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16 min readBeginner

Law 25: checklist compliance for Quebec small businesses

Law 25 on the protection of personal information applies to EVERY business in Quebec, no matter the size. Here's your concrete checklist to get compliant.

FIG 0.0 · INTRO

What is Law 25?

Law 25, officially the Act to modernize legislative provisions as regards the protection of personal information, came into force gradually starting in September 2022. Since September 2024, all of its provisions are in force.

It's the Quebec equivalent of Europe's GDPR. It strengthens citizens' rights over their personal data and imposes strict obligations on businesses that collect, use or share that data.

FIG 0.1 · WHO'S AFFECTED

Who's affected?

Every business that collects personal information in Quebec, no matter:

  • Its size (even self-employed workers)
  • Its industry
  • Whether it's incorporated or not
  • The number of clients or employees
Heads upIf you have a website with a contact form, you're collecting personal information. Law 25 applies to you.
FIG 0.2 · OBLIGATIONS

The 8 main obligations

1

Name a person in charge of the protection of personal information (RPRP)

By default, that's the business owner. You can delegate the role to an employee. The RPRP's name and contact info must be available on your website.

2

Publish a privacy policy

It has to be written in clear, simple terms. It must explain what data you collect, why, how you protect it and how to have it deleted.

3

Get explicit consent

Before collecting personal information, you have to get the person's clear consent. Pre-checked boxes are NOT valid consent.

4

Limit collection to what's necessary

Only collect information that's strictly necessary for your activities. If you don't need the date of birth, don't ask for it.

5

Keep an incident log

In case of a data leak or privacy incident, you have to document it in a log and notify the Commission d'acces a l'information (CAI) and the people affected.

6

Run a privacy impact assessment (PIA)

Before any new project involving personal information (a new form, new software, etc.), assess the risks to privacy.

7

Respect the right to portability

People can ask to receive their data in a structured, commonly used format, or to transfer it to another organization.

8

De-indexing and the right to be forgotten

People can ask to have their data deleted and their information de-indexed from search engines in certain cases.

toncrm.io is Law 25-compliant by defaultTry it free
FIG 0.3 · CHECKLIST

Full compliance checklist

Governance
Name an RPRP (or confirm it's the owner)
Publish the RPRP's name on the website
Privacy policy
Write a policy in plain French
Publish the policy on the website (visible link)
Describe the types of data collected
Explain the purposes of the collection
Describe the security measures in place
Consent
Add a cookie banner to the site
Get consent BEFORE collecting (not after)
No pre-checked boxes in forms
Let people withdraw consent easily
Security
Encrypt sensitive data
Update software regularly
Limit data access (need-to-know basis)
Keep a log of privacy incidents
People's rights
A process to respond to access requests
A process to delete data on request
A process for data portability
FIG 0.4 · PENALTIES

Penalties for non-compliance

Law 25 provides for severe penalties:

10 M$
Maximum fine for a business
2% of revenue
Or 2% of worldwide revenue
Heads upPenalties apply even to small businesses. The CAI has already imposed administrative penalties on Quebec SMBs. Better to be compliant now.
FIG 0.5 · TOOLS

Tools to get compliant

Tiptoncrm.io includes a Law 25-compliant cookie banner, data encryption, explicit consent on forms and right-to-be-forgotten management. It's all built in by default.
FIG 0.6 · TRIAL

A CRM that's Law 25-compliant from day one

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