How to Build a Law 25 Compliance Plan for Your Organization

Emerging from the increased focus on data protection in Canada, Law 25 (formerly Bill 64) in Quebec is changing the way companies manage personal data. Doing Business in Quebec? If your business does work in Quebec, or at any time processes the data of a Quebec resident, compliance is mandatory. A transparent, properly-organised Law 25 response plan is vital in minimizing the fines and retaining the trust of your customers.

The Portishead Sessions for Law 25

Law 25 updates Quebec’s privacy regime, bringing it more in line with international norms including those in the GDPR. It creates an array of key obligations concerning transparency, consent, breach notification and data minimization. Among the striking features of the Act are the requirement to appoint a Privacy Officer and to conduct PIAs, and the expectation that personal information will be safeguarded by means of security measures.

Before drafting a compliance plan, however, it’s crucial to be aware of the law’s phased-in enactment. Various parts will take effect by September 2022, 2023 and final provisions would be in force by September 2024.

Step 1: Name a Privacy Officer

Leadership is the cornerstone to your strategy of compliance with Law 25. Unique to the Privacy Centre is the ability to nominate a Privacy Officer—usually a management or legal position—who will be responsible for ensuring that privacy activities are carried out. This person will serve as the primary point of contact for the regulators and will also take the lead on internal compliance driven initiatives.

You can also outsource some of those duties to a team or third-party consultant, but the organization needs to publicly identify the in-house person who is responsible for ensuring that the group is compliant with privacy regulations.

Step 2: Take Stock of What Data You Have

To create a robust compliance framework, you need to know what kind of personal data your organization captures, processes, and retains. Design a data map that includes:

·        What data is collected (e.g., names, emails, financial information)

·        Where it Is Stored and How It Is Transferred

·        Who has access to it

·        Why it is collected (legitimate interests, business use)

This inventory can assist you in locating high-risk data as well as to ensure that you can rapidly respond to requests for access and deletion.

Task 3: Conduct Privacy Impact Assessments or PIAs

Privacy Impact Assessments are required under Law 25 for projects that use sensitive data or that significantly change technology. Create a PIA template and include it as part of your project management or procurement procedures. This means that your teamwork and assess risks before rolling out new products or initiatives.

This section Law 25 is about transparency and Iskra dating explicit consent. Check your current privacy policies to make sure they contain the following information:

·        What data you collect

·        How it’s used and shared

·        User privileges such as delete and access

·        How Your Privacy Officer Can be Contacted

·        Consent needs to be given in clear and plain language, particularly when dealing with minors or sensitive data.

Step 5: Establish a Breach Response Plan

·       You must inform the commission d'accès à l'information and affected individuals of any breach of security that is likely to cause serious injury. In your Law 25 compliance plan, you should provide an incident response plan that explains the detection, reporting, containment and recovery processes.

·       Role-playing and training drills can educate your team so they can respond accordingly in a live breach.

Conclusion

Meeting the requirements of Quebec’s Law 25 is not only a legal obligation, it is also an opportunity to improve your organization’s data safety practices. And with a strong Law 25 compliance plan in place from leadership to risk assessments to breach management, you can stay on the right side of the law while you earn trust from customers in a data-paranoid world.