Quebec Privacy Regime (QC)

On September 21, 2022, Quebec’s Act to modernize legislative provisions as regards the protection of personal information (Act) was enacted. The Act’s provisions will become effective gradually over a two-year period, from September 22, 2022, to September 22, 2024.

Effective September 21, 2022,
Employers must:

  • Appoint a person in charge of the protection of personal information
  • Report any confidentiality incident or privacy breach to the Commission d’accès à l’informtation du Québec (CAI)

Employees may file a complaint with the CAI regarding protecting personal information.

As of September 22, 2023,

  • Employers must establish and implement a confidentiality policy that includes personal data management.
  • Employers must assess employee performance management tools, including computers, emails, and video surveillance.
  • Employers who use software, artificial intelligence, or another method involving automated processing of personal data must inform their employees of the type of personal information used to make the decision.
  • Any private sector organization that fails to comply with the Act risks incurring fines of up to the greater of $25 million or an amount corresponding to 4% of worldwide turnover for the preceding fiscal year.

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