Identify the applicable rules
Law 25 amended several Quebec laws. Rules for private businesses should not be confused with those for public bodies. The Commission d’accès à l’information outlines the main changes and their timelines.
Assess before building
For a business subject to the relevant law, acquiring, developing or redesigning an information system involving personal information requires a privacy impact assessment. The privacy officer must be involved from the outset. The CAI explains this role in its guidance for businesses.
Our practical recommendation is to map data flows before selecting tools: collection, use, access, retention and deletion. Include providers and transfers outside Quebec. Hosting a cloud service in Canada does not remove the need to examine those flows.
Keep useful evidence
A signed document is insufficient if the deployed system changes without review. Connect planned measures to actual controls: permissions, logging, retention and procedures for responding to requests. Reassess significant changes with the people responsible. Compliance is an ongoing process, not something a single product can guarantee.
Sources and features may change. Check the current version when planning your project. This article provides general guidance and does not replace legal analysis of your situation.
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