive. In particular, we have put in place appropriate physical, technical, IT and administrative safeguards to protect your Personal Information against confidentiality incidents.

Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or warrant the security and confidentiality of any information you transmit or provide to us. If you have reason to believe that Personal Information has been compromised, please contact us as indicated in Section 2 of the Notice.

7. Cookies

Please refer to our Cookies Notice for detailed information regarding cookies and other tracking technologies employed by McGill, including the purposes for which McGill is using cookies and how you can manage your cookie preferences.

8. Third-Party Websites and Services

Our websites, portals and some other means of communication with you may contain links to content, to services or to sites or applications maintained by third parties that McGill does not control. You understand that we are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Notice.

9. Modification to this Notice

We may, from time to time, modify this Notice to reflect changes in our processes or in the law.

Before entering into effect, the intended modifications will be published on the University’s website along with a notice of such changes.

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