Privacy regulations continue to evolve worldwide as governments strengthen protections for personal information in response to increasing cyber threats, digital transformation, and growing consumer expectations. Organizations are collecting and processing more personal data than ever before through websites, mobile applications, cloud platforms, artificial intelligence (AI), Internet of Things (IoT) devices, customer relationship management (CRM) systems, and digital business processes. While this data enables organizations to innovate and deliver personalized experiences, it also increases the responsibility to manage personal information securely and transparently.

 

In Canada, one of the most significant privacy developments in recent years has been Quebec Law 25, formerly known as Bill 64. The legislation modernizes Quebec’s private-sector privacy framework and introduces comprehensive requirements that align more closely with global privacy regulations such as the General Data Protection Regulation (GDPR). It significantly expands organizational accountability, strengthens the rights of individuals, and increases penalties for non-compliance.

 

Organizations operating in Quebec or processing the personal information of Quebec residents must understand the law’s requirements and implement appropriate governance, security, and compliance measures. Compliance is no longer limited to publishing a privacy policy or obtaining consent. Organizations are expected to establish privacy governance programs, perform privacy impact assessments, appoint responsible individuals, manage third-party risks, respond to privacy incidents, and continuously monitor compliance.

 

Many organizations also need to comply with Quebec Law 25 alongside PIPEDA, ISO 27001, ISO 27701, SOC 2, PCI DSS, GDPR, and industry-specific cyber security frameworks. Managing these obligations through spreadsheets and disconnected documentation creates unnecessary complexity and increases the likelihood of compliance gaps.

 

This guide provides a detailed overview of Quebec Law 25, its requirements, implementation best practices, and how organizations can simplify privacy governance using a centralized Governance, Risk, and Compliance (GRC) platform.

 

 

What is Quebec Law 25?

 

Quebec Law 25 is Quebec’s modernized privacy legislation governing the protection of personal information in the private sector.

 

The law updates Quebec’s privacy framework to reflect today’s digital economy by introducing stronger privacy protections, expanded organizational responsibilities, and enhanced rights for individuals.

 

The legislation applies to organizations that collect, use, disclose, retain, or otherwise process personal information in Quebec.

 

Law 25 was implemented through a phased approach beginning in 2022, with additional requirements becoming effective over subsequent years.

 

The legislation is administered by the Commission d’accès à l’information du Québec (CAI).

 

Why Quebec Law 25 matters

 

Privacy has become a business issue rather than simply a legal obligation.

 

Customers expect organizations to handle personal information responsibly, regulators demand stronger accountability, and business partners increasingly evaluate privacy practices before entering commercial relationships.

 

Quebec Law 25 helps organizations build responsible privacy programs while increasing transparency regarding how personal information is managed.

 

Organizations that achieve compliance benefit from:

 

• Greater customer trust.
• Improved cyber security governance.
• Better operational resilience.
• Reduced regulatory risks.
• Stronger executive oversight.
• Increased confidence from partners and stakeholders.

 

Conversely, organizations that fail to comply may face significant financial penalties, regulatory investigations, reputational damage, and operational disruption.

 

Who must comply with Quebec Law 25?

 

Quebec Law 25 applies to private-sector organizations that collect, use, disclose, or retain personal information within Quebec.

 

The legislation may apply regardless of where an organization is headquartered if it processes the personal information of individuals located in Quebec.

 

Organizations commonly affected include:

 

• Technology companies.
• Financial institutions.
• Healthcare organizations.
• Manufacturers.
• Retail businesses.
• E-commerce companies.
• Telecommunications providers.
• Professional service firms.
• Educational organizations.
• SaaS providers.

 

Organizations operating nationally often need to comply with both Quebec Law 25 and federal privacy legislation such as PIPEDA.

 

What is personal information under Quebec Law 25?

 

Personal information refers to any information relating to an identifiable individual.

