Understanding Quebec’s Law 25: Overview and key information

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Quebec’s Law 25, officially known as the Privacy Legislation Modernization Act, is a crucial piece of legislation that addresses these concerns and aims to modernize legislative provisions related to personal information protection. This comprehensive law has significant implications for businesses and organizations operating within the province.

Initially introduced in 2022 and continuing to roll out over a three-year period, Law 25 addresses various aspects of data privacy and protection. It applies to a broad spectrum of entities, encompassing companies, small to medium-sized businesses, and organizations conducting business activities in Quebec.

What are Quebec’s Bill 64 and Law 25?

Bill 64 is being proposed in Quebec to modernize privacy laws. The law was later dubbed Law 25. The legislation includes new requirements for businesses to protect their personal information from unauthorized persons who use the Internet.

What businesses must comply with Law 25?

Unlike other legislation requiring the Legislature to adopt a comprehensive statute, the Quebec legislation applies to private companies and public organizations operating throughout Quebec. It entails the collection or use of information about Quebec citizens by companies in their business activities. The obligations vary depending on the nature of the business, how many personal data are collected, and the circumstances within which the processing is conducted.

Business obligations and implementation timeline

Law 25 makes alterations, which can take considerable work to implement, but that’s not a miracle of a day. In a 2021 vote, lawmakers split their business obligations into three phases: the major changes will take effect by 2024, and the majority will take effect in 2023.

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Phases of Law 25

Quebec Law 25 introduces a phased approach to its requirements, which are designed to enhance data privacy and protection gradually. These phases come into effect on specific dates, each with its set of obligations for businesses.

Phase 1 – September 22nd, 2022

Starting on September 22nd, 2022, businesses operating under Quebec Law 25 must designate a privacy officer who will oversee data privacy matters. Additionally, they are required to establish an incident management plan to address potential data breaches promptly. Maintaining a privacy incident log is another essential aspect of this phase, ensuring that any privacy incidents are documented thoroughly. Moreover, businesses must disclose these privacy incidents to the Commission d’accès à l’information (CAI) for transparency. Lastly, if biometric processes are used to develop a database, businesses must inform the CAI at least 60 days in advance.

Phase 2 – September 22nd, 2023

By September 22, 2023, businesses need to implement further measures. They must establish a governance framework that outlines how they will handle and protect personal information. This includes publishing a comprehensive privacy policy that informs individuals about data handling practices. Handling personal information complaints becomes an essential part of this phase, necessitating the development of a structured process for addressing such issues.

Furthermore, businesses must provide individuals with the option to opt-in for the collection of their personal information, ensuring their consent is obtained transparently. They are also required to offer sufficient notice when collecting personal information and establish appropriate contractual agreements with any third parties who will receive this data.

An important aspect of this phase is the obligation to delete or anonymize personal information upon consumer request, respecting the right to be forgotten. Correcting inaccurate personal information, avoiding automated decision-making upon request, permitting consumers to withdraw their consent, conducting privacy impact assessments under certain circumstances, and informing data subjects when their personal information may be transferred outside of Quebec are additional responsibilities that businesses must address during this phase.

Phase 3 – September 22nd, 2024

The final phase, commencing on September 22, 2024, mandates that businesses provide data subjects with their collected personal information in a portable format upon request. This step ensures that individuals have greater control and access to their own data, aligning with the overarching goal of Quebec Law 25 to enhance data privacy and empower individuals with greater control over their personal information.

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Who is covered under Law 25?

The 25 Law provides full and comprehensive protection of personal details, regardless of nationality or location of residence, for the purpose of which the information is stored under the law. Those who reside there also include Canadians from another province and many Canadians who are citizens of other countries, too! It provides further safeguards for children younger than 13 years old, who need a stricter consent procedure to do so. It is also a security mechanism to protect personal data collected by people who have died. Businesses outside Quebec or Canada generally have to adhere to Law 25 for processing information about residents in Quebec.

