Effective Date: December 17, 2025 
Last Updated: December 17, 2025

 

Introduction 

OctanePeople (“we”, “us”, “our”) is an executive search and talent acquisition firm based in Ontario, Canada. This Privacy Policy explains how we collect, use, disclose, and protect personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Ontario’s Employment Standards Act, the Working for Workers Act and related regulations, and any other applicable provincial laws. 

This Policy applies to candidates, client representatives, and website users whose personal information we handle in the course of providing recruitment and related advisory services. 

Contact Information 

Company Name: OctanePeople 
Email:info@octanepeople.com  
Phone: 519-204-8341 
Province of Operation: Ontario, Canada 

For privacy‑related inquiries, access or correction requests, or complaints, please contact us using the information above. 

Accountability 

OctanePeople is responsible for personal information in its possession or control and is committed to complying with PIPEDA and applicable provincial privacy and employment laws. A designated Privacy Officer is accountable for our privacy program, including policies, procedures, and responses to questions or complaints about our handling of personal information. 

As a recruitment and talent acquisition firm, we do not maintain HR or training records for our clients’ employees. Our accountability relates specifically to the personal information of candidates, client contacts, and website users that we collect, use, or disclose in the course of providing executive search and advisory services. 

Identifying Purposes 

Before or at the time personal information is collected, we identify the purposes for which it is being collected. We collect and use personal information for purposes that a reasonable person would consider appropriate in the context of recruitment and executive search, including: 

  • Assessing candidates for current and future opportunities 
  • Presenting candidates to client organizations for specific mandates 
  • Understanding client strategy, structure, and culture to support accurate and effective placements 
  • Advising clients on talent markets, organizational design, and search strategy 
  • Managing relationships and communications with candidates and clients 
  • Operating, maintaining, and improving our services and website 
  • Meeting legal, regulatory, tax, and audit requirements under PIPEDA, the Employment Standards Act, the Working for Workers Act framework, and other applicable laws 

If we intend to use personal information for a new purpose not previously identified, we will identify that purpose and, where required, seek additional consent. 

Consent 

We obtain meaningful consent for the collection, use, and disclosure of personal information, except where otherwise permitted or required by law. Consent may be express (verbal, written, or electronic) or implied (for example, where you submit your resume to be considered for opportunities). 

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we will explain any implications, such as our ability to continue considering you for roles. 

In limited circumstances, we may collect, use, or disclose personal information without consent where allowed by law, such as to comply with a court order, investigate a breach of an agreement, or as otherwise permitted by PIPEDA, the Employment Standards Act, the Working for Workers Act, and other applicable legislation. 

Limiting Collection 

We collect personal information only to the extent necessary for the purposes identified in this Privacy Policy and by lawful means. 

We do not collect or store Social Insurance Numbers (SINs) in the course of providing our recruitment and executive search services. 

We do not seek or require past salary history where this is restricted or discouraged under applicable employment standards or related legislation, including reforms introduced through Ontario’s Working for Workers Act and related regulations. Where candidates voluntarily provide compensation expectations or limited historical compensation information, we treat that information as sensitive and use it only for legitimate recruitment‑related purposes in compliance with PIPEDA, Ontario’s Employment Standards Act, and the Working for Workers legislative framework. 

We will continue to monitor legislative and regulatory changes, including future regulations and guidance issued under the Working for Workers Act and its subsequent amendments, and adjust our practices as required to remain compliant. 

What Personal Information We Collect 

From Candidates 

Depending on the engagement, we may collect: 

  • Contact information (name, email address, phone number, city/province or state of residence) 
  • Employment history and professional experience 
  • Educational background, designations, and certifications 
  • Resume, CV, cover letter, and supporting materials 
  • Professional references and reference contact details 
  • Publicly available professional profile information (for example, LinkedIn or corporate biographies) 
  • Skills, competencies, career interests, role preferences, and geographic mobility 
  • Compensation expectations and, where voluntarily disclosed and permissible, relevant compensation details 
  • Interview scheduling, availability, and communication history 
  • Interview notes, assessments, and feedback from our discussions with you 

From Client Organizations 

Depending on the mandate, we may collect: 

  • Organization name, address, industry, and contact details 
  • Names, titles, and contact information for hiring managers, executives, and other decision‑makers 
  • Detailed position descriptions, reporting lines, performance expectations, and success measures 
  • Information about organizational strategy, business plans, priorities, and growth objectives relevant to the search 
  • Information about team structure, capabilities, strengths, and areas for development or skill gaps 
  • Information about cultural norms, leadership styles, and working environment 
  • Compensation ranges, incentive structures, benefits, and non‑financial rewards associated with the role 
  • Feedback on candidates, search progress, and outcomes 

To the extent this information includes personal information about identifiable individuals (for example, named leaders or team members discussed in the context of a search), we treat it as personal information and protect it in accordance with this Privacy Policy. 

From Website Users and Other Interactions 

We may collect: 

  • IP address, browser type, device information, and general location data 
  • Pages visited, time on site, and interaction data (via cookies and similar technologies) 
  • Information submitted through website forms, email, or other communication channels 

How We Collect Personal Information 

We collect personal information in various ways, including: 

  • Directly from you when you submit a resume, apply through our website, email us, or speak with us by phone or video 
  • Through interviews and ongoing conversations during the recruitment process 
  • From professional references you authorize us to contact 
  • From public, professional sources such as LinkedIn, corporate websites, professional associations, and other directories where individuals have chosen to make information publicly available 
  • From client organizations in the context of a search or advisory mandate 

When we use publicly available professional sources, we do so only for purposes that a reasonable person would consider appropriate in the recruitment context and consistent with PIPEDA’s expectations for appropriate use and meaningful consent. 