 

Examples include:

 

• Full names.
• Email addresses.
• Telephone numbers.
• Home addresses.
• Financial information.
• Government-issued identification.
• Health information.
• Employee records.
• Customer account information.
• Online identifiers.
• Location data.
• Purchase history.
• Biometric information.

 

Organizations should maintain accurate inventories of personal information throughout its lifecycle.

 

Key requirements of Quebec Law 25

 

Appointment of a privacy officer

 

Organizations must designate an individual responsible for ensuring compliance with Quebec Law 25.

 

By default, this responsibility falls to the organization’s highest-ranking executive unless delegated formally.

 

The designated individual oversees privacy governance, policies, incident response, and compliance activities.

 

Privacy governance program

 

Organizations must establish and maintain documented privacy governance policies and practices.

 

These policies should cover:

 

• Collection of personal information.
• Use and disclosure.
• Retention.
• Destruction.
• Roles and responsibilities.
• Complaint handling.
• Security safeguards.

 

Privacy governance should become part of the organization’s overall governance framework.

 

Privacy impact assessments (PIAs)

 

One of the most significant additions introduced by Quebec Law 25 is the requirement to perform Privacy Impact Assessments.

 

Organizations should conduct PIAs before implementing projects involving personal information, including:

 

• New information systems.
• Cloud migrations.
• Digital transformation initiatives.
• AI implementations.
• Cross-border data transfers.

 

Privacy Impact Assessments help organizations identify and mitigate privacy risks before deployment.

 

Consent requirements

 

Organizations must obtain clear, meaningful consent before collecting, using, or disclosing personal information unless another lawful basis applies.

 

Consent should be:

 

• Clear
• Free
• Informed
• Given for specific purposes

 

Organizations should also maintain records demonstrating consent where appropriate.

 

Transparency

 

Organizations must provide clear privacy notices explaining:

 

• What information is collected
• Why it is collected
• How it is used
• Who receives it
• Individual privacy rights

 

Transparency builds trust while supporting regulatory compliance.

 

Privacy by default

 

Where appropriate, organizations should configure systems to provide the highest level of privacy protection by default.

 

Individuals should not need to modify settings to obtain reasonable privacy protections.

 

Individual rights

 

Quebec Law 25 strengthens several privacy rights, including:

 

• Right of access.
• Right to correction.
• Right to withdraw consent.
• Right to data portability (under applicable conditions).
• Right to request deletion where appropriate.

 

Organizations should establish documented procedures for handling these requests efficiently.

 

Incident management

 

Organizations must establish procedures for detecting, assessing, documenting, and responding to privacy incidents.

 

Certain breaches may require notification to regulators and affected individuals where there is a risk of serious harm.

 

Maintaining documented incident response procedures improves organizational resilience.

 

 

Cross-border data transfers

 

Before transferring personal information outside Quebec, organizations must assess whether adequate privacy protection exists in the receiving jurisdiction.

 

This assessment frequently forms part of a Privacy Impact Assessment.

 

Security requirements under Quebec Law 25

 

Strong cyber security controls are essential for demonstrating compliance.

 

Organizations should implement administrative, physical, and technical safeguards appropriate to the sensitivity of personal information.

 

Examples include:

 

• Multi-factor authentication.
• Encryption.
• Identity and access management.
• Network security.
• Endpoint protection.
• Backup and recovery.
• Vulnerability management.
• Security monitoring.
• Logging and audit trails.

 

Cyber security governance and privacy governance should work together rather than operate independently.

 

Common challenges with Quebec Law 25 compliance

 

Organizations frequently encounter several implementation challenges.

 

Many struggle to identify where personal information exists throughout the organization.

 

Others find it difficult to coordinate privacy governance across legal, IT, compliance, cyber security, human resources, and business units.

 

Managing Privacy Impact Assessments, documenting consent, monitoring third-party risks, and maintaining evidence for audits also require considerable administrative effort.

 

Organizations relying on spreadsheets often experience duplicate work, inconsistent documentation, and reduced visibility into compliance activities.