Subject rights

Subject rights under section 26 have similar characteristics to those under the GDPR. Almost the entire subject right is set for effect from September 2023, and data transfer will start in September 2024. In Quebec, subject rights include the ability to request privacy information on time with a possible extension of 90 days.

How is ‘Personal Information’ defined under Law 25?

The intent of Law 25 is to update the current privacy framework for Quebec and the law relating, in particular, to the definitions of personal data under Quebec law. According to privacy laws, personal information includes information relating to a specific individual. These might include names, addresses, ages, genders, identification numbers, financial details, and even specific online identifications. The data is not required for identification by itself.

Modernizing legislative provisions

Quebec’s Law 25 is a significant step forward in modernizing legislative provisions governing data protection in the province. Its primary objective is to ensure that individuals’ personal information remains secure, even in an age of rapid technological advancements. The law introduces several key concepts and measures to achieve this goal.

Data portability and control

One of the fundamental principles of Quebec’s Law 25 is the emphasis on data portability. It recognizes that individuals should have control over their personal information and the ability to move it from one service provider to another. This provision empowers the person concerned by providing them with more choices and flexibility regarding their data.

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The law places a strong emphasis on transparency and consent systems. It requires organizations in the private sector to communicate clearly and in simple language how they collect, use, and disclose personal information. Moreover, obtaining express consent from individuals for data processing activities is a cornerstone of this legislation. This approach ensures that individuals are fully informed about how their data will be used and have the opportunity to consent or withdraw consent as needed.

Privacy officers and impact assessments

To ensure compliance with the law, organizations are required to appoint a privacy officer responsible for overseeing personal information protection. Additionally, mandatory privacy impact assessments are introduced to assess and mitigate privacy risks associated with data processing activities. These measures collectively enhance accountability and protection.

Key provisions in Quebec’s Law 25

This law includes several important provisions that are designed to address various issues and challenges facing the province. Some of the key provisions of Law 25 include measures to promote transparency and accountability in government, protect the rights and interests of citizens, and promote economic growth and development. Additionally, the law includes provisions that are designed to improve access to healthcare and education, as well as measures to address environmental concerns.

Mandatory breach reporting

Quebec’s Law 25 introduces mandatory breach reporting, which means that private organizations must report data breaches to affected individuals promptly. This provision ensures that individuals are informed about any potential risks to their personal information, allowing them to take appropriate action.

Biometric database protection

In an era where biometric data is increasingly used for authentication and identification, the law places specific protections on biometric data. Organizations must take reasonable measures to protect biometric information from unauthorized access and disclosure.

Automated decision-making

The law also addresses automated decision-making processes that impact individuals. It ensures that individuals have the right to challenge decisions made solely through automated processing, particularly when they could result in serious harm.

Consumer rights framework

Quebec’s Law 25 aligns with the General Data Protection Regulation (GDPR) and other international privacy standards. This alignment ensures that individuals in Quebec enjoy similar rights and protections as their counterparts worldwide. These rights include the right to access personal information, request its deletion, and obtain valid consent.

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Compliance and impact on private sector entities

It is compulsory for private sector companies in Quebec to adhere to the regulations set forth by this law. Failure to comply with these provisions can lead to serious repercussions, such as significant fines and harm to their reputation. That being said, it is of utmost importance for businesses to allocate resources towards implementing comprehensive data protection measures and routinely assess and revise their privacy policies and protocols. By doing so, they can ensure that they are operating ethically and responsibly while safeguarding their clients’ sensitive information.


Quebec’s Law 25, the Privacy Legislation Modernization Act, represents a significant step forward in the protection of personal information in the digital age. It modernizes legislative provisions, emphasizes data portability, transparency, and consent systems, and introduces measures to hold private sector entities accountable for data protection. Understanding and complying with this law is not just a legal requirement but also a demonstration of commitment to privacy and data security in an increasingly data-driven world. By adhering to these principles and provisions, businesses can navigate the complex landscape of data privacy while ensuring the rights and protection of the person concerned.

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