Employee Privacy Policy
PURPOSE AND SCOPE
This Employee Privacy Policy (“Policy”) establishes the responsibilities of all employees of GVE Global Vision Inc. (“GlobalVision”) to protect the confidentiality and privacy of information relating to the company, its employees, clients, suppliers, and business partners. It applies to all employees, regardless of location, as well as contractors, consultants, freelancers, and any other individuals working on behalf of or with GlobalVision. The Policy is designed to ensure compliance with all applicable privacy laws, including those of Quebec and any other relevant jurisdictions.
EMPLOYEE OBLIGATIONS TO PROTECT DATA PRIVACY AND CONFIDENTIAL BUSINESS INFORMATION
Employees are entrusted with access to confidential business information and personal information or data, including information or data about clients, suppliers, business partners, and fellow employees. Employees must:
Treat all such information or data as strictly confidential.
Use confidential and personal information or data only for legitimate business purposes and only as necessary to fulfil their job responsibilities.
Never disclose, share, or misuse confidential or personal information or data, whether intentionally or inadvertently, and regardless of the medium (written, electronic, verbal, etc.).
Ensure that any information or data accessed, processed, or stored is handled in accordance with GlobalVision’s policies and applicable privacy laws.
ACCESS RIGHTS AND LIMITATION
Access to confidential and personal information or data is strictly limited to employees who require it to perform their duties. Employees must not attempt to access information or data beyond their authorized scope. Access rights are granted on a need-to-know basis and are subject to regular review and audit by the Data Protection Officer (DPO) and/or relevant committees.
Any request for access to personal information or data by an individual (employee, client, or other) must be handled in accordance with GlobalVision’s procedures and applicable privacy laws. Employees must cooperate with the Data Protection Officer (DPO) and/or relevant committees in responding to such requests.
COMPLIANCE WITH DATA PRIVACY LAWS AND COMPANY POLICIES
Employees must comply with all applicable privacy laws, and any other relevant legislation. Employees are also required to adhere to all GlobalVision policies and procedures relating to data protection, including:
Bring Your Own Device (BYOD) Policy
Acceptable Use of Assets Policy
Access Control Policy
Information Security Policy
Record Retention Policy
Remote Work Policy
Data Classification and Labelling Policy
Employees may not act in contravention of any of these policies under any circumstances. Employees must ensure that any device used to access GlobalVision systems or data, whether company-owned or personal (BYOD), is secured in accordance with GlobalVision’s security requirements.
PARTICIPATION IN TRAINING AND AWARENESS
All employees are required to participate in mandatory training sessions on data privacy, confidentiality, cybersecurity, and information security as scheduled by GlobalVision. This includes regular updates and refresher courses to ensure ongoing awareness of current threats and best practices. Completion of such training is a condition of employment or contractual engagement, as applicable.
SECURITY MEASURES AND COMPLIANCE
GlobalVision has implemented multiple layers of security safeguards (technical, physical, organizational, and administrative) to protect confidential and personal information or data from loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. Employees must:
Comply with all security measures and controls in place.
Never attempt to bypass, disable, or undermine any security controls or procedures.
Use only authorized devices and systems for accessing company information or data.
Employees are responsible for ensuring that personal information or data is handled securely at all times, including during collection, use, storage, transmission, and destruction.
REPORTING DATA BREACHES AND SUSPICIOUS ACTIVITY
If an employee becomes aware of, or suspects, a data breach or privacy incident (including unauthorized access, use, loss, or disclosure of personal information or data), they must immediately report it to the Data Protection Officer and/or relevant committees in accordance with GlobalVision’s Information Security Event and Incident Management Procedure.
Employees must also report any suspicious emails, phishing attempts, or other potential cybersecurity threats to the IT department or designated contact, and follow all instructions provided during cybersecurity training.
PROHIBITION OF CONTRAVENTION AND UNAUTHORIZED DISCLOSURE
Employees are strictly prohibited from:
Contravening any GlobalVision policy or procedure relating to data privacy, confidentiality, or information security.
Disclosing confidential or personal information or data to unauthorized persons, either within or outside the organisation.
Using confidential or personal information or data for any purpose other than that for which it was collected and authorised.
RETURN OF COMPANY PROPERTY UPON TERMINATION
Upon termination of employment or the contractual engagement, whether voluntary or involuntary, all employees are required to promptly return to GlobalVision all company property, equipment, and materials in their possession or control. This includes, but is not limited to, company-owned laptops and mobile devices, access cards, keys, documents (in any format), storage media, and any other items or materials containing company information or personal information or data.
Employees must not retain, copy, or transfer any confidential or personal information or data belonging to GlobalVision after their employment or contract ends. The return of all such property is a condition of the completion of the termination process and may be subject to verification by the Data Protection Officer, the Legal Department and/or other relevant departments. Failure to return company property or materials may result in legal action and/or the withholding of final payments, as permitted by law.
CONSEQUENCES OF NON-COMPLIANCE
Any violation of this Policy may result in disciplinary action, up to and including termination of employment or contractual engagement. In addition, employees may be subject to civil or criminal prosecution if their conduct violates applicable laws or regulations.
QUESTIONS AND FURTHER GUIDANCE
Employees who have questions about this Policy, their obligations, or the handling of confidential or personal information or data should contact the Data Protection Officer at privacy@globalvision.co or through the Legal Department.
This Policy is reviewed and updated as required to ensure ongoing compliance with applicable laws and best practices.
Date of last review: August 6th, 2025