 

Quebec Law 25 and other compliance frameworks

 

Quebec Law 25 overlaps with numerous privacy and cyber security standards.

 

Organizations commonly align compliance activities with:

 

PIPEDA

 

Organizations operating nationally frequently maintain compliance programs covering both federal and Quebec privacy legislation.

 

ISO 27001

 

ISO 27001 provides structured information security controls supporting privacy governance.

 

ISO 27701

 

ISO 27701 extends ISO 27001 by providing comprehensive privacy management guidance.

 

GDPR

 

Many organizations serving international customers align Quebec Law 25 requirements with GDPR due to similarities in governance and individual rights.

 

SOC 2

 

Technology companies often pursue SOC 2 while implementing Quebec Law 25 to demonstrate mature security and privacy practices.

 

Mapping controls across frameworks reduces duplication and improves efficiency.

 

Best practices for maintaining compliance

 

Organizations should establish privacy governance as an ongoing business function rather than treating compliance as a one-time project.

 

Best practices include maintaining accurate data inventories, conducting regular Privacy Impact Assessments, reviewing policies periodically, providing employee awareness training, monitoring third-party risks, performing internal audits, and continuously monitoring compliance controls.

 

Automation further strengthens compliance by reducing manual effort while improving visibility into governance activities.

 

How CyberArrow GRC simplifies Quebec Law 25 compliance

 

CyberArrow GRC helps organizations centralize governance, risk management, and privacy compliance within a single platform.

 

Instead of managing privacy activities through disconnected systems and spreadsheets, organizations gain a unified approach to compliance.

 

Centralized privacy governance

 

CyberArrow enables organizations to manage privacy policies, governance documentation, approvals, and accountability from one platform.

 

Privacy risk management

 

Organizations can identify, assess, monitor, and mitigate privacy risks using centralized workflows and dashboards.

 

Compliance monitoring

 

CyberArrow helps organizations manage Quebec Law 25 alongside PIPEDA, ISO 27001, ISO 27701, SOC 2, PCI DSS, GDPR, and other regulatory frameworks without duplicating effort.

 

Automated evidence collection

 

The platform streamlines compliance by automatically organizing documentation and maintaining audit-ready evidence.

 

Executive reporting

 

Real-time dashboards provide leadership with visibility into privacy maturity, compliance status, risk exposure, remediation progress, and governance performance.

 

Benefits of using a GRC platform for Quebec Law 25

 

Managing Quebec Law 25 through a centralized GRC platform delivers measurable operational benefits.

 

Organizations improve collaboration between legal, IT, cyber security, and compliance teams while reducing manual administrative work. Automated workflows improve consistency, continuous monitoring strengthens compliance visibility, and centralized reporting helps leadership make informed decisions based on real-time risk and compliance data.

 

As organizations continue expanding their digital operations, adopting a centralized GRC platform becomes essential for maintaining sustainable privacy governance.

 

See what our clients have to say about CyberArrow GRC:

 

Conclusion

 

Quebec Law 25 represents one of Canada’s most comprehensive privacy regulations and establishes significantly higher expectations for organizations managing personal information.

 

Compliance requires far more than obtaining consent or publishing a privacy policy. Organizations must establish mature privacy governance, perform Privacy Impact Assessments, strengthen cyber security controls, manage third-party risks, respond effectively to incidents, and continuously monitor compliance.

 

Organizations that treat privacy as an integral part of governance are better positioned to reduce regulatory risk, strengthen customer trust, and support long-term business growth.

 

CyberArrow GRC helps organizations simplify Quebec Law 25 compliance by centralizing governance, risk management, policy management, compliance monitoring, automated evidence collection, and audit readiness within a single platform.

 

Trusted by some of the world’s biggest brands across the United States, Europe, Africa, Asia, and the Middle East, CyberArrow empowers organizations to build scalable privacy and compliance programs that reduce manual effort, improve operational visibility, and maintain continuous compliance across multiple regulatory frameworks.

 

 

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