Use of Recording and AI Transcription Tools 

With your knowledge and consent, we may record certain candidate and client meetings (including video or phone calls) using secure third‑party tools that include artificial intelligence features for transcription and note generation. 

These tools are used only to: 

  • Accurately capture discussions 
  • Create transcripts and summaries for internal use 
  • Enhance the quality, accuracy, and consistency of our search and advisory services 

We do not use artificial intelligence or automated decision‑making systems to screen, rank, or make hiring decisions about candidates. AI‑enabled tools are used solely to support accurate note‑taking and service delivery, not to independently evaluate or score individuals. 

Before recording any meeting, we will inform you that the session may be recorded and transcribed and provide an opportunity to decline. If you do not wish to be recorded, we will disable recording and take manual notes instead. 

Recordings and transcripts are treated as personal information and protected under the same safeguards described in this Policy. Where AI transcription providers are located outside Canada, your information may be processed in those jurisdictions; we use contractual and technical measures to help ensure a level of protection comparable to Canadian standards. 

How We Use Personal Information 

We use personal information to: 

  • Identify, assess, and present candidates for current and future roles 
  • Understand our clients’ strategy, organization, culture, and leadership needs so we can recommend candidates who are likely to succeed in the role and environment 
  • Communicate with candidates and clients regarding opportunities, mandates, and engagement progress 
  • Provide talent market insights and advisory services on recruitment and organizational design 
  • Manage relationships, billing, and business records 
  • Operate, secure, and improve our systems, processes, and website 
  • Comply with legal, regulatory, tax, and professional obligations under PIPEDA, the Employment Standards Act, the Working for Workers Act, and other applicable laws 

We do not sell personal information to third parties. 

How We Share Personal Information 

We may disclose personal information to: 

  • Client organizations that have engaged us to conduct a search, when you are being considered for or have expressed interest in a specific opportunity, or where you have requested that we facilitate introductions 
  • Service providers (for example, IT hosting, applicant tracking, video‑conferencing, AI transcription, and professional services) that support our operations under agreements requiring appropriate privacy and security safeguards 
  • Professional advisors such as legal or accounting advisors, where necessary for compliance, dispute resolution, or risk management 
  • Regulators, courts, or government bodies where required or permitted by law 

We limit disclosures to what is reasonably necessary for the purposes described and require third parties to protect personal information in a manner consistent with this Policy and applicable law. 

Cross‑Border Transfers 

Some of our service providers, including AI transcription and cloud hosting providers, may be located outside Canada (for example, in the United States). Personal information processed or stored in other jurisdictions may be subject to the laws of those jurisdictions and accessible to their authorities. 

We use contractual and technical safeguards designed to ensure that cross‑border processing affords a level of protection comparable to that required under Canadian privacy law. 

Retention of Personal Information 

We retain personal information only as long as necessary to fulfill the purposes identified in this Policy or as required by applicable federal and provincial legislation, including PIPEDA, Ontario’s Employment Standards Act, and the Working for Workers Act and related regulations, which together govern certain employment‑related records, transparency obligations, and monitoring practices. 

  • Candidate Information: We generally retain candidate information (including resumes, communications, interview notes, and related records) for up to 5 years from the last meaningful interaction, to consider you for future opportunities and maintain accurate search history, unless you request deletion sooner and we are not required by PIPEDA, the Employment Standards Act, the Working for Workers Act framework, or other applicable laws to retain the information. 
  • Client Information: We retain client records, mandate files, and billing information for the duration of the client relationship and for at least 7 years thereafter to satisfy contractual, tax, audit, and legal obligations, including those under Ontario employment and labour legislation and the Working for Workers Act. 
  • Recordings and Transcripts: Recordings and AI‑generated transcripts of meetings are retained only as long as necessary to complete or support a specific search or advisory engagement and in accordance with our standard retention periods, then securely deleted or anonymized unless a longer retention period is required by law or is necessary to address a complaint or legal claim under PIPEDA, Ontario employment law, or the Working for Workers Act framework. 

We periodically review the personal information we hold and securely destroy, anonymize, or de‑identify information that is no longer required, using methods appropriate to the format and sensitivity of the data, consistent with PIPEDA, the Employment Standards Act, and the Working for Workers Act and its regulations in force as of January 1, 2026. 

Safeguards 

We protect personal information through physical, organizational, and technological safeguards appropriate to its sensitivity, including: 

  • Role‑based access controls and need‑to‑know restrictions 
  • Secure, password‑protected systems and, where appropriate, encryption 
  • Confidentiality obligations for personnel and service providers who handle personal information 
  • Secure destruction processes for physical and electronic records 

We maintain incident‑response processes. Where a breach creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada, and any required provincial authorities, in accordance with legislative requirements. 

Cookies and Website Technologies 

Our website may use cookies and similar technologies to improve functionality, analyze traffic, and understand how visitors use our site. You can adjust your browser settings to refuse or delete cookies, though this may affect site